the revisions to marpol annex ii

November 2006

The Revisions toMARPOL Annex II

(entry into force 1/1/2007)

A Practical Guide

INTERTANKO would like to thankStolt-Nielsen Transportation Group BV

for sponsoring this publication.

INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide November 2006 1

The Revisions to MARPOL Annex II(entry into force 1/1/2007)

A Practical Guide

ContentsPage

1. Disclaimer/copyright notice 12. Preface 23. INTERTANKO Chemical Tanker Committees 34. INTERTANKO 45. Market analysis section 56. INTERTANKO MARPOL Annex II tonnage impact study 107. Joint INTERTANKO, CCA, Norwegian stripping limitation survey 108. MARPOL Annex II Summary and Overview 119. IMO Circular Letter 2730 1510. Pollution category/ship type changes 1711 USCG NVIC 3012. MEPC 55 Working Paper 8 3013. Tripartite Agreement for the provisional assessment of liquid substances 3114. INTERTANKO MARPOL Annex II waste reception facility survey 3315. Possible scenarios for existing ships under the Amended IBC Code requirements 3816. P&A Manual application and Certificates of Fitness 3917. Biofuels – an update 40

1. Disclaimer/copyright noticeNo part of this publication may be reproduced, stored in a retrieval system or transmitted in any form or by any means

electronic, mechanical, photocopying, recording or otherwise without the prior written permission of the International

Association of Independent Tanker Owners (INTERTANKO).

It does not purport to be comprehensive or to render legal advice. Whilst every effort has been made to ensure that the

information contained in this publication is correct INTERTANKO does not accept any responsibility for any errors or

omissions or any consequences resulting therefrom.

© INTERTANKO 2006

INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide2

2. PrefaceThe transportation of chemicals is technically and logistically different from the transportation of oil and oil products. Chemical

tankers are more advanced in many ways. The cargoes may be hazardous and noxious chemicals or such products as edible

oils and fats. A common characteristic of these cargoes is that they tend to be high value and require sophisticated handling

for safety, health and loss prevention reasons. The ships are complex and technologically advanced due to the degree of

subdivision created by 50+ cargo tanks. They are inherently more robust vessels compared to bulk tankers. This large number

of cargo tanks, sophisticated cargo operating systems and supply of deck services enable them to carry a broad range of chemicals,

in accordance with the requirements of the International Code for the Construction and Equipment of Ships Carrying Dangerous

Cargoes in Bulk (IBC/BCH Code), and in strict accordance with anti-pollution regulations under MARPOL Annex II.

Every chemical cargo carried requires careful consideration during the planning process and loading. Some are temperature

sensitive some are semi-gases, some need to be inhibited, some are sensitive to water, and some react with each other. Checks

also need to be made regarding the chemical ship type, (i.e. category I, II or III), tank coating compatibility, cross

compatibility with other cargoes carried, environmental controls if required (inerting). In addition, the tank construction

type for containment, venting requirements, gauging equipment, vapour detection, compatible fire protection medium, heating

requirements, inhibition requirements, density limitations of the product in relation to the cargo tank construction, and pumping

requirements are important considerations. Most of this information is set out in the IBC Code (The International Code

for the Construction and Equipment of Ships Carrying Dangerous Chemicals in Bulk) or BCH Code (Code for the

Construction and Equipment of Ships Carrying Dangerous Chemicals in Bulk).

November 2006

Chemical tanker fleet by hull – numberDWT cat DB DH DS SH No info Total5,000-10,000 174 360 4 37 47 62210,000-19,999 94 369 3 40 50620,000-29,999 41 101 1 23 2 16830,000-39,999 46 313 10 20 1 39040,000 + 35 271 10 11 327Total 390 1,414 28 131 50 2,013

Chemical tanker fleet by hull – dwtDWT segment DB DH DS SH No info. Grand Total5,000-10,000 1,245,535 2,656,408 29,556 258,679 318,488 4,508,66710,000-19,999 1,399,329 5,452,673 39,070 592,957 7,484,02920,000-29,999 1,058,239 2,573,600 29,900 668,084 59,996 4,389,81930,000-39,999 1,636,298 11,159,267 391,355 690,802 37,314 13,915,03640,000 + 1,525,061 12,511,339 447,058 518,147 15,001,605Grand Total 6,864,462 34,353,287 936,939 2,728,669 415,798 45,299,155

NB includes tankers with IMO type that may not trade in Annex II productsSource: Chemindex (Inge Steensland)

Figure 1

INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide 3

3. INTERTANKO Chemical Tanker Committees

For many years INTERTANKO represented its members' chemical tanker interests through an open forum within

INTERTANKO called the Chemical Tanker Owners' Advisory Group (CTOAG). However, the number of chemical tankers

within INTERTANKO's membership has been steadily increasing. To ensure that INTERTANKO provides optimal support

and representation for its chemical tanker owners, it was decided in 2002 to reconsider the then current methods of work

within INTERTANKO.

Accordingly, the CTOAG reviewed its terms of reference. As a result the CTOAG was elevated from an open forum to the

full status of a committee within INTERTANKO. This new committee is called the Chemical Tanker Committee (CTC) and

meets three times a year rotating between Europe, the Far East and the United States.

To ensure that the Americas are fully represented, INTERTANKO inaugurated the Chemical Tanker Sub-committee – Americas

(CTSCA) in April 2003. This CTC Sub-committee aims to support the work of the CTC whilst handling specific regional

issues that arise from both North and South America.

INTERTANKO also has NGO status at the International Maritime Organization (IMO) and participates in all the IMO meetings.

INTERTANKO regularly logs over 3,500 man-hours representing its members at the IMO each year.

INTERTANKO is also represented in Washington and Europe, and maintains close contacts with the U.S. Coast Guard Chemical

Tanker Advisory Committee. In addition we have a close working relationship with the Federation of Oil Seeds and Fats

Association (FOSFA) and the National Institute of Oilseed Products (NIOP) in the United States.

The major chemical trade routes end in Asia, India, the Middle East and South America from the U.S. and Europe. There

is a considerable bilateral trade between the U.S. and Europe. Seagoing transport from the Arabian Gulf to destinations both

in the East and in the west is increasing as new production capacity is being developed in this area. The industry has also

seen a large production increase in the Far East with a considerable share of this volume going to overseas markets.

November 2006

Figure 2

Source: Chemindex/Inge Steensland


Figure 3 (Courtesy of Odfjell Tankers)

4. INTERTANKO

How does INTERTANKO provide its support function? Through an effective team of experts in relevant fields ranging from

marine biologists, master mariners, maritime lawyers, naval architects, brokers, statisticians, political scientists, and charter

party experts and administrative support.

These are supplemented by a team of political consultants in Brussels, legislative representation in Washington DC, and external

consultants with chemicals and oil expertise. INTERTANKO has two principal offices in Oslo and London as well as regional

offices in Singapore and Washington DC.

The Chemical Tanker Committee reports directly to INTERTANKO’s Council ensuring correct process in all its policy decisions.

INTERTANKO's MISSION is to:

Provide leadership to the Tanker Industry in serving the world with the safe, environmentally sound and efficient seaborne

transportation of oil, gas and chemical products.

VISION FOR THE TANKER INDUSTRY

A responsible, sustainable and respected Tanker Industry, committed to continuous improvement and constructively

influencing its future.

INTERTANKO AND ITS MEMBERS GOALS

1. Be the representative forum of choice for all quality tanker owners and managers.

2. Enhance public and political awareness of the importance and positive performance of the tanker industry.

3. Promote balanced terms of trade and a competitive, transparent and sustainable tanker industry.

4. Lead the development, acceptance and implementation of uniform, worldwide international tanker standards

5. Lead in establishing and maintaining partnerships, cooperation and open and constructive dialogue with the relevant maritime

authorities, organizations, associations and special interest groups.

November 2006


INTERTANKO MEMBERS will:

6. Lead the continuous improvement of the Tanker Industry’s performance in striving to achieve the goals of: � Zero pollution� Zero deaths� Zero detentions

7. Deliver the highest quality services to meet the expectations of their stakeholders.

8. Promote the availability and utilization of personnel with the highest quality marine skills and competencies

5. Market Analysis Section

The major focus on the reclassification of products, becoming effective 1 January 2007, is the requirement to transport vegetable

oils in double hull chemical tankers.

1 January 2007, reclassification of products

The table below shows the reclassification of the products representing the biggest volumes from 1 January 2007.

The vegetable oil trade represents close to 50 million tonnes. The palm oil trade represents some 60%, soybean oil some

20%, and sunflower seed 7%. Palm kernel oil, peanut oil, olive oil, cottonseed oil and coconut oil represent the remaining

23% of the market. The graphs below show a steady increase in trade of these oils in recent years.

November 2006

Figure 4 (mts=million tons).

Type of change Reclassified from to Products and volumes

Re-categorisation of vegoils, D to IMO type 2 (or IMO type 3 with DH Palm oil 27 m tssoft oils and fats meeting operational requirements) Soybean oil 10 m ts

Sunflowerseed 3 m ts+Other veg oils 6 m ts+Tallow 2 m ts+Fatty acids, paraffin wax Total appox. 50m ts)

Other products with no previous IBC ch18 to IMO type IMO 3 Methanol 17 m tsrequirement to IMO ship type MTBE 5.5 m ts

UAN 5 m tsMEG/TEG/DEG 5 m tsEthyl acetate, Methyl ethyl ketone 1 m ts

Change of ship type requirements IMO type 3 to 2 Xylenes > 5 m ts

No requirements No change Molasses 6 m tsEthanol 3 m ts

Source: Inge Steensland AS


Malaysia and Indonesia each account for just under one-third of the vegetable oils exported each, Argentine some 15%,

and Brazil some 5%.

The biggest importing areas are Europe (9 m tonnes) China (7.5 m tonnes) and India 6 m tonnes), which together take about

half the imports. Vegetable oils are imported by a multitude of countries the majority of which, and the smaller ones, come

under the "other" category in the graph below:

November 2006

Figure 5

Figure 6

Figure 7

Source: United States Department of Agriculture




Chinese Vegetable Oil Consumption Continues to Grow

According to the United States Department of Agriculture, in the last 7 years, China's per capita vegetable oil consumption

has almost doubled from 9.5 kg per person per year in 1999/00, to a forecast 17.1 kg in 2006/07. China's per capita vegetable

oil consumption has reached levels similar to Japan and South Korea in a relatively short time. If China's per capita oil

consumption were to reach that of the Taiwanese, China would consume 52% more vegetable oil, or 35 million tons in 2006/07

instead of the 23 million tons estimated. A large portion of the vegetable oil growth is being captured by restaurants. China's

growing middle class, with its increasing disposable income, eats more meals outside the home.

Soybean oil and palm oil dominate China's vegetable oil market. Soybean oil's expected market share in 2006/07 is 37%,

a 10% increase in consumption over that of last year. Palm oil's market share is forecast to grow by 2% over the current

year to 24% and is expected to grow 14% year-over-year. The growth in other vegetable oils is forecast to be fairly constant

for year-over-year levels. Palm oil demand is increasing primarily due to its lower price along with its use in processed foods,

for example, packaged ready-to-eat noodles. Until now the low shipping costs for imported Indonesian and Malaysian palm

oil give it an advantage over imported oil. A new regulatory regime with requirements for the carriage of vegetable oils with

more expensive tankers will to some extent change this situation. The growth in soybean oil consumption will be captured

primarily by domestic crushing facilities using imported soybeans.

China represents some 19% of soybean oil production and 17% of world imports, whereas India represents only 3% of

production and 20% of imports.

Transportation of vegoils

The world's biggest vegetable oil trades are the transportation of palm oil from Malaysia and Indonesia. This market has

increased from some 27.5 million tonnes in 2005 to 29.4 million tonnes in 2006. The largest part of this trade is carried

out by tankers with double hulls, and this share increased from 53% in 2005 to 60% in 2006. The Malaysian export of palm

oil is projected to increase from 12,634 million tonnes in 2004/05 to 13,770 million tonnes in 2005/06 and 13,840 million

tonnes in 2006/07, according to the Malaysian Palm Oil Board.

November 2006

Country Per capita vegetable oil Percentage growthconsumption (kg)1999/00 2006/07* 1999/00 to 2006/07*

Japan 16.8 17.7 5%South Korea 13.4 17.5 31%Taiwan 24.7 26.5 7%China 9.5 17.1 8%

Figure 8


Vegoils are currently to a great extent being transported by single hull product tankers with no IMO type, in particular in

vegoil trade from South America. Figure 10 shows that only 16% of the vegoil from South American is transported by double

chemical tankers hull tankers and with IMO type.

