Compromise proposal for post MARPOL Annex II Vegetable Oils

The Netherlands, Panama and US have submitted to MEPC 52 a proposal regarding the transport of vegetable oils. Despite the findings and conclusions of MEPC 51, the vegetable oil industry remains concerned as to whether there will be sufficient tonnage to cope with the proposed changes within MARPOL Annex II.

In the event of a specific shortage of tonnage to transport an identified vegetable oil, regulation 2 (7) of the current text of MARPOL Annex II provides a mechanism by which an Administration may modify or delay for a specific period the application of the revised requirements for the carriage of that cargo.

The new proposal is thus a follow-up to the proposal made by The Netherlands and Panama at MEPC 51 last March. At MEPC 51 it was proposed that the identified cargoes be allowed to utilise Type 3 ships with double hulls that meet the dimensions (b/15 or 6 m whichever is less for double bottom and the 760 mm minimum for sides) for Type 2 chemical tankers. This could only be granted by an Administration via Regulation 4 of the revised text after they were able to justify an exemption or delay in accordance with the amendments to MARPOL Annex II.

The new Regulation 4 to Annex II (proposed at MEPC 51) allowed for the following exemptions

  • the Administration may modify or delay for a specified period the application of such amendment... if immediate application of such amendment is considered unreasonable or impracticable…
  • the Administration... shall submit a report giving details of the ships concerned, the cargoes certified to carry, the trade in which each ship is engaged and the justification for the relaxation....

The MEPC 52 submission amends this to some extent:

  • The Administration may exempt ships from the carriage requirements under regulation 11 (i.e. the IBC Code construction, equipment and operation requirements) for ships certified to carry individually identified vegetable oils..., provided the ship complies with the following conditions:
  1. They meet all requirements for ship type 3... except for cargo tank location;
  2. The cargo tanks shall be located at the following (double hull distances)...;
  3. The relevant certificate shall indicate the exemption granted.

INTERTANKO is seeking clarification to see if new double hull product tankers would otherwise have to meet full chemical tanker requirements to carry the cargoes in question. Under the new proposal vessels will have to be double hull but not ship type 2 double hull (no tank size limits, no damage stability requirement). They will, however, have to meet the relevant stripping limits.

Contact: Margaret Doyle