INTERTANKO MARPOL Annex II chemical tonnage study at the IMO

As members are aware INTERTANKO has conducted a chemical tonnage impact study taking into account the proposed revisions within MARPOL Annex II for pollution and ship type criteria.

Link to Weekly News article No 8/2004 and  to download a copy of the INTERTANKO submission and summary of our study of the impact of reclassification of products..

INTERTANKO submitted this paper (MEPC 51/6) to IMO which was discussed this week at MEPC 51.  A lot of interest and comments have been published in the shipping press recently before the paper was discussed at this session. Despite the findings and conclusions the vegetable oil Industry still felt that there would be insufficient tonnage to cope with the proposed changes within MARPOL Annex II.

In order to pre-empt questions raised over INTERTANKO’s submission Click hereto view the text that was read out when the paper was introduced.

One of the main points made in the intervention was that vessels below 10,000 dwt had not been taken into account in the  study. The effect of this means that the margins shown in the conclusions would be significantly increased if these smaller vessels were to be included in the study. The reason INTERTANKO did not include vessels below 10,000 dwt is to ensure that such vessels are not counted twice within the study due to their general coastal trade characteristics. This means that the margins shown in the study are conservative. To quantify this, there are 1,095 chemical tankers below 10,000 DWT equating to 5.1 million dwt.

The committee recollected that over the years concerns had been expressed regarding potential disruptions to trade by these proposed revisions but the committee noted that such concerns had not been substantiated by any submitted documents.

Following considerable debate within the plenary session on the INTERTANKO study  and some proposals by attending member states for further study to be undertaken by the IMO, it was eventually agreed by an overwhelming majority that no further study was needed and that the INTERTANKO study confirmed the previous information submitted by IPTA and CEFIC.

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

Some states noted that the application of this regulation should not be used to permit phased out single hull MARPOL ANNEX 1 tankers to transport vegetable oils, and that the practice of this regulation should be restricted to IBC Code Type 3 ships meeting the dimensional requirements of IBC Type 2 ships with regard to double bottom and double side protection. It was recognised that such an option would only be used where it was demonstrated that there was a shortage of tonnage available to transport an identified vegetable oil.

However, the Committee is in the process of reviewing the final report and a final conclusion to its deliberations will be given in next week’s Weekly News.

The committee reviewed the drafted text to the new IBC code and agreed that the changes to the IBC Code are amendments and will not be viewed as a new code.

The draft changes have been approved by this session and will be put forward for adoption as a pink paper at MEPC 52 in December 2004

Link to Howard Snaith’s presentation on INTERTANKO’s IMO submission MEPC 51/11/6 - INTERTANKO tonnage study - 

Link to Weekly News article No 8/2004and  to download a copy of the INTERTANKO submission and summary of our study of the impact of reclassification of products..

Contacts: Howard Snaith, Margaret Doyle