Anti-Trust/Competition Law
Compliance Statement
INTERTANKO’s policy is to be firmly committed to maintaining a fair and
competitive environment in the world tanker trade, and to