A 30,000 tanker trading between Rio de Janeiro and Shanghai can make just over 5 trips per year. The carriage of nine

million tonnes over this distance would require some 58 such tankers, just under 2 m dwt, which is just over what will be

delivered in 2005 or just over the amount of tonnage that so far has been converted to double hull

Chemical tanker fleet

The chemical tanker fleet is 48% (21.6 m dwt) IMO Type 3 tankers, 32% (14.3 m dwt) IMO Type 2/3 tankers, and 16%

(7.1 m dwt) Type 2 tankers. Larger chemical tankers above 30,000 dwt are 61% IMO Type 3, whereas the smaller chemical

tankers 10,000-19,999 dwt are 60% IMO Type 2/3 and 22% Type 2.

November 2006

Malaysia/Indonesian palm oil trade by hull typeHull type 2005 - 27.5 m ts 2006 - 29.4 m ts

m tonnes Share m tonnes ShareSH 3.6 13% 4.1 14%DB 8.8 32% 7.1 24%DH 14.6 53% 17.6 60%Unknown 0.5 2% 0.6 2%Total 27.5 100% 29.4 100%

The shares were estimated based on reported spot fixtures only - approximately 5 million tonnes of the trade.Source: Inge Steensland AS

South American vegoil tradeShip type M tonnes ShareDH and IMO type tanks 1.9 16%DB to be converted to DH 1.8 15%Non-DH and IMO centertanks 2.8 23%Non-DH and non-IMO type 5.5 46%Total 12.0 100%

Source: Inge Steensland AS

Figure 9

Figure 10

Figure 11

Source: Chemindex / Inge Steensland AS


According to Inge Steensland AS, the chemical tanker fleet of 26.2 m dwt with just over 1,400 tankers is increasing fast.

This fleet includes both dedicated chemical tankers and swing tonnage tankers that are also trading in petroleum products.

There have been record deliveries of about 1.175 m dwt or some 90 ships per year over the last three years. The deliveries

are projected to increase to some 2.175 m dwt or some 133-167 ships annually in the years 2006, 2007 and 2008. Already

the order book for 2009 is 70 tankers or two million dwt. The chemical tanker fleet is modern with an average age of some

11.5 years. Some 66% of the fleet is below 15 years and just under 8% more than 25 years old. The confirmed orders represent

some 37% of the current fleet. If tankers are sold for decommissioning at the age of 28 years, some 0.6 to 1.0m is expected

to be removed annually until 2011.

November 2006

Figure 12

Source: Chemindex / Inge Steensland AS The graphs include tankers with IMO type that may not trade inAnnex II products

Figure 13


6. INTERTANKO MARPOL Annex II Tonnage Impact Study

INTERTANKO conducted a tonnage impact study in 2004 with regard to the then current proposed revisions to MARPOL

Annex II. Once the tonnage impact study was completed this was submitted to the IMO's Marine Environmental Protection

Committee as document MEPC 51/11/6. The sole aim of the study was to assist IMO in its decision-making and re-categorisation

process. The submission we made to IMO is available on our web site.

At that time GESAMP had yet to reach a conclusion regarding the categorisation of some of the vegetable oils. For this reason

some of these products were shown as provisional and some were shown as a ship Type 2/3. That is why INTERTANKO

ran two alternative conclusions to the study.

The INTERTANKO study was performed to produce an impartial information paper with the most up-to-date accurate

information available to assist the IMO in its decision-making process. On the basis of this study the IMO decided to create

a compromise solution within the revisions that would allow certain IMO Ship Type 3 ships to carry footnote "k" vegetable

oils (see section 8 of this booklet for full details.)

7. Joint INTERTANKO, CCA, Norwegian Shipping Association stripping capability survey

Based upon the conclusions drawn from the joint INTERTANKO, Chemical Carriers Association (CCA) and Norwegian

Shipping Association stripping study, it was agreed that technology was available to reduce the current stripping limitations

for new buildings only, to which MARPOL Annex II applied, to 75 litres.

November 2006

Figure 14


This was supported by other industry representatives and government organisations at the IMO Bulk Liquid Gas Sub-committee

in 2002. Accordingly, it was agreed that the revised stripping requirements should be set at 75 litres for new buildings within

the new revisions to MARPOL Annex II.

8. MARPOL Annex II, a Summary and Overview

The work on the revision of MARPOL Annex II and the International Code for the Construction and Equipment of Ships

Carrying Dangerous Chemicals in Bulk (IBC Code) commenced almost 15 years ago. It concluded with the adoption of the

revised MARPOL Annex II by the Marine Environmental Protection Committee (MEPC 52 in October 2004) and the adoption

of the revised IBC Code by both MEPC 52 and the Maritime Safety Committee (MSC 79 in December 2004). The revised

requirements will accordingly enter into force and take effect from 1 January 2007.

The current IBC Code contains 5 pollution categories: A, B, C, D and an Appendix III. (Appendix III lists products to which

the IBC Code does not apply). As a result of the re-evaluation process of the existing MARPOL Annex II products by the

GESAMP Working Group on the Evaluation of the Hazards of Harmful Substances Carried by Ships (GESAMP/EHS), existing

products will be re-categorised into a new "3 + 1" category system.

At MEPC 49 in 2003 this "3+1" pollution category system (X, Y, Z + OS) was agreed upon. The fourth category, OS (Other

Substances), contains only 8 harmless products (apple juice, clay slurry, coal slurry, dextrose solution, glucose solution, kaoline

slurry, molasses, water).

The revision of Annex II will therefore replace the current 5 pollution category system; (A, B, C and D, and Appendix III

products) with a revised 4 pollution category system; (X, Y, Z and OS (Other Substances)).

Products defined as "floaters" and "persistent floaters", which include vegetable oils, will be assigned to ship type 2 and pollution

category Y. (See later explanation regarding IMO Ship Type 3 carriage).

Oil-Like Substances

Oil-like substances will not exist under the revisions. Hence products like for instance Xylene, Toluene, Pentanes will all

require ships holding Certificate of Fitness (CoF). Before these products culd also be carried on product tankers as oil products.

Vegetable oils

Vegetable oils will be specified and are upgraded from Appendix III (of the IBC Code) to Category Y. After 1 January 2007

all ships loading IBC Code cargoes will need to hold a Certificate of Fitness (CoF) issued under the revised requirements.

The replacing of the current 5-category system (A,B,C,D and Appendix III products) with the new pollution categories has

also affected what products can be carried in the different IMO ship types. The IBC Code provides standards for the construction

of three types of chemical tankers generally known as IMO ship Types 1, 2 and 3.

November 2006


An IMO Ship Type 1 is a chemical tanker intended for the transportation of products considered to present the greatest

overall hazard, and Type 2 and Type 3 for products of progressively lesser hazards. The quantity of cargo required to be

carried in a Type 1 ship should not exceed 1,250 m3 in any one tank.

An IMO Ship Type 2 is intended to transport products with appreciably severe environmental and safety hazards which

require significant preventive measures to preclude escape of such cargo. The quantity of cargo required to be carried in a

Type 2 ship should not exceed 3000 m3 in any one tank.

An IMO Ship Type 3 is a chemical tanker intended to transport products with sufficiently severe environmental and safety

hazards. These products require a moderate degree of containment to increase survival capability in a damaged condition.

There is no filling restriction for chemicals assigned to Ship Type 3.

Ship Type Cargo Tank Location

The revised IBC Code indicates that the cargo tank location shall be as follows:

"2.6 Location of cargo tanks

2.6.1 Cargo tanks shall be located at the following distances inboard:

.1 Type 1 ships: from the side shell plating, not less than the transverse extent of damage specified in 2.5.1.1.2, (B/5 or 11.5m

whichever is less), and from the moulded line of the bottom shell plating at centreline, not less than the vertical extent of

damage specified in 2.5.1.2.3, (B/15 or 6 m whichever is less), and nowhere less than 760 mm from the shell plating. This

requirement does not apply to the tanks for diluted slops arising from tank washing.

.2 Type 2 ships: from the moulded line of the bottom shell plating at centreline, not less than the vertical extent of damage

specified in 2.5.1.2.3, (B/15 or 6 m which ever is less), and nowhere less than 760 mm from the shell plating. This requirement

does not apply to the tanks for diluted slops arising from tank washing.

.3 Type 3 ships: no requirement"

Figure 15 below illustrates these differences

November 2006

B /5

B /15 B /15

760mm

Type I Tank Configuration Type II Tank Configuration Type III Tank Configuration

Tank Configuration

B/5 or 11.5m(Whichever isless, but nowhere less than760mm)

Cargo

Figure 15


Regulation 4.1.3 in MARPOL Annex II (carriage requirements for individually identified

vegetable oils)

The vegetable oils listed in Chapter 17 of the IBC Code will be regulated as Pollution Category Y and Ship Type 2. It was

agreed at the IMO that the individually identified vegetable oils should in principle be carried in Ship Type 2 as mentioned

earlier.

However, via regulation 4.1.3 of the revised MARPOL Annex II, an Administration "may" allow the carriage of these substances

in a Ship Type 3, but ONLY if the ship complies with all the requirements for a Ship Type 3, as identified in the IBC Code,

except for cargo tank location.

The cargo tank location shall be in accordance with regulation 4.1.3.2 of the revised MARPOL Annex II, but these ships must

be constructed with double sides meeting the requirements for IMO Ship Type 2 vessels and double bottom requirements of

B/15 or 2 metres (whichever is the lesser) and the Certificate of Fitness (CoF) shall indicate the exemption granted.

This new regulation was proposed to alleviate any potential tonnage shortage in the vegetable oil trade resulting from the

re-categorisation of many vegetable oils in the revised Annex II.

Regulation 4.1.3 will not change the environmental protection requirements of the revised Annex II. It will, however, allow,

subject to administration approval, IMO Type 3 ships that meet the environmental protection requirements of an IMO Type

2 ship to carry specified vegetable oils. Without the new regulation 4.1.3 all such cargoes (those indicated by footnote "k"

in the revised IBC Code) would have required carriage in IMO Type 2 ships.

An administration may exempt ships from the carriage requirements under Regulation 11 for ships certified to carry

individually identified vegetable oils identified by the relevant footnote "k" in Chapter 17 of the IBC Code, provided the

ship complies with the following conditions:

"1. Subject to this regulation, the noxious liquid substance (NLS) tanker shall meet all requirements for Ship Type 3 as identified

in the IBC Code except for cargo tank location;

2. Under this regulation, cargo tanks shall be located at the following distances inboard. The entire cargo tank length shall

be protected by ballast tanks or spaces other than tanks that carry oil as follows:

1. Wing tanks or spaces shall be arranged such that cargo tanks are located inboard of the moulded line of the side shell plating

nowhere less than 760 mm; and

2. Double bottom tanks or spaces shall be arranged such that the distance between the bottom of the cargo tanks and the

moulded line of the bottom shell plating measured at right angles to the bottom shell plating is not less than B/15 (m) or 2.0

m at the centreline, whichever is the lesser. The minimum distance shall be 1.0 metre.

The relevant certificate shall indicate the exemption granted."

November 2006


Stripping requirements

Every ship constructed before 1 July 1986 shall be provided with a pumping and piping arrangement to ensure that each

tank certified for the carriage of substances in Category X or Y does not retain a quantity of residue in excess of 300 litres

in the tank and its associated piping and that each tank certified for the carriage of substances in Category Z does not retain

a quantity of residue in excess of 900 litres in the tank and its associated piping. A performance test shall be required to be

carried out.

Every ship constructed on or after 1 July 1986 but before 1 January 2007 shall be provided with a pumping and piping

arrangement to ensure that each tank certified for the carriage of substances in Category X or Y does not retain a quantity

of residue in excess of 100 litres in the tank and its associated piping and that each tank certified for the carriage of substances

in Category Z does not retain a quantity of residue in excess of 300 litres in the tank and its associated piping.

Every ship constructed on or after 1 January 2007 shall be provided with a pumping and piping arrangement to ensure that

each tank certified for the carriage of substances in Category X, Y or Z does not retain a quantity of residue in excess of

75 litres in the tank and its associated piping.

After 1 January 2007, the stripping performance requirements will apply to all tankers holding a Certificate of Fitness (CoF).

Underwater discharge

The underwater discharge arrangement for tank washing water is required for pollution categories X and Y for ships keel-

laid before 1 January 2007. New buildings will require such for all pollution categories X, Y and Z. Category Z products

will be exempted from the underwater discharge requirement, although new vessels will be required to comply.

The waiver possibilities in respect of stripping performance and the underwater discharge arrangement for dedicated ships

engaged in the carriage of products not involving the cleaning of cargo tanks will remain unchanged.

