MARPOL Annex II revisions carriage restriction updates

As advised in our article in Weekly NEWS No. 1/2007 of 5 January 2007 regarding the revisions to MARPOL Annex II, and specifically the question pertaining to the 3000m3 limitations, we wrote to The Netherlands Government (click here to view letter), Singapore and the United Kingdom in December 2006 highlighting our concerns and raising some specific questions.


We have since received a reply from The Netherlands (click here to view).


Singapore has recently advised that they have issued Shipping Circular No. 10/2006, which outlines the Singapore position regarding Annex II reg. 4.1.3. However, regarding the question of allowing Type 2 tankers to carry more than 3000 cubic metres of footnote "k" vegetable oils in each cargo tank, for the time being Singapore will be monitoring how other flag and port administrations are dealing with the issue.


For members' information the INTERTANKO views regarding the limitations for the carriage of individually identified foot note "k" vegetable oils are as follows:

Irrespective of the IMO ship Type, 2 or 3, if the cargo tanks are bigger than 3000m3 INTERTANKO believes that the ship should be allowed to fill the cargo tanks to an operational level of 98%, if required, as not being allowed to do so would have the following detrimental effects upon both the safety of the vessel and the environment:

  • A reduction in the stability of the vessel would be introduced by virtue of the slack tanks and increased free surface effect.
  • It would have a negative effect upon the environment due to:

(a) cargo sloshing en route in the slack tank - the heated cargo would cool on the upper parts of the cargo tank bulkheads creating "cold clingage" resulting in increased cargo residue;

(b) more cargo tanks having to be loaded, which would also increase cargo residue to the environment because the stripping limitations are based on a minimum residual quantity per cargo tank not upon the total volume carried.

  • Adequate curing of the cargo tank coatings would not be possible also due to the sloshing effect.


However, a unified view within the industry on this issue is not yet available and we currently expect it to be discussed at the IMO's Bulk Liquids and Gases Sub-Committee (BLG) meeting in April 2007, where we hope a pragmatic approach will be adopted as outlined above.


Contact: Howard Snaith or Margaret Doyle