Chemical Tankers: Regulatory Update

Janet Strode

General Manager

International Parcel Tankers Association

• Application of inert gas

• Damage Stability Requirements for Tankers

• Review of IBC Code

• EU Acceptable List

• FOSFA and tank coatings

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APPLICATION OF INERT GAS TO CHEMICAL TANKERS AND SMALLER OIL

TANKERS

FP 56 (January 2013) finalised draft amendments to SOLAS:

Application of

inert gas

new oil tankers below 20,000

dwt

new chemical tankers

–lower size limit of 8,000 dwt

–vessels of less than 20,000 dwt to be allowed to use shore-supplied inert gas

–chemical tankers to be allowed to apply inert gas on completion of loading but before commencement of discharge

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SOLAS II/2 Reg.16.3.3.2

“….for chemical tankers constructed on or after [date of entry into force], the application of inert gas may take place after the cargo tank has been loaded, but before commencement of unloading and shall continue to be applied until that cargo tank has been purged of all flammable vapours before gas-freeing. Only nitrogen is acceptable as inert gas under this provision."

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FSS Code Chapter 15

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Requirements applying to all

systems

additional requirements for flue

gas systems

additional requirements for nitrogen systems

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Amendments to be formally approved and adopted by Maritime

Safety Committee

Entry into force January 2016?

Oxygen dependent inhibitors

IBC Code Reg 15.13 Cargoes protected by additives

15.13.5 When a product containing an oxygen dependent inhibitor is to be carried in a ship:-

.1 [constructed on or after date of entry into force of the new SOLAS IG requirements], and for which inerting is required as per paragraph 11.1.1 of this Code, the application of inert gas shall not take place before loading or during the voyage, but shall be applied before commencement of unloading*.

.2 [constructed before the entry into force of the SOLAS amendments for IG], the product shall be carried without inertion (in tanks of a size not greater than 3,000 m3). Such cargo shall not be carried in a tank requiring inertion under the requirements of SOLAS Chapter II-2*

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MSC/Circ.879 MEPC/Circ.348 (1998) Equivalency arrangements for Styrene Monomer

Styrene monomer can be carried in a chemical tanker with cargo tanks over 3,000 provided that the oxygen content inside those tanks is maintained between 2% and 8%

– upon completion of loading and taking of product samples, the vapour space must be checked to ensure that the oxygen level is within acceptable limits (2% to 8%).

– during the voyage, the vapour space oxygen content must be monitored and recorded at least twice per day, at least 8 hours apart; and

– temperature and pressure readings of the cargo tanks must be monitored and recorded at least twice per day, at least 8 hours apart.

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Damage Stability of Tankers

SLF 55 • Agreed to amendments to MARPOL Annex I

and IBC Code to require damage stability instruments on ships

“All ships subject to the Code shall be fitted with a stability instrument capable of verifying compliance with intact and damage stability requirements approved by the Administration and having regard to the performance standards recommended by the Organization”

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Entry into force:

• January 2016?

Existing ships:

• first scheduled renewal survey after date of entry into force, but not later than 5 years after EIF

Instrument installed before date of EIF

• no need to replace provided it can verify compliance with intact and damage stability to the satisfaction of the Administration

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Guidelines for verification of damage stability requirements for tankers

Part 1:

Guidelines for preparation and approval of tanker

damage stability calculations

tankers constructed on or after [date to be decided]

Part 2:

Guidelines for operation and demonstration of damage

stability compliance.

all tankers

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REVIEW OF THE IBC CODE

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Changes to GESAMP hazard profiles

2007 amendments applied on pollution

grounds only

New criteria for assigning carriage

requirements applied to new products only

Dual standard

product list

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– around 18% of products would be affected

– 17 products moved from chapter 18 to chapter 17

– “significant number” increase in ship type of one level

– “small number” increase in ship type of 2 levels

– A few cases, increase in tank type from 2G to 1G

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If all the products in the Code were re-evaluated according to the current criteria:

Are the measures triggered appropriate to the hazard identified?

prime triggers for higher ship/tank types are inhalation and dermal toxicity

Is product likely to be inhaled or come into

contact with skin?

If No, why are measures necessary?

If Yes, is a higher ship/tank type the best

way to deal with the hazard?