Figure 16 Revised MARPOL & IBC Discharge & Stripping Requirements

November 2006

Category BCH Ships Constructed Existing IBC Constructed New Buildings Constructed Ships Other thanbefore 31/7/1986 from 31/7/1986 from 1/1/2007 Chemical Tankers

but before 1/1/2007 constructedbefore 1/1/2007

X Pre Wash Pre Wash Pre Wash Carriage ProhibitedStrip to 350 Litres Strip to 150 Litres Strip to 75 Litres

12 mile 12 mile 12 mile25m water depth 25m water depth 25m water depth7 knots, en-route 7 knots, en-route 7 knots, en-route

Y Pre Wash for solidifying for Pre Wash for solidifying for Pre Wash for solidifying for Carriage Prohibitedhigh viscosity substances high viscosity substances high viscosity substances

Strip to 350 Litres Strip to 150 Litres Strip to 75 Litres12 mile 12 mile 12 mile

25m water depth 25m water depth 25m water depth 7 knots, en-route 7 knots, en-route 7 knots, en-route

Z Strip to 950 Litres Strip to 350 Litres Strip to 75 Litres Strip to12 mile 12 mile 12 mile Maximum Extent

25m water depth 25m water depth 25m water depth 12 mile7 knots, en-route 7 knots, en-route 7 knots, en-route 25m water depth

7 knots, en-route

OS No carriage Requirements No Carriage Requirements No Carriage Requirements

Underwater Only X and Y cargoes Only X and Y cargoes X,Y and Z cargoesDischargeRequired


As figure 16 indicates, the 75 litre stripping limit is required for all new tankers with keels laid after 1 January 2007 (existing

IBC Code ships will retain existing stripping limits of 150 litres for categories X, Y and 350 litres for category Z).

No quantity requirement shall apply to a ship other than a chemical tanker which was constructed before 1 January 2007

but which cannot meet the requirements for the pumping and piping arrangements for substances in Category Z (referred

in paragraphs 1 and 2 of the revised Regulation 12). Compliance is deemed to be reached if the tank is emptied to the most

practicable extent.

9. IMO Circular Letter 2730

On 3 July 2006 the International Maritime Organization (IMO) issued Circular Letter No. 2730 to all IMO Member States

and all Parties to MARPOL 73/78, the United Nations (the IMO parent organisation) and its specialised agencies, all

Intergovernmental Organisations and Non-Governmental Organisations with Consultative Status.

The subject of the Circular Letter is the "Entry into force of the revised Annex II to MARPOL 73/78 and the amended IBC

Code". This document mirrors the information contained in many of the INTERTANKO documents forwarded over the

last three years on this very important issue. We provide an overview of the Circular Letter below.

The three-page Circular Letter gives a synopsis of the adoption of the revisions by Resolutions MEPC.119 (52) and

MSC.176 (79), explains that they were accepted on 1 July 2006, and reiterates that they will enter into force on 1 January

2007. As the Circular Letter states, “The purpose of this circular letter is to explain the principal points of the revision and

to ensure that all parties are aware of their obligations as from 1 January 2007”.

The Circular also explains: � Why the revisions were considered necessary; the purpose of the work of the Joint Group of Experts on the Scientific

Aspects of Marine Environmental Protection (GESAMP) in revising its hazard evaluation procedure for chemical

products carried by ships to bring it in line with the U.N.'s Globally Harmonised System of Classification and Labelling

of Chemicals (GHS); � The subsequent revaluation of all of the products listed in the current IBC Code and in the relevant sections of the

MEPC.2/Circular as well as the re-evaluation of products; � The relative development of a new pollution categorisation system and criteria for assigning products to these new

categories; � The revision of stripping requirements and discharge criteria and why it was necessary to make a number of amendments

to the IBC Code, in particular the criteria for ship typing from an environmental point of view;� That in the process of re-evaluation of products it was revealed that a large number of products in the IBC Code

had incomplete GESAMP hazard profiles because data related to safety and/or pollution issues were missing and

the subsequent efforts over the next three years by IMO and industry to provide the missing data, allowing the GESAMP

hazard profiles to be completed. � The fate of any products omitted from the amended IBC Code due to missing safety and/or pollution data. They

November 2006


will appear in List 1 of the MEPC.2/Circular that will be issued on 31 December 2006. Products with missing data

omitted from the amended IBC Code that have not yet been re-evaluated can be carried under a tripartite agreement

but no such agreement should be established until confirmation has been received by the Administration that the

required data have been submitted to the GESAMP/EHS Working Group. � That BLG.1/Circ.19 was recently issued listing those products which to date have been classified or re-classified since

the adoption of the amended IBC Code in 2004 (see article in this issue). The purpose of this circular is to assist

national Administrations and other stakeholders in their preparations for the entry into force of the revised

MARPOL Annex II and the amended IBC Code.� Why regulation 4.1.3 of MARPOL Annex II was developed, to allow unmodified oils and fats displaying the footnote

(k) in column ‘e’ in Chapter 17 of the amended IBC Code to be carried on ship type 3 chemical tankers, on the

condition that these chemical tankers meet all the requirements for ship type 3 and are provided with double bottom

and double sides meeting the specifications laid out in regulation 4.1.3. � It also reminds that the vast majority of noxious liquid substances will now be subject to regulation; and revised

stripping limits will greatly reduce the amount of residues that vessels will be allowed to discharge into the marine

environment.

The Circular Letter also reiterates that the 24th session of the IMO Assembly recognised the importance of this provision,

and that the 54th session of the Marine Environment Protection Committee confirmed that: .1 when an Administration agrees

on an exemption, regulation 4.1.3 is the only regulation for existing and new ships to be used for vegetable oils identified by

footnote (k) in column e in chapter 17 of the amended IBC Code.

The document also clarifies that regulations 4.1.1 and 4.1.2 were only developed to allow Administrations to submit to the

Organization a relaxation of certain provisions of an amendment under restricted conditions, for a specified period and for

existing ships only, and that these regulations were not permitted to be used for the vegetable oils under footnote (k).

Lastly the Circular Letter reiterates that before 1 January 2007, vessels certified to carry noxious liquid substances identified

in Chapter 17 of the IBC Code will have to be issued with new Certificates of Fitness and P&A Manuals reflecting the changes

in categorisation of products, and this should be taken into account when preparations for entry into force are undertaken.

November 2006

Type of concern Action to be taken in relation to existing certificate Action to be taken in relation to certificate under the revised MARPOL Annex II

Certificate valid until N/A Issue a certificate under the revised MARPOL Annex IIafter 1 January 2007 starting as from 1 January 2007 with an identical expiry

date as the existing certificate.

Renewal survey on or Extend the validity of the existing Issue a new certificate under the revised MARPOLafter 1 July 2006 certificate to 1 January 2007. Annex II with an expiry date of 5 years from the survey date.

Change of flag on or Replace the coversheet of the current certificate R Issue a new certificate under the revised MARPOLafter 1 July 2006 with an extension of the validity to 1 January 2007. Annex II with an expiry date of 5 years from the renewal

survey date.

Delivery of a new vessel Issue a short term certificate under the current Issue a full term certificate alid for 5 years after the(e.g. 1 July 2006) MARPOL Annex II valid until 1 January 2007. initial survey.

Figure 17


10. Pollution Category/Ship type changes

November 2006

Product New Poll Cat New ship type Old poll cat Old ship TypeAcetic acid Z 3 D 3Acetic anhydride Z 2 D 2Acetochlor X 2 A 2Acetone cyanohydrin Y 2 A 2Acetonitrile Z 2 III 2Acetonitrile (low purity grade) Y 3 D 2Acid oil mixture from soyabean, corn (maize) and sunflower oil refining Y 2 D n/aAcrylamide solution (50% or less) Y 2 D 2Acrylic acid Y 2 D 3Acrylonitrile Y 2 B 2Acrylonitrile-Styrene copolymer dispersion in polyether polyol Y 3 D n/aAdiponitrile Z 3 D 3Alachlor technical (90% or more) X 2 B 3Alcohol (C9-C11) poly (2.5-9) ethoxylate Y 3 B 3Alcohol (C6-C17) (secondary) poly(3-6)ethoxylates Y 2 A 2Alcohol (C6-C17) (secondary) poly(7-12)ethoxylates Y 2 B 3Alcohol (C12-C16) poly(1-6)ethoxylates Y 2 A 2Alcohol (C12-C16) poly(20+)ethoxylates Y 3 C 3Alcohol (C12-C16) poly(7-19)ethoxylates Y 2 B 3Alcohols (C13+) Y 2 III n/aAlcohols (C8-C11) primary, linear and essentially linear Y 2Alcohols (C12-C13) primary, linear and essentially linear Y 2Alcohols (C14-C18) primary, linear and essentially linear Y 2Alkanes (C6-C9) X 2 C 3Iso- and cyclo-alkanes (C10-C11) Z 3 18 - D n/aIso- and cyclo-alkanes (C12+) Z 3 18 -III n/an-Alkanes (C10+) Z 3 18 - III n/aAlkenyl (C16-C20) succinic anhydride Z 3 D 3Alkaryl polyethers (C9-C20) Y 2 B 3Alkenyl (C1 1+) amide X 2 18 -D n/aAlkyl acrylate-vinylpyridine copolymer in toluene Y 2 C 3Alkylaryl phosphate mixtures (more than 40% Diphenyl tolylphosphate, less than 0.02% ortho-isomers) X 1 A 1Alkylated (C4-C9) hindered phenols Y 2 D 3Alkylbenzene, alkylindane, alkylindene mixture (each C12-C17) Z 3 A 2Alkyl benzene distillation bottoms Y 2Alkylbenzene mixtures (containing at least 50% of toluene) Y 3Alkyl (C3-C4) benzenes Y 2 A 3Alkyl (C5-C8) benzenes X 2 A 2Alkyl(C9+)benzenes Y 3 III n/aAlkyl (C11-C17) benzene sulphonic acid Y 2 C 3Alkylbenzene sulphonic acid, sodium salt solution Y 2 C 3Alkyl (C12+) dimethylamine X 1 A 1Alkyl dithiocarbamate (C19-C35) Y 3 D n/aAlkyldithiothiadiazole (C6-C24) Y 3 D n/aAlkyl ester copolymer (C4-C20) Y 2 D n/aAlkyl (C7-C9) nitrates Y 2 B 2

Table 1

The IBC Code Chapters 17 and 18 A comparison of the old and new ship type and pollution category.

This reflects the latest chapters drafted for review and approval by MEPC 55 (MEPC 55 WP 8).Products where there is no information regarding old pollution and ship type, are either new submissions or data was not

found in the existing IBC or the most current MEPC. 2. Circ

INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide18 November 2006

Alkyl (C8-C10)/(C12-C14):(40% or less/60% or more)polyglucoside solution (55% or less) Y 3 B 3Alkyl (C8-C10)/(C12-C14):(60% or more/40% or less)polyglucoside solution(55% or less) Y 3 C 3Alkyl (C8-C40) phenol sulphide Z 3 D n/aAlkyl (C8-C9) phenylamine in aromatic solvents Y 2 A 3Alkyl(C7-C1 1)phenol poly(4-12) ethoxylate Y 2 B 3Alkyl (C9-C15) phenyl propoxylate Z 3 III n/aAlkyl (C8-C10)/(C12-C14):(50%/50%) polyglucosidesolution (55% or less) Y 3 C 3Alkyl (C12-C14) polyglucoside solution (55% or less) Y 3 B 3Alkyl (C8-C10) polyglucoside solution (65% or less). Y 3 C 3Alkyl(C 10-C20, saturated and unsaturated) phosphite Y 2 C 3Alkyl sulphonic acid ester of phenol Y 3 III n/aAllyl alcohol Y 2 B 2Allyl chloride Y 2 B 2Aluminium sulphate solution Y 2 D n/a2-(2-Aminoethoxy) ethanol Z 3 D 3Aminoethyldiethanolamine/Aminoethylethanolamine solution Z 3 D 3Aminoethyl ethanolamine Z 3 D 3N-Aminoethylpiperazine Z 3 D 32-Amino-2-methyl-1 -propanol Z 3 D n/aAmmonia aqueous (28% or less) Y 2 C 3Ammonium hydrogen phosphate solution Z 3 D n/aAmmonium lignosulphonate solutions Z 3 III n/aAmmonium nitrate solution (93% or less) Z 2 D 2Ammonium polyphosphate solution Z 3 D n/aAmmonium sulphate solution Z 3 D n/aAmmonium sulphide solution (45% or less) Y 2 B 2Ammonium thiosulphate solution (60% or less) Z 3 C 3Amyl acetate (all isomers) Y 3 C 3n-Amyl alcohol Z 3 D n/aAmyl alcohol, primary Z 3 D n/asec-Amyl alcohol Z 3 D n/atert-Amyl alcohol Z 3 III n/atert-Amyl methyl ether X 2 C 3Aniline Y 2 C 2Aryl polyolefins (C1 1-C50) Y 2 D n/aAviation alkylates (C8 paraffins and iso-paraffins BPT 95 - 120°C) X 2 C 3Barium long chain (C11-C50) alkaryl sulphonate Y 2 B 2Benzene and mixtures having 10% benzene or more (i) Y 3 C 3Benzene sulphonyl chloride Z 3 D 3Benzenetricarboxylic acid, trioctyl ester Y 2 III n/aBenzyl acetate Y 2 C 3Benzyl alcohol Y 3 C 3Brake fluid base mix: Poly(2-8)alkylene (C2-C3) glycols/Polyalkylene(C2-C10) glycols monoalkyl (C1-C4) ethers and their borate esters Z 3 D n/aBromochloromethane Z 3 D 3Butene oligomer X 2 B 3Butyl acetate (all isomers) Y 3 C 3Butyl acrylate (all isomers) Y 2 B 2tert-Butyl alcohol Z 3 III n/aButylamine (all isomers) Y 2 C 2Butylbenzene (all isomers) X 2 A 3Butyl benzyl phthalate X 2 A 2Butyl butyrate (all isomers) Y 3 B 3Butyl/Decyl/Cetyl/Eicosyl methacrylate mixture Y 2 D 3Butylene glycol Z 3 D n/a1,2-Butylene oxide Y 3 C 3n-Butyl ether Y 3 C 3

INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide 19November 2006

Butyl methacrylate Z 3 D 3n-Butyl propionate Y 3 C 3Butyraldehyde (all isomers) Y 3 C 3Butyric acid Y 3 D 3gamma-Butyrolactone Y 3 D n/aCalcium carbonate slurry Z 3 III n/aCalcium hydroxide slurry Z 3 D n/aCalcium hypochlorite solution (15% or less) Y 2 C 3Calcium hypochlorite solution (more than 15%) X 1 B 3Calcium lignosulphonate solutions Z 3 III n/aCalcium long-chain alkaryl sulphonate (C11-C50) Z 3 D n/aCalcium long-chain alkyl(C5-C10) phenate Y 3 C 3Calcium long-chain alkyl(C11 -C40) phenate Z 3 D n/aCalcium long-chain alkyl phenate sulphide (C8-C40) Y 2 D n/aCalcium long-chain alkyl salicylate (C13+) Y 2 C 3Calcium nitrate/Magnesium nitrate/Potassium chloride solution Z 3 III n/aepsilon-Caprolactam (molten or aqueous solutions) Z 3 D n/aCarbolic oil Y 2 A 2Carbon disulphide Y 2 B 2Carbon tetrachloride Y 2 B 3Cashew nut shell oil (untreated) Y 2 D n/aCastor oil Y 2 (k) D n/aCetyl/Eicosyl methacrylate mixture Y 2Chlorinated paraffins (C10-C13) X 1 A 1Chlorinated paraffins (C14-C17) (with 50% chlorine or more,and less than 1% C13 or shorter chains) X 1 D n/aChloroacetic acid (80% or less) Y 2 C 2Chlorobenzene Y 2 B 3Chloroform Y 3 B 3Chlorohydrins (crude) Y 2 D 24-Chloro-2-methylphenoxyacetic acid, dimethylamine salt solution Y 2 C 3o-Chloronitrobenzene Y 2 B 21-(4-Chlorophenyl)-4,4- dimethyl-pentan-3-one Y 2 B 32- or 3-Chloropropionic acid Z 3 C 3Chlorosulphonic acid Y 1 C 1m-Chlorotoluene Y 2 B 3o-Chlorotoluene Y 2 A 3p-Chlorotoluene Y 2 B 2Chlorotoluenes (mixed isomers) Y 2 A 2Choline chloride solutions Z 3 D n/aCitric acid (70% or less) Z 3 D n/aCoal tar X 2 A 2Coal tar pitch (molten) X 2 D 3Coal tar naphtha solvent Y 2 B 3Cocoa Butter Y 2 (k) D n/aCoconut oil Y 2 (k) D n/aCoconut oil fatty acid Y 2 C 3Coconut oil fatty acid methyl ester Y 2 D n/aCopper salt of long chain (C17+) alkanoic acid Y 2 D N/aCorn Oil Y 2 (k) D N/aCotton seed oil Y 2 (k) D N/aCreosote (coal tar) X 2 A 2Cresols (all isomers) Y 2 A 2Cresylic acid, dephenolized Y 2 A 2Cresylic acid, sodium salt solution Y 2 A 2Crotonaldehyde Y 2 A 21,5,9-Cyclododecatriene X 1 A 1Cycloheptane X 2 C 3Cyclohexane Y 2 C 3Cyclohexanol Y 2 D n/a


Cyclohexanone Z 3 D 3Cyclohexanone, Cyclohexanol mixture Y 3 D 3Cyclohexyl acetate Y 3 B 3Cyclohexylamine Y 3 C 31,3-Cyclopentadiene dimer (molten) Y 2 B 2Cyclopentane Y 2 C 3Cyclopentene Y 2 B 3p-Cymene Y 2 C 3Decahydronaphthalene Y 2 D n/aDecanoic acid X 2 C 3Decene X 2 B 3Decyl acrylate X 1 A 2Decyl alcohol (all isomers) Y 2 B 3Decyloxytetrahydrothiophene dioxide X 2 A 2Diacetone alcohol Z 3 D n/aDialkyl (C8-C9) diphenylamines Z 3 D N/aDialkyl (C7-C13) phthalates X 2 D n/aDibromomethane Y 2 C 2Dibutylamine Y 3 C 3Dibutyl hydrogen phosphonate Y 3 B 32,6 -Di-tertbutylphenol X 1 A 1Dibutyl phthalate X 2 A 2Dichlorobenzene (all isomers) X 2 B 23,4-Dichloro-1-butene Y 2 B 31,1-Dichloroethane Y 3 D 3Dichloroethyl ether Y 2 B 21,6-Dichlorohexane Y 2 B 22,2'-Dichloroisopropyl ether Y 2 C 2Dichloromethane Y 3 D 32,4-Dichlorophenol Y 2 A 22,4-Dichlorophenoxyacetic acid, diethanolamine salt solution Y 3 A 32,4-Dichlorophenoxyacetic acid, dimethylamine salt solution (70% or less) Y 3 A 32,4-Dichlorophenoxyacetic acid, triisopropanolamine salt solution Y 3 A 31, 1 -Dichloropropane Y 2 C 21,2-Dichloropropane Y 2 C 21,3-Dichloropropene X 2 B 2Dichloropropene/Dichloropropane mixtures X 2 B 22,2-Dichloropropionic acid Y 3 D 3Diethanolamine Y 3 D 3Diethylamine Y 3 C 3Diethylaminoethanol Y 2 C 32,6-Diethylaniline Y 3 C 3Diethylbenzene Y 2 A 3Diethylene glycol dibutyl ether Z 3 D n/aDiethylene glycol diethyl ether Z 3 III n/aDiethylene glycol phthalate Y 3 D n/aDiethylenetriamine Y 3 D 3Diethylenetriaminepentaacetic acid, pentasodium salt solution Z 3 III n/aDiethyl ether Z 2 D 2Di-(2-ethylhexyl) adipate Y 2 D n/aDi-(2-ethylhexyl) phosphoric acid Y 2 C 3Diethyl phthalate Y 2 C 3Diethyl sulphate Y 2 B 2Diglycidyl ether of bisphenol A X 2 B 3Diglycidyl ether of bisphenol F Y 2 B 3Diheptyl phthalate Y 2 D n/aDi-n-hexyl adipate X 1 B 3Dihexyl phthalate Y 2 III n/aDiisobutylamine Y 2 C 2Diisobutylene Y 2 B 3


Diisobutyl ketone Y 3 D n/aDiisobutyl phthalate X 2 B 3Diisononyl adipate Y 2 D n/aDiisooctyl phthalate Y 2 III n/aDiisopropanolamine Z 3 C 3Diisopropylamine Y 2 C 2Diisopropylbenzene (all isomers) X 2 A 2Diisopropylnaphthalene Y 2 D N/aN,N-Dimethylacetamide Z 3 D 3N,N-Dimethylacetamide solution (40% or less) Z 3 D 3Dimethyl adipate X 2 B 3Dimethylamine solution (45% or less) Y 3 C 3Dimethylamine solution (greater than 45% but not greater than 55%) Y 2 C 2Dimethylamine solution (greater than 55% but not greater than 65%) Y 2 C 2N,N-Dimethylcyclohexylamine Y 2 C 2Dimethyl disulphide Y 2 B 3N,N-Dimethyldodecylamine X 1 A 1Dimethylethanolamine Y 3 D 3Dimethylformamide Y 3 D 3Dimethyl glutarate Y 3 C 3Dimethyl hydrogen phosphite Y 3 B 3Dimethyl octanoic acid Y 2 C 3Dimethyl phthalate Y 3 C 3Dimethylpolysiloxane Y 3 III n/a2,2-Dimethylpropane-1,3-diol (molten or solution) Z 3 D n/aDimethyl succinate Y 3 C 3Dinitrotoluene (molten) X 2 A 2Dinonyl phthalate Y 2 D n/aDioctyl phthalate X 2 III n/a1,4-Dioxane Y 2 D 2Dipentene Y 3 C 3Diphenyl X 2 A 1Diphenylamine (molten) Y 2 B 3Diphenylamine, reaction product with 2,2,4-Trimethylpentene Y 1 A 1Diphenylamines, alkylated Y 2 A 2Diphenyl/Diphenyl ether mixtures X 2 A 1Diphenyl ether X 2 A 3Diphenyl ether/Diphenyl phenyl ether mixture X 2 A 3Diphenylmethane diisocyanate Y 2 B 2Diphenylol propane-epichlorohydrin resins X 2 B 3Di-n-propylamine Y 2 C 3Dipropylene glycol Z 3 III n/aDistilled resin oil Y 2 D n/a2,6-Di-tert-butylphenol X 1Dithiocarbamate ester (C7-C35) X 2 A 2Ditridecyl adipate Y 2 III n/aDitridecyl phthalate Y 2 D n/aDiundecyl phthalate Y 2 D n/aDodecane (all isomers) Y 2 III n/atert-Dodecanethiol X 1 A 1Dodecene (all isomers) X 2 B 3Dodecyl alcohol Y 2 B 3Dodecylamine/Tetradecylamine mixture Y 2 A 2Dodecylbenzene Z 3 III n/aDodecyl diphenyl ether disulphonate solution X 2 A 2Dodecyl hydroxypropyl sulphide X 2 A 1Dodecyl methacrylate Z 3 III 3Dodecyl/Octadecyl methacrylate (mixture) Z 3 D 3Dodecyl/Pentadecyl methacrylate mixture Y 2 III 3Dodecyl phenol X 2 A 1


Dodecyl Xylene Y 2 III n/aDrilling brines (containing zinc salts) X 2 B 3Drilling brines, including:calcium bromide solution, calciumchloride solution and sodium chl soln Z 3 III n/aEpichlorohydrin Y 2 A 2Ethanolamine Y 3 D 32-Ethoxyethyl acetate Y 3 C 3Ethoxylated long chain (C16+) alkyloxyalkylamine Y 2 D n/aEthyl acetate Z 3 D n/aEthyl acetoacetate Z 3 D n/aEthyl acrylate Y 2 A 2Ethylamine Y 2 C 2Ethylamine solutions (72% or less) Y 2 C 2Ethyl amyl ketone Y 3 C 3Ethylbenzene Y 2 B 3Ethyl tert-butyl ether Y 3 C 3Ethyl butyrate Y 3 C 3Ethylcyclohexane Y 2 C 3N-Ethylcyclohexylamine Y 2 D 3S-Ethyl dipropylthiocarbamate Y 2 C 3Ethylene chlorohydrin Y 2 C 2Ethylene cyanohydrin Y 3 D 3Ethylenediamine Y 2 C 2Ethylenediaminetetraacetic acid, tetrasodium salt solution Y 3 D n/aEthylene dibromide Y 2 B 2Ethylene dichloride Y 2 B 2Ethylene glycol Y 3 D n/aEthylene glycol acetate Y 3 D n/aEthylene glycol butyl ether acetate Y 3 C 3Ethylene glycol diacetate Y 3 C 3Ethylene glycol methyl ether acetate Y 3 C 3Ethylene glycol monoalkyl ethers Y 3 D 3Ethylene glycol phenyl ether Z 3 D n/aEthylene glycol phenyl ether/Diethylene glycol phenyl ether mixture Z 3 D n/aEthylene oxide/Propylene oxide mixture with an ethylene oxidecontent of not more than 30% by mass Y 2 C 2Ethylene-Vinyl acetate copolymer (emulsion) Y 3 III n/aEthyl-3-ethoxypropionate Y 3 C 32-Ethylhexanoic acid Y 3 D n/a2-Ethylhexyl acrylate Y 3 B 32-Ethylhexylamine Y 2 B 22-Ethyl-2-(hydroxymethyl) propane-1,3-diol, C8-C10 ester Y 2 D n/aEthylidene norbornene Y 2 B 3Ethyl methacrylate Y 3 D 3N-Ethylmethylallylamine Y 2 C 22-Ethyl-3-propylacrolein Y 2 A 3Ethyl toluene Y 2 B 3Fatty acid (saturated C13+) Y 2 III n/aFatty acid methyl esters (m) Y 2 D n/aFatty acids, C12+ Y 3Fatty acids, C16+ Fraction Y 2Fatty acid (saturated C13+) Y 2 III n/aFatty acids C8-C10 Fraction Y 2Fatty acids, essentially linear,C6-C18, 2-ethylhexyl ester. Y 2 D n/aFerric chloride solutions Y 3 C 3Ferric nitrate/Nitric acid solution Y 2 C 2Fish oil Y 2 (k) D n/aFlourosilic acid (20-30%) in water solution Y 3 C 3Formaldehyde solutions (45% or less) Y 3 C 3Formamide Y 3 D n/a