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the ESPH Group began to examine Saturated Vapour Concentration (SVC) and product behaviour in water

No need for stringent carriage

requirements

low Saturated Vapour

Concentration

likely to dissolve or

evaporate in water

• Amendments developed to criteria in chapter 21 and applied on trial basis to products in Big Movers List

• Results: – 4 products moved from Type 3 to Type 2

– 1 product moved from chapter 18 to Type 3

– 1 product moved from Type 3 to chapter 18

– Many products alterations to carriage requirements:

– Closed gauging

– Controlled venting

– Toxic vapour detection

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Increased special requirements • 15.17: Increased ventilation

• 15.19: Overflow control

• 15.12: Toxic products

– Exhaust openings

– Vapour return line

– Stowage • Not adjacent to oil fuel tanks

• Separate piping systems

• Separate vent systems

– PV valves minimum 0.02 gauge

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What now? • Apply this approach on a trial basis to all products

in IBC Code – systematic evaluation of all aspects of the carriage

requirements

• Amendment of chapter 21 of the IBC Code (criteria for assigning carriage requirements)

• Amendments to carriage requirements in chapters 17 and 18

Review of Chapter 21 of IBC Code

• ESPH 19 (Oct 2013)

• BLG 18 (FEB 2014)

Review of chapters 17 and 18 of the IBC Code

• ESPH 20 (Oct 2014

• BLG 19 (Feb 2015)

Approval of amendments

• MSC and MEPC 2015

Adoption of Amendments

• MSC and MEPC 2015-206

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Earliest Entry into Force: 2018

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• 1990’s • Lypophylic substances (Vegetable oil)

• 2013 • Paraffin wax • Polyisobutylene

Paraffin Wax

Poly(4+)isobutylene

Residues can be discharged into sea providing cargo does not meet criteria for high viscosity or solidifying substances at discharge temperature

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Ship type 2 Pollution Category Y

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PIB

“ RSPB believes the risk of PIB is seriously underestimated and we are calling on the International Maritime Organisation (IMO) to urgently review the hazard classification of PIB, and implement regulations that prevent any further tragic and wholly avoidable incidents like the one just witnessed.”

A serious hazard to seabirds and the marine environment

Calls for more amendments to carriage

requirements on pollution grounds?

• Cannot “cherry pick”

• Carriage requirements assigned according to product characteristics as outlined in GESAMP Hazard Profile

• Many more products would be captured by any proposed amendments to criteria

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Carriage of Oils

and Fats

EU Acceptable List

• European Commission asked the European Food Safety Agency (EFSA) to review all the products in the EU List according to Codex criteria

• Completed November 2012

• Most products considered acceptable

However……

• calcium lignosulphonate: – no longer considered acceptable due to variations in

its composition and lack of information on its impurities and potential reaction with fats and oils

• wine lees and montan wax: – insufficient information available on their composition

to conclude that they would not be of health concern when used as a previous cargo

• Carnauba wax and silicon dioxide: – safety concerns because of insolubility in water and

high melting point, which may affect the efficiency of tank cleaning

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• EFSA have recommended that restrictions placed on potable water, caustic soda and caustic potash be lifted

• However, there will be no change to current situation until new EU list is issued – unlikely to be before mid-2014

• Still no indication of when new products proposed for inclusion will be considered

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Acceptability of HCP Coatings

• Discussions ongoing over number of years into whether highly cross-linked polymer (HCP) coatings should be treated in the same way as stainless steel in respect of Styrene and EDC as last cargoes

• FOSFA Technical committee agreed that a new criterion should be defined, based on performance of a coating with respect to absorption, desorption and retention (ADR) properties

DRAFT AMENDED VERSION OF THE 'RESTRICTIONS’

Banned list • Restrictions beyond the Immediate Previous Cargo

– Leaded products shall not be carried as the three previous cargoes. – * Ethylene Dichloride and Styrene Monomer shall not be carried as the three

previous cargoes in organic coated tanks, or as the last cargo in stainless steel, inorganic or technically equivalent organic coated tanks.

Acceptable list • Restrictions beyond the Immediate Previous Cargo

– Leaded products shall not be carried as the three previous cargoes. – Ethylene Dichloride and Styrene Monomer (both of which are on the FOSFA

Banned List) shall not be carried as the three previous cargoes in organic coated tanks, or as the last cargo in stainless steel, inorganic or technically equivalent organic coated tanks.

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Thank you for your attention

25 years serving the chemical tanker industry

www.ipta.org.uk

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