Formic acid Y 3 D 3Furfural Y 3 C 3Furfuryl alcohol Y 3 C 3Glucitol/glycerol blend propoxylated (containing less than 10 % amines) Z 3Glutaraldehyde solutions (50% or less) Y 3 D 3Glycerol monooleate Y 2 D n/aGlycerol propoxylated Z 3Glycerol propoxylated and ethoxylated Z 3Glycerol/Sucrose Blend propoxylated and ethoxylated Z 3Glyceryl triacetate Z 3 III n/aGlycidyl ester of C 10 trialkylacetic acid Y 2 B 3Glycine, sodium salt solution Z 3 III n/aGlycolic acid solution (70% or less) Z 3 D 3Glyoxal solution (40% or less) Y 3 D n/aGlyoxylic acid solution (50 % or less) Y 3 D 3Glyphosate solution (not containing surfactant) Y 2 D n/aGroundnut oil Y 2 (k) D n/aHeptane (all isomers) X 2 C 3n-Heptanoic acid Z 3 D n/aHeptanol (all isomers) (d) Y 3 C 3Heptene (all isomers) Y 3 C 3Heptyl acetate Y 2 B 31-Hexadecylnaphthalene / 1,4-bis(hexadecyl)naphthalene mixture Y 2 III n/aHexamethylenediamine adipate (50% in water) Z 3 D n/aHexamethylenediamine (molten) Y 2 C 2Hexamethylenediamine solution Y 3 C 3Hexamethylene diisocyanate Y 2 B 2Hexamethylene glycol Z 3 III n/aHexamethyleneimine Y 2 C 2Hexane (all isomers) Y 2 C 31,6-Hexanediol, distillation overheads Y 3 C 3Hexanoic acid Y 3 D n/aHexanol Y 3 D n/aHexene (all isomers) Y 3 C 3Hexyl acetate Y 2 B 3Hydrochloric acid Z 3 D 3Hydrogen peroxide solutions (over 8% but not over 60% by mass) Y 3 C 3Hydrogen peroxide solutions (over 60% but not over 70% by mass) Y 2 C 22-Hydroxyethyl acrylate Y 2 B 2N-(Hydroxyethyl)ethylenediaminetriacetic acid, trisodium salt solution Y 3 D n/a2-Hydroxy-4-(methylthio)butanoic acid Z 3 C 3Illipe oil Y 2 (k) D n/aIsoamyl alcohol Z 3 D n/aIsobutyl alcohol Z 3 III n/aIsobutyl formate Z 3 D n/aIsobutyl methacrylate Z 3 D 3Isophorone Y 3 C 3Isophoronediamine Y 3 D 3Isophorone diisocyanate X 2 B 2Isoprene Y 3 C 3Isopropanolamine Y 3 C 3Isopropyl acetate Z 3 D n/aIsopropylamine Y 2 C 2Isopropylamine (70% or less) solution Y 2 C 2Isopropylcyclohexane Y 2 C 3Isopropyl ether Y 3 D 3Lactic acid Z 3 D n/aLactonitrile solution (80% or less) Y 2 B 2Lard Y 2 (k) D n/aLatex, ammonia (1% or less), inhibited Y 3 D n/a


Latex: Carboxylated styrene-Butadiene copolymer;Styrene-Butadiene rubber Z 3 III n/aLauric acid X 2 B 3Ligninsulphonic acid, sodium salt solution Z 3 III n/aLinseed oil Y 2 (k) D n/aLiquid chemical wastes X 2 A 2Long-chain alkaryl polyether (C11-C20) Y 2 C 3Long-chain alkaryl sulphonic acid (C16-C60) Y 2 D n/aLong-chain alkylphenate/Phenol sulphide mixture Y 2 III n/aL-Lysine solution (60% or less) Z 3 D n/aMagnesium chloride solution Z 3 III n/aMagnesium long-chain alkaryl sulphonate (C11-C50) Y 2 D n/aMagnesium long-chain alkyl salicylate (C1 1+) Y 2 D n/aMaleic anhydride Y 3 D 3Mango kernel oil Y 2 (k) D n/aMercaptobenzothiazol, sodium salt solution X 2 B 3Mesityl oxide Z 3 D 3Metam sodium solution X 1 A 2Methacrylic acid Y 3 D 3Methacryclic acid - alkoxypoly (alkylene oxide) methacrylate copolymer,sodium salt aqueous solution (45% or less) Z 3 D n/aMethacrylic resin in Ethylene dichloride Y 2 D 2Methacrylonitrile Y 2 D 23-Methoxy-1-butanol Z 3 III n/a3-Methoxybutyl acetate Y 3 D n/aN-(2-Methoxy-1-methyl ethyl)-2-ethyl-6-methyl chloroacetanilide X 1Methyl acetate Z 3 III n/aMethyl acetoacetate Z 3 D n/aMethyl acrylate Y 2 B 2Methyl alcohol Y 3 D n/aMethylamine solutions (42% or less) Y 2 C 2Methylamyl acetate Y 2 C 3Methylamyl alcohol Z 3 C 3Methyl amyl ketone Z 3 B 3Methylbutenol Y 3 D n/aMethyl tert-butyl ether Z 3 D n/aMethyl butyl ketone Y 3 D n/aMethylbutynol Z 3 D n/aMethyl butyrate Y 3 C 3Methylcyclohexane Y 2 C 3Methylcyclopentadiene dimer Y 2 B 3Methylcyclopentadienyl manganese tricarbonyl X 1 A 1Methyl diethanolamine Y 3 D 32-Methyl-6-ethyl aniline Y 3 C 3Methyl ethyl ketone Z 3 III n/a2-Methyl-5-ethyl pyridine Y 3 B 3Methyl formate Z 2 D 22-Methyl-2-hydroxy-3 -butyne Z 3 III 3Methyl isobutyl ketone Z 3 D n/aMethyl methacrylate Y 2 D 23 -Methyl-3 -methoxybutanol Z 3 III n/aMethyl naphthalene (molten) X 2 A 22-Methyl-1,3-propanediol Z 3 III n/a2-Methylpyridine Z 2 D 23-Methylpyridine Z 2 C 24-Methylpyridine Z 2 D 2N-Methyl-2-pyrrolidone Y 3 D n/aMethyl salicylate Y 3 B 3alpha-Methylstyrene Y 2 A 33-(methylthio)propionaldehyde Y 2 B 3


Molybdenum Polysulfide Long Xhain Alkyl Dithocrabamide Complex Y 2Morpholine Y 3 C 3Motor fuel anti-knock compounds (containing lead alkyls) X 1 A 1Myrcene X 2 D n/aNaphthalene (molten) X 2 A 2Naphthalenesulphonic acid-Formaldehyde copolymer, sodium salt solution Z 3 D n/aNeodecanoic acid Y 2 C 3Nitrating acid (mixture of sulphuric and nitric acids) Y 2 C 2Nitric acid (70% and over) Y 2 C 2Nitric acid (less than 70%) Y 2 C 2Nitrilotriacetic acid, trisodium salt solution Y 3 D n/aNitrobenzene Y 2 B 2Nitroethane Y 3 D 3Nitroethane(80%)/ Nitropropane(20%) Y 3 D 3Nitroethane, 1-Nitropropane (each 15% or more) mixture Y 3 D 3o- or p-Nitrotoluenes Y 2 B 2o-Nitrophenol (molten) Y 2 B 21- or 2-Nitropropane Y 3 D 3Nitropropane (60%)/Nitroethane (40%) mixture Y 3 D 3Nonane (all isomers) X 2 C 3Nonanoic acid (all isomers) Y 3 D n/aNonene (all isomers) Y 2 B 3Nonyl alcohol (all isomers) Y 2 B 3Nonyl methacrylate monomer Y 2 D n/aNonylphenol X 1 A 2Nonylphenol poly(4+)ethoxylate Y 2 B 3Noxious liquid, NF, (1) n.o.s. (trade name ...., contains ....) ST1, Cat. X X 1 A 1Noxious liquid, F, (2) n.o.s. (trade name ...., contains ....) ST1, Cat. X X 1 A 1Noxious liquid, NF, (3) n.o.s. (trade name ...., contains ....) ST2, Cat. X X 2 A 2Noxious liquid, F, (4) n.o.s. (trade name ...., contains ....) ST2, Cat. X X 2 A 2Noxious liquid, NF, (5) n.o.s. (trade name ...., contains ....) ST2, Cat. Y Y 2 B 2Noxious liquid, F, (6) n.o.s. (trade name ...., contains ....) ST2, Cat. Y Y 2 B 2Noxious liquid, NF, (7) n.o.s. (trade name ...., contains ....) ST3, Cat. Y Y 3 B 3Noxious liquid, F, (8) n.o.s. (trade name ...., contains ....) ST3, Cat. Y Y 3 B 3Noxious liquid, NF, (9) n.o.s. (trade name ...., contains ....) ST3, Cat. Z Z 3 C 3Noxious liquid, F, (10) n.o.s. (trade name ...., contains ....) ST3, Cat. Z Z 3 C 3Octane (all isomers) X 2 C 3Octanoic acid (all isomers) Z 3Octanol (all isomers) Y 2 C 3Octene (all isomers) Y 2 B 3n-Octyl acetate Y 3 C 3Octyl aldehydes Y 2 B 3Octyl decyl adipate Y 2 B 3Olefin-Alkyl ester copolymer (molecular weight 2000+) Y 2Olefin mixtures (C5-C7) Y 3 C 3Olefin mixtures (C5-C15) X 2 B 3alpha-Olefins (C6-C18) mixtures X 2 B 3Olefins (C13+, all isomers) Y 2Oleic acid Y 2Oleum Y 2 C 2Oleylamine X 2 A 2Olive oil Y 2 (k) D n/aOxygenated aliphatic hydrocarbon mixture Z 3 D n/aPalm acid oil Y 2Palm fatty acid distillate Y 2Palm kernel oil Y 2 (k) D n/aPalm kernel acid oil Y 2 C 3Palm kernel olein Y 2 (k) D n/aPalm kernel stearin Y 2 (k) D n/aPalm mid fraction Y 2(k)


Palm oil Y 2 (k) D n/aNon-edible industrial grade palm oil Y 2Palm oil fatty acid methyl ester Y 2Palm olein Y 2 (k) D n/aPalm stearin Y 2 (k) D n/aParaffin wax Y 2 III n/aParaldehyde Z 3 C 3Paraldehyde-ammonia reaction product Y 2 C 2Pentachloroethane Y 2 B 21,3-Pentadiene Y 3 C 3Pentane (all isomers) Y 3 C 3Pentanoic acid Y 3 D n/an-Pentanoic acid (64%)/2-Methyl butyric acid (36%) mixture Y 2 D 2Pentene (all isomers) Y 3 C 3n-Pentyl propionate Y 3 C 3Perchloroethylene Y 2 B 3Petrolatum Y 2 III n/aPhenol Y 2 C 21-Phenyl-1-xylyl ethane Y 3 C 3Phosphate esters, alkyl (C12-C14) amine Y 2 B 3Phosphoric acid Z 3 D 3Phosphorous, yellow or white X 1 A 1Phthalic anhydride (molten) Y 2 C 3alpha-Pinene X 2 A 3beta-Pinene X 2 B 3Pine oil X 2 C 3Polyacrylic acid solution (40% or less) Z 3 III n/aPolyalkyl (C18-C22) acrylate in xylene Y 2 C 3Poly(2-8)alkylene glycol monoalkyl(C1-C6) ether Z 3 D n/aPoly(2-8)alkylene glycol monoalkyl (C1-C6) ether acetate Y 2 D n/aPolyalkyl (C10-C20) methacrylate Y 2 D n/aPolyalkyl (C10-C18) methacrylate/ethylene-propylene copolymer mixture Y 2 D n/aPolybutene Y 2 III n/aPolybutenyl succinimide Y 2 D n/aPoly(2+)cyclic aromatics X 1 A 2Polyethylene glycol Z 3 III n/aPolyethylene glycol dimethyl ether Z 3 III n/aPolyethylene polyamines Y 2 C 3Polyferric sulphate solution Y 3 C 3Poly(iminoethylene)-graft-N-poly(ethyleneoxy) solution (90% or less) Z 3 III n/aPolyisobutenamine in aliphatic (C10-C14) solvent Y 3 C 3Polyisobutenyl anhydride adduct Z 3 III n/aPoly(4+)isobutylene Y 2 III n/aPolymethylene polyphenyl isocyanate Y 2 D 2Polyolefin (molecular weight 300+) Y 2 III n/aPolyolefin amide alkeneamine (C17+) Y 2 D n/aPolyolefin amide alkeneamine borate (C28-C250) Y 2 D n/aPolyolefinamine (C28-C250) Y 2 C 3Polyolefinamine in alkyl (C2-C4) benzenes Y 2 C 3Polyolefinamine in aromatic solvent Y 2 C 3Polyolefin aminoester salts (molecular weight 2000+) Y 2 D n/aPolyolefin anhydride Y 2 D n/aPolyolefin ester (C28-C250) Y 2 D n/aPolyolefin phenolic amine (C28-C250) Y 2 D n/aPolyolefin phosphorosulphide, barium derivative (C28-C250) Y 2 C 3Poly(20)oxyethylene sorbitan monooleate Y 2 III n/aPoly(5+)propylene Y 3 III n/aPolypropylene glycol Z 3 D n/aPolysiloxane Y 3 III n/aPotassium chloride solution (10% or more) Z 3 III n/a


Potassium hydroxide solution Y 3 C 3Potassium oleate Y 2 C 3Potassium thiosulphate (50% or less) Y 3 C 3n-Propanolamine Y 3 C 3beta-Propiolactone Y 2 D 2Propionaldehyde Y 3 C 3Propionic acid Y 3 D 3Propionic anhydride Y 3 C 3Propionitrile Y 2 C 2n-Propyl acetate Y 3 D n/an-propyl alcohol Y 3 III n/an-Propylamine Z 2 C 2Propylbenzene (all isomers) Y 3 A 3Propylene glycol methyl ether acetate Z 3 D n/aPropylene glycol monoalkyl ether Z 3 D n/aPropylene glycol phenyl ether Z 3 D n/aPropylene oxide Y 2 C 2Propylene tetramer X 2 B 3Propylene trimer Y 2 B 3Pyridine Y 2 D 3Pyrolysis gasoline (containing benzene) Y 2 B 3Rapeseed oil Y 2 (k) D n/aRape seed oil fatty acid methyl esters Y 2 D n/aRice bran oil Y 2 (k) D n/aRosin Y 2 B 3Safflower oil Y 2 (k) D n/aShea butter Y 2 (k) D n/aSodium alkyl (C14-C17) sulphonates (60-65% solution) Y 2 B 3Sodium aluminosilicate slurry Z 3 III n/aSodium benzoate Z 3 D n/aSodium borohydride (15% or less)/Sodium hydroxide solution Y 3 D 3Sodium carbonate solution Z 3 D n/aSodium chlorate solution (50% or less) Z 3 III 3Sodium dichromate solution (70% or less) Y 2 C 2Sodium hydrogen sulphide (6% or less)/Sodiumcarbonate (3% or less) solution Z 3 B 3Sodium hydrogen sulphite solution (45% or less) Z 3 D 3Sodium hydrosulphide/Ammonium sulphide solution Y 2 B 2Sodium hydrosulphide solution (45% or less) Z 3 B 3Sodium hydroxide solution Y 3 D 3Sodium hypochlorite solution (15% or less) Y 2 C 3Sodium nitrite solution Y 2 B 2Sodium petroleum sulphonate Y 2 B 2Sodium poly(4+)acrylate solutions Z 3 III n/aSodium silicate solution Y 3 C 3Sodium sulphide solution (15% or less) Y 3 B 3Sodium sulphite solution (25% or less) Y 3 C 3Sodium thiocyanate solution (56% or less) Y 3 B 3Soyabean oil Y 2 (k) D n/aStyrene monomer Y 3 B 3Sulphohydrocarbon (C3-C88) Y 2 D n/aSulpholane Y 3 D n/aSulphonated polyacrylate solution Z 3 D n/aSulphur (molten) Z 3 III 3Sulphuric acid Y 3 C 3Sulphuric acid, spent Y 3 C 3Sulphurized fat (C14-C20) Z 3 D n/aSulphurized polyolefinamide alkene (C28-C250) amine Z 3 D n/aSunflower seed oil Y 2 (k) D n/aTall oil, crude Y 2 B 3


Tall oil, distilled Y 2 B 3Tall oil fatty acid (resin acids less than 20%) Y 2 C 3Tall oil pitch Y 2Tallow Y 2 (k) D n/aTallow fatty acid Y 2 D n/aTetrachloroethane Y 2 B 3Tetraethylene glycol Z 3 III n/aTetraethylene pentamine Y 2 D 3Tetrahydrofuran Z 3 D 3Tetrahydronaphthalene Y 2 C 3Tetramethylbenzene (all isomers) X 2 A 3Titanium dioxide slurry Z 3 III n/aToluene Y 3 C 3Toluenediamine Y 2 C 2Toluene diisocyanate Y 2 C 2o-Toluidine Y 2 C 2Tributyl phosphate Y 3 B 31,2,3-Trichlorobenzene (molten) X 1 A 11,2,4-Trichlorobenzene X 1 B 21, 1, 1 -Trichloroethane Y 3 C 31,1,2-Trichloroethane Y 3 C 3Trichloroethylene Y 2 C 31,2,3-Trichloropropane Y 2 C 21,1,2-Trichloro-1,2,2-Trifluoroethane Y 2 C 3Tricresyl phosphate (containing less than 1% ortho-isomer) Y 2 A 2Tridecane Y 2 III n/aTridecanoic acid Y 2 B 3Tridecyl acetate Z 3 III n/aTriethanolamine Z 3 D 3Triethylamine Y 2 C 2Triethylbenzene X 2 A 2Triethylenetetramine Y 2 D 3Triethyl phosphate Z 3 B 2Triethylphosphite Z 3 B 3Triisopropanolamine Z 3 III n/aTriisopropylated phenyl phosphates X 2 A 2Trimethylacetic acid Y 2 D 3Trimethylamine solution (30% or less) Z 2 C 2Trimethylbenzene (all isomers) X 2 A 3Trimethylol propane propoxylated Z 32,2,4-Trimethyl-1,3-pentanediol diisobutyrate Z 3 III n/a2,2,4-Trimethyl-1,3-pentanediol-1 -isobutyrate Y 2 C 31,3,5-Trioxane Y 3 D 3Tripropylene glycol Z 3 III n/aTrixylyl phosphate X 2 A 1Tung oil Y 2 (k) D n/aTurpentine X 2 B 3Undecanoic acid Y 2 B 31-Undecene X 2 B 3Undecyl alcohol X 2 B 3Urea/Ammonium nitrate solution Z 3 D n/aUrea/Ammonium nitrate solution (containing less than 1% free ammonia) Z 3 C 3Urea/Ammonium phosphate solution Y 2 III n/aUrea solution Z 3 III n/aValeraldehyde (all isomers) Y 3 C 3Vegetable acid oils (m) Y 2 D n/aVegetable fatty acids distillates(m) Y 2 III n/aVinyl acetate Y 3 C 3Vinyl ethyl ether Z 2 C 2Vinylidene chloride Y 2 D 2


Vinyl neodecanoate Y 2 B 3Vinyltoluene Y 2 A 3Waxes Y 2 D n/aWhite spirit, low (15-20%) aromatic Y 2 B 2Xylenes Y 2 C 3Xylenes/ethylbenzene (10% or more) mixture Y 2 B 3Xylenol Y 2 B 3Zinc alkaryl dithiophosphate (C7-C16) Y 2 C 3Zinc alkenyl carboxamide Y 2 D n/aZinc alkyl dithiophosphate (C3-C14) Y 2 B 3

Chapter 18 – as amended by MEPC 52 and the MSC 79 – reflects products listed in MEPC 55 wp.8 as amendedCHAPTER 18 Pollution Category Ship Type Acetone Z NAAlcoholic beverages, n.o.s. Z NAApple juice OS NAn-Butyl alcohol Z NAsec-Butyl alcohol Z NACalcium nitrate solutions (50% or less) Z NAClay slurry OS NACoal slurry OS NADiethylene glycol Z NAEthyl alcohol Z NAEthylene carbonate Z NAGlucose solution OS NAGlycerine Z NAGlycerol monooleate Z NAHexamethylenetetramine solutions Z NAHexylene glycol Z NAHydrogenated Starch Hydrolysate OS NAIsopropyl alcohol Z NAKaolin slurry OS NALecithin OS NAMagnesium hydroxide slurry Z NAMaltitol Solution OS NAN-Methylglucamine solution (70% or less) Z NAMethyl propyl ketone Z NAMolasses OS NANoxious liquid, (11) n.o.s. (trade name ...., contains ....) Cat. Z Z NANon-noxious liquid, (12) n.o.s. (trade name ...., contains ....) Cat. OS OS NAPolyaluminium chloride solution Z NAPolyglycerin, sodium salt solution (containing less than 3% sodium hydroxide) Z NAPotassium formate solutions Z NAPropylene carbonate Z NAPropylene glycol Z NASodium acetate solutions Z NASodium sulphate solutions Z NASorbitol solution OS NASulphonated polyacrylate solution Z NATetraethyl silicate monomer/oligomer (20% in ethanol) Z NATriethylene glycol Z NAVegetable protein solution (hydrolysed) OS NAWater OS NA


11. USCG NVIC

Although the U.S. will become party to these new revisions, the U.S. regulations will not be completed in time for their entry

into force date of 1 January 2007. Therefore, the U.S. Coast Guard (USCG) regulations that will be in effect on that date

will be the current regulations for the transport of Annex II substances. The USCG does not intend to object under the

provisions of Article 16 of the MARPOL Annex II Revisions.

The USCG is developing a Navigation and Vessel Inspection Circular (NVIC) (guidance document to industry) that will provide

the industry with a method of complying with the regulations in effect. This elective method will reflect the revised Annex

II. The NVIC will reflect the process that the shipowner should follow if it should choose to use the elective method.

In November 2005, the USCG Chemical Transportation Advisory Committee (CTAC) approved the formation of the MARPOL

Annex II Work Group whose primary objective is to develop a framework for the Navigation and Vessel Inspection

Circular (NVIC) that will be used to implement MARPOL Annex II.

When the Chemical Transportation Advisory Committee (CTAC) held its 2006 Autumn meeting, the INTERTANKO

representative chairing the MARPOL Annex II Work Group appraised the Committee of the various meetings held since

its inception in 2005 up to its final meeting on 22 August 2006 and presented the final report of the group. The work in

the preceding nine months had culminated in a "draft guidance" that contains recommendations from CTAC regarding the

development of the Navigation and Vessel Inspection Circular (NVIC) that will be used to implement MARPOL Annex II.

The purpose of the most recent meeting (held August 2006) was to review the efforts by the Work Group which culminated

in a draft guidance document to be used by the USCG to develop an NVIC.

The document developed by the MARPOL Annex II Work Group is in a format similar to that of an NVIC but is not intended

to represent a "draft" of the document that will be ultimately published and utilised by the USCG and industry. It should

be noted, however, that this document, regardless of the positions taken on particular issues, represents work that is integral

to the development of the "skeleton" which will be used by the USCG to implement MARPOL Annex II in the United States

until the rulemaking process begins. It was also decided that this Work Group should remain intact for 2007 in order to

address any MARPOL Annex II implementation issues that may arise.

The USCG expects to publish the NVIC in the autumn of 2006. At the time of this document going to press the USCG NVIC

is in internal clearance within the USCG and has yet to be released. It will be posted on the NVIC website as soon as it is

approved for release (http://www.uscg.mil/hq/g-m/nvic/index00.htm) and will be placed on the INTERTANKO website

immediately after.

12. MEPC 55 Working Paper 8

As part of the agenda for MEPC 55, the Committee reviewed and accepted, MEPC 55 WP 8, a working paper developed

November 2006


by the drafting group tasked to review the amendments to the IBC Code. MEPC WP 8 contains a listing the products that

have been classified or re-classified since the adoption of the amended IBC Code at the 52nd Session of the IMO's Marine

Environment Protection Committee (MEPC 52) and the 79th Session of the Maritime Safety Committee (MSC 79) in 2004

and the products to be included (to date) in the December 2006 issue of the MEPC.2 Circular. Although the amendments

made since the 2004 adoption will not be officially entered into the Code until 2009, all the products amended or added

since then will be included in MEPC.2 Circular 12 due out 31 December 2006.

An electronic version of this document is available on the INTERTANKO web site and has being circulated to members.

13. Tripartite Agreement for the provisional assessment of Liquid Substances

All non-oil cargoes carried in bulk are classified by the International Maritime Organization (IMO) and/or the vessel's flag

state. The carriage requirements for a product are then determined by these entities using the guidelines set out by GESAMP

and the IMO. If regulated by the IBC Code, those cargoes must be authorised for carriage on that particular ship and listed

on the ship's Certificate of Fitness. The bulk carriage of any liquid product other than those defined as oil (subject to MARPOL

Annex I) is prohibited unless the product has been evaluated and categorised for inclusion in Chapter 17 or 18 of the IBC

Code (The International Code for the Construction and Equipment of Ships Carrying Dangerous Chemicals in Bulk).

Because new products are continually being created and proposed for carriage onboard chemical tankers a mechanism has

been created to provisionally classify these cargoes under the IMO guidelines. This mechanism is called the tripartite agreement.

If the carriage requirements for a cargo cannot be found in the IBC Code, a tripartite agreement is initiated between � 1. The port state of the shipper. � 2. The flag state of the carrier � 3. The port state receiving the cargo.

If a tripartite agreement is completed it is then included in the "Provisional Categorization of Liquid Substances" (also known

as the MEPC.2 Circular). An updated circular is published every December. The initiator of the tripartite agreement has

three years in which to provide all of the required data to formally classify a substance. It is not acceptable to repeatedly

initiate new tripartite agreements for the same product.

When there is a need to transport a bulk liquid cargo that has not been classified, the shippers have to go to their

administration and request that a tripartite agreement be established between the shipping country, the receiving country,

and the ship's flag state. That administration would need to receive the BLG Product Data Form. This is in accordance with

Regulation 3(4) of MARPOL Annex II.

The tripartite agreement will stand for three years, before which time all outstanding or otherwise necessary data will have

to have been forwarded to the IMO (GESAMP) for the formal classification. Otherwise the tripartite agreement will expire.

If the cargo is assessed as being regulated by the IBC Code or MARPOL Annex II, the ship's Certificate of Fitness and Procedures

November 2006


& Arrangements Manual will have to be amended (usually by the classification society, arranged by the owner or manager).

The shipping country will determine the provisional carriage requirements per Annex I of MEPC/Circ.265, and seek the

concurrence of the flag state and receiving countries using the standard fax format per Annex 7 of MEPC/Circ.265. The

IMO and other involved administrations should also be copied. In the absence of a response from the flag state or receiving

countries after 14 days, the agreement may be deemed to have been accepted, and the IMO is informed. If there is a question

as to whether the cargo has been classified, the International Bulk Chemical Code (IBC Code) should be consulted. If not

found there, check the annual "Provisional Categorization of Liquid Substances", the most recent of which is MEPC.2/Circ11.

It is expected MEPC.2 Circ 12 will be produced by the IMO on 31 December 2006 (to ensure all products are considered).

All of the products considered for inclusion in MEPC.2 Circ 12 are included in the spreadsheet containing Chapters 17 and

18 of the Amended IBC Code (as approved by MEPC 52 and MSC 79). The official MEPC.2 Circ 12 will not be available

until mid-January 2007 and will not reflect any tripartite submissions received by the IMO between September (ESPH 12)

and December 2006.

However, important parts of the MEPC.2 Circ 11 are: The issuance of an Addendum to CoF may be done immediately based

on the Tripartite Agreement. The submission of data and evaluation by GESAMP and ESPH may come afterwards.

� Annex 1/List 1: List of pure or technically pure substances

These cargo classifications either have an expiration date (initially after three years), after which data must have been submittedto the IMO for inclusion in the IBC Code; or where there is no expiration date, they are candidates for the next formalamendment of the Code and will be included in the Code at the next publication.

� Annex 2/List 2: List of (pollutant only) mixtures

This is a permanent list, updated annually. These products will not be listed in the Code.

� Annex 3/List 3: List of trade name substances with safety hazards

As for the potential Code entries in List 1, these classifications can have an expiry date - but they will not be listed in the

Code.

� Annex 8: Tripartite Contact Addresses

Table 1 in the circular defines what each list is and its current status relative to the decision made by the ESPH Work Group.

Amendments to the Tripartite Lists (Annexes 1 to 4) are identified by shading the field in which the change has been made.

However, members are advised to note that on 15 October 2004, MEPC 52 adopted the revised MARPOL Annex II [by

resolution MEPC.118(52) and the amended IBC Code (by resolution MEPC.119(52)], both of which enter into force on 1

January 2007. Consequently, where appropriate, the expiry dates for the products have been adjusted to 31 December 2006.

November 2006


14. INTERTANKO MARPOL Annex II waste reception survey results

INTERTANKO members will be aware that INTERTANKO has kept them informed of the work being undertaken on reception

facilities, both within the Port Reception Facility Forum and within the IMO. We recently advised on the discussion and

our input during the 14th session of the IMO Flag State Implementation Sub-committee (FSI 14) regarding reception facilities

pertaining to Annex II.

Following on from this, the IMO is in the process of further developing its Global Integrated Shipping Information System

(GISIS) database, which can be accessed at the following link: http://gisis.imo.org/Public/. The area of interest to chemical

owners is not only the Annex II reception facility information that is available within the GISIS web site, but also the manner

in which the information is presented and the detail of the information - not only at the current time but especially when

the revision to Annex II comes into force on 1.1.2007 and particularly the additional requirements regarding pre-wash for

certain vegetable oils.

INTERTANKO therefore had the opportunity in our discussions with the IMO Secretariat, to supply our input and

feedback on not only what information is or would be beneficial to you (the users), but also the format of the way in which

the information could be presented.

We undertook a survey of chemical tanker members on this issue. The replies we received to our survey have now being

collated into a report and submitted to the IMO Secretariat to help and assist them with regard to the IMO GISIS database

work that is being undertaken. We are pleased to also make this report available as follows:

MARPOL Annex II waste reception survey report

INTERTANKO represents over 71% of the world's independent tanker fleet and over 81% of the world's chemical tankers.

We therefore issued the survey to all our chemical members and those having a need to utilise MARPOL Annex II reception

facilities. As with all surveys we did not receive replies from all our members; however we have received replies from 26

companies representing 467 chemical tankers.

The results of the questions asked in the survey are presented as percentages of the total of the 26 companies that replied.

For ease of reference we have indicated the particular question asked in the survey above the results received.

Within the survey we asked for "free comments" with regard to question 4 and we have grouped these separately in our report.

However, we also received various unsolicited "free comments" to some of the other questions we asked in the survey, and

we have also included these as we felt they also provide guidance.

We have submitted our survey report to the IMO and hope that these results will prove beneficial and will help assist and

guide the IMO accordingly.

November 2006

We received replies from 26 companies representing 467 chemical tankers.

The following are the questions asked in the survey, and the corresponding collective replies, presented as a percentage of

the 26 companies who replied.

Question 1

is the way the information is currently presented on Annex II reception facilities in the GISIS database adequate for your needs?

(i.e. is it sufficient to simply state that say a Pollution Cat B, Annex II reception facility is available?)

Yes - 50%

No - 50%

Question 2

would it be much more useful for GISIS to contain information not only if on whether there is a Pollution Cat B Annex II

reception facility available in that port, but, in addition what specific Annex II cargo reception facilities are available?

77% - Yes it would be more useful, because normally we cannot obtain this information in a reliable way.

23% - No it would not be more useful as we can obtain this information from reliable sources (e.g. agents, charterers, etc)

Question 3

Would it be a true statement to say that by the nature of the current chemical trade then if the vessel is fixed to carry say a

Cat A, or Cat B cargo requiring a pre-wash then there would be, without doubt, appropriate reception facilities available at

the same port of discharge for that cargo?

(Note: it has being suggested that it would not be necessary to maintain information on GISIS on which specific cargoes could

be received by a reception facility because by virtue of that cargo being discharged in that port then there would invariably

be a reception facility for that product available).

65% - Yes, in the main it is a true statement

35% - No, it is often a false statement

Question 4

Do members encounter problems with a lack of Annex II reception facilities today?

Yes - 54%

No - 46%

….if so, why are these not reported to the flag state and then to IMO? (The free comment replies can be found on page 3 of

this letter).

Question 5

Although not directly related to the GISIS iQuestion 2

would it be much more useful for GISIS to contain information not only if on whether there is a Pollution Cat B Annex II

reception facility available in that port, but, in addition what specific Annex II cargo reception facilities are available?

77% - Yes it would be more useful, because normally we cannot obtain this information in a reliable way.

23% - No it would not be more useful as we can obtain this information from reliable sources (e.g. agents, charterers, etc)



Question 3

Would it be a true statement to say that by the nature of the current chemical trade then if the vessel is fixed to carry say a

Cat A, or Cat B cargo requiring a pre-wash then there would be, without doubt, appropriate reception facilities available at

the same port of discharge for that cargo?

(Note: it has being suggested that it would not be necessary to maintain information on GISIS on which specific cargoes could

be received by a reception facility because by virtue of that cargo being discharged in that port then there would invariably

be a reception facility for that product available).

65% - Yes, in the main it is a true statement

35% - No, it is often a false statement

Question 4

Do members encounter problems with a lack of Annex II reception facilities today?

Yes - 54%

No - 46%

...if so, why are these not reported to the flag state and then to IMO? (The free comment replies can be found on page 3 of

this letter).

Question 5

Although not directly related to the GISIS issue we would none the less appreciate your comments regarding reception facilities

for Vegetable Oils, particularly with regards to the changes that will come into force for pre-wash on some Veg oils post 1/1/2007.

On this issue we have two questions:

5A. Do you believe that from your experience of today’s availability of reception facilities for Veg Oils that there will be adequate

reception facilities available for Veg oils as required under the revisions to MARPOL Annex II.?

Yes - 8%

No - 92%

5B. would it be beneficial to have within GISIS details of the availability of vegetable oil reception facilities rather than a

generic listing of Category Y?

Yes - 96%

No - 4%

Specific free comments to question 4

The following is the list of “free comments” we received to question 4 of the survey which asked “Do members encounter

problems with a lack of Annex II reception facilities today? if so, why are these not reported to the flag state and then to IMO?”

� “Once we have “chemical” slops onboard they are often refused to be taken ashore and have to be kept on board

until adequate facilities can be found. Reporting to IMO may appear useless”.

� “We do not report the lack of reception facilities as we doubt anything would be done – this also applies to Annex

I facilities”.

� “Reporting contact details are not readily available”

� We have encountered problems with inadequate availability of reception facilities but this is usually worked around

by barging or trucking to distant destinations but this involves exorbitant costs. Knowing the problem exists we

look ahead to arrange better reception facilities at the vessel’s future ports.

� Such problems of inadequate reception facilities have been discussed with flag state but the flag state could not assist.

General unsolicited comments received

As we mentioned in the forward to our letter, we did receive other unsolicited general comments to the survey which we

believe are of interest and are thus reproduced under the appropriate question as follows:

Question1

is the way the information is currently presented on Annex II reception facilities in the GISIS database adequate for your needs?

i.e. is it sufficient to simply state that say a Pollution Cat B, Annex II reception facility is available?

Comments:� “Most reception barges (other than cargo charterers, receiver’s facility) are not concerned by categories”.

� “There is no information on any facilities in Houston; we are a public marine terminal that routinely receives discharges

from vessels with no issues. We can arrange receipt of just about any cargo”.

Question 2

would it be much more useful for GISIS to contain information on not only whether there is a Pollution Cat B Annex II reception

facility available in that port, but, in addition what specific Annex II cargo reception facilities are available?

Comments:� “Detailed reception conditions must also be described: barge, pipe, which berth, when, availability receiving rate &

quantity, cost, etc”.

� “We have checked some ports but found no information available but slops are being disposed of to reception facilities.

We have confirmed such information from local agents”.

� “Our sources today (agents, charterers) are reliable, however for a database like this to be of any benefit at all to us,

it needs to be complete. In a case where the database only states minimum information we would still have to contact

the agent for an detailed answer weather the cargo is acceptable or not (Question2”)



Question 5

Although not directly related to the GISIS issue we would none the less appreciate your comments regarding reception facilities

for Vegetable Oils, particularly with regards to the changes that will come into force for pre-wash on some Veg oils post 1/1/2007.

On this issue we have two questions

5A. Do you believe that from your experience of today’s availability of reception facilities for Veg Oils that there will be adequate

reception facilities available for Veg oils as required under the revisions to MARPOL Annex II.?

5B. Would it be beneficial to have within GISIS details of the availability of vegetable oil reception facilities rather than a

generic listing of Category Y?

Comments:� “The current categorisation today (Cat A & B etc) is commonly known for its disposal but depends on the port,

some toxic products cannot always be received due to its toxic smell to the surrounding area. Reception facilities for

vegetable oil, animal fat & waxes are very limited. Many soft oils such as dry type vegetable oil and animal fat will

also be required depending on its viscosity at the discharge temperature but at this moment, no proper reference to

viscosity at every temperature and the reception facility is available. (Q5) “

� “We understand that reception facilities for vegetable and animal oils in Japanese ports are not available but some

Korean ports may be available by barge”.

� “Information for shore facilities should be categorised e.g.

1. Annex 1, oil slop, machinery and cargo slops

2. Chemical products (toxic & flammable but not necessary to divide into two categories)

3. Vegetable, animal fat, fish oil

4. Waxes (facilities install heating system would be required)”

� “On the condition that the reception facilities also accept trade names”

� “This may also be beneficial to vessels needing to discharge materials”.

� “It’s important that the “Viscosity” according to temperature is clearly made available in the GISIS system”.

15. Possible scenarios for existing ships under the Amended IBC Code requirements

The following are some of the scenarios that are possible in order to comply with the Revised MARPOL Annex II and the

Amended IBC Code:

� Existing product tankers carrying IBC Code Chapter 18 cargoes

These ships will be able to carry the cargoes left in the revised Chapter 18.

� Existing IMO Ship Type 3 chemical tanker carrying Cat D cargoes only

Caustic soda is a big mover for this type of ship, and although it remains a ship Type 3, it falls into Pollution Category Y requiring

increased stripping limits and underwater discharge requirements.

� Conversion of a product tanker to a Ship Type 3 chemical tanker

For the purpose of converting an oil product tanker to an IMO Ship Type 3 chemical tanker complying with the IBC Code,

the following major differences in regulatory regimes need to be considered: damage stability criteria, cargo tank & venting

requirements, environmental control, fire-extinguishing systems, personnel protection, gauging and high level alarms, welded

pipe, underwater discharge outlet, stripping limits and officer/crew training.

� Conversion of a product tanker with a double hull complying with Regulation 19 of MARPOL Annex I or a double

hull IMO Ship Type 3, to an IMO Ship Type 2(k) (veg oils)

MARPOL Annex II regulation 4.1.3 offers an exemption for a double hull products tanker (complying with Regulation 19

of MARPOL Annex 1 or an IMO Ship Type 3 that complies with all the requirements of an IMO Ship Type 2 (except cargo

tank location) to carry vegetable oils.

However, we stress that in view of the revisions to MARPOL Annex II, it is dependent upon the vessel's flag state granting

the allowance for compliance with the exemption outlined in MARPOL Annex II Regulation 4.1.3. It is important to

understand that paragraph 4.1.3 of the revised MARPPOL Annex II states: "An administration may exempt ships from the

carriage requirements under Regulation 11 for ships certified to carry individually identified vegetable oils identified by the

relevant footnote in Chapter 17 of the IBC Code, provided the ship complies with…..":

� Conversion of a Ship Type 3 chemical tanker with double hull complying with MARPOL Annex I Regulation 19, to

a full IMO Ship Type 2

The double bottom height must meet the B/15 at the centreline, as required by IBC Code paragraph 2.6.1.2. The ship will

also need to be verified as complying with the requirements of Type 2 damage stability and various safety requirements, enabling

the vessel to carry IMO Ship type 2 chemicals.

After 1 January 2007, the stripping performance requirements will apply to all tankers holding a Certificate of Fitness (CoF).



16. P&A Manual application and Certificates of Fitness

If you are an INTERTANKO member you will be aware from the advice in our Weekly NEWS and chemical bulletins that

part of the MARPOL Annex II revision process will entail a revision of the ship's Certificate of Fitness (CoF) and its

Procedures and Arrangements Manual (P&A Manual). Every chemical tanker is required to have a Certificate of Fitness (CoF)

indicating that it is certified to carry certain products. The new P&A Manuals and the new Certificates need to be onboard

each ship as of 1 January 2007 deadline. These documents must be approved/issued and forwarded to the ships before this

date.

We informed members that we had contacted the International Association of Classification Societies (IACS) requesting advice

of any common procedures for the application for the revised P&A manuals. We circulated its advice that, whilst there will

not be a common procedure for the application of the P&A Manual (as the individual classification societies will advise their

own arrangements), nevertheless the process for the application of the revised P&A manuals would commence from the 1st

August 2006.

Members are advised accordingly and urged to commence the process of application for their revised P&A manuals

to their respective classification societies without delay.

INTERTANKO has circulated various information on this issue. In particular details are also available including various P&A

manual templates that are available from some classification societies as follows:

Det Norske Veritas

Det Norske Veritas (DNV) has advised that the template it supplies is in PDF format for guidance. However, users are requested

to contact DNV through the DNV Section mailbox [email protected] to obtain the template in Word format for

direct use.

American Bureau of Shipping

The American Bureau of Shipping has prepared comprehensive guidance for owners to assist them in meeting the new regulations

including an easy-to-follow template for the required Procedures and Arrangements Manual. ABS engineering offices around

the world are also available to assist owners in understanding and applying the new standards and, where authorised by the

relevant flag Administration, are able to review and approve the new P&A Manuals. For further information please refer to

the links on the home page of the ABS website:www.eagle.org

Lloyd's Register of Shipping

Lloyd's Register has produced instructions for updating P&A Manuals, together with Guidelines and a checklist to assist those

preparing the P & A Manuals according to the new format. Their template is available on the INTERTANKO web site at

http://www.intertanko.com/upload/weeklynews/P&AManualtemplate.pdf

If members require a Microsoft Word version of this template, they are requested to email [email protected], who is

the Head of the MARPOL Group in Lloyd's Register, London.

Germanischer Lloyd

Templates and Instructions for the Amendment of Procedures and Arrangements Manuals according to the revised Annex

II of MARPOL, have also been produced by Germanischer Lloyd. Please refer to the instruction document for full details

but the following summarises the documents available on the INTERTANKO web site www.intertanko.com

a. Chemical Tankers (IBC) with keel laying between 1st July 1994 and 31st December 2006

b. Chemical Tankers (IBC) with keel laying between 1st July 1986 and 30th June 1994

c. Chemical Tankers (BCH) (keel laid before 1st July 1986)

d. Gas Carriers

e. Other Ships which are not chemical tankers, with a keel laying date before 1st Jan 2007

17. Biofuels – an update

Requests for information on biofuels are increasing. Therefore in an effort to update members on the background to the

classification and pending carriage requirements of these products, INTERTANKO has developed a background brief on

this issue.

Any fuel made from a renewable biological source is considered a biofuel.� Biofuel is derived from "biomass" - recently living organisms or their metabolic by-products, such as waste streams

(agricultural, domestic or municipal).

� It is a renewable energy, unlike other natural resources such as petroleum, coal and nuclear fuels.

� From a global warming perspective, the carbon in biofuels was recently extracted from atmospheric carbon dioxide

by growing plants, so burning it does not result in a net increase of carbon dioxide in the earth's atmosphere.

� The term "biofuel" encompasses a diverse range of products such as biogas, biodiesel (methylester of vegetable oils)

and bio-ethanol, and also includes ethanol, and methanol. Liquid biofuels are mainly developed as a vehicle fuel.

Biodiesel is produced from a variety of vegetable oils, including but not limited to palm, rape, canola, soy, linseed, coconut,

mustard and cotton oils. It can also be manufactured from tallow oil and yellow grease (used cooking oils). The production

process is to modify the oils through esterification to give glycerine as a useable by-product.

Because of the already-existing infrastructure for processing soft oils such as palm oil, countries in Asia and Latin America



are looking to invest in biodiesel production, resulting in significant increases in the exports of crude palm oil and fatty acid

methyl esters (FAME). According to expert forecasts, there will be some 100 new biodiesel and bio-ethanol plants in Europe

by the year 2010.

Bio-ethanol is a readily available, clean fuel that can be utilised in combustion engines in different ways:� Anhydrous (or dehydrated) ethanol is free of water and at least 99% pure. This ethanol can be blended with conventional

fuel in proportions up to 85% (E85). Blends up to 20% can be used in modern engines without modification.

Traditionally, methyl-tertiary-butyl-ether (MTBE) or ethanol has been added as an oxygenate to gasoline at 6-10%

blend for a cleaner burn. As the use of MTBE has been banned by a growing number of states, the U.S. ethanol market

has grown from 2.3 to 4 billion gallons in the last three years.

� Higher blends require modified engines that run as flexible fuel vehicles (FFVs). There are currently over a million

FFVs on the road in the U.S. with an increasing number added each year, and there are a small but growing number

of E85 gas stations, primarily in the Midwest.

� Finally, bio-ethanol is also used to manufacture ETBE (ethyl-tertiary-butyl-ether), a fuel additive for conventional

petrol.

Because ethanol is a great solvent and pulls in water, it is typically not mixed with gasoline prior to being shipped via pipeline.

In the U.S., most blends are shipped separately – the gasoline is transported via pipeline and the ethanol is sent by

truck/rail/barge for blending at the distribution point.

The U.S. Congress has recently passed a Renewable Fuel Standard (RFS) that requires that a minimum percentage of liquid

fuels be from renewable sources. At current gasoline prices there is an economic incentive to blend more than the required

levels of ethanol. In markets where states have not yet banned MTBE, distributors are switching to ethanol blends for economic

reasons.

The carriage of biofuels is an important subject in itself.

These generic terms "biofuel" and "biodiesel" involve a number of different products. Because of this, these products cannot

be shipped under MARPOL Annex II using these trade names. Most of the discussion recently regarding the classification

of biofuels has been predominantly about biodiesel. The majority of biodiesel cargoes are fatty acid methyl esters (FAME),

which can have various compositions. There are only three fatty acid methyl esters approved for carriage under the current

MARPOL Annex II:

1. Palm oil fatty acid methyl ester (currently in the IBC Code)

2. Coconut oil fatty acid methyl ester (currently in the IBC Code)

3. Rapeseed oil fatty acid methyl ester (currently in list 1 of MEPC.2 Circ)

All three of these products are Category D and Chapter 18.


Tripartites are required for any FAME other than those listed above. (See section 6 of this pamphlet for information on

tripartites). Soyabean oil FAME is currently being tripartited between the United States, the U.K. and Singapore. Any new

entity looking to transport this cargo must also be listed as a party to the tripartite agreement.

Regardless of the base oil, FAME products are not "unmodified" oils, and will not be considered applicable under the exemption

clause in MARPOL Regulation 4.1.3. (carried in Type 3 space with Type 2 hull requirements). Right now some charterers

are lobbying to consider biofuels and biodiesel as Annex I cargoes and not Annex II. There are obviously other stakeholders

who wish to assess each individual product separately under Annex II, including applicable biofuels in Chapters 17 and 18

of the IBC Code.

Most bio-ethanol cargoes (and some biodiesels) made up from any blend containing 85% or more of a mineral diesel oil

or gasoline qualify as Annex I product. The issue of the carriage of biofuels will become more prevalent as more of this product

is shipped.

ESPH 12 approved a generic entry for fatty acid methyl esters (FAME) products. A footnote (m) on this entry will indicate

that the FAME products carried are derived from vegetable oils already in the IBC Code. The individual FAME products

that have already been evaluated under the new system are palm oil FAME, rapeseed oil FAME and coconut oil FAME. From

1 January next year FAME derived from any other vegetable oil already evaluated and classified may be carried under the

generic entry. This will also mean that blends of FAME products need not be subject to a mixture calculation.

November 2006

Outside back cover image courtesy Odfjell ASA.

the revisions to marpol annex ii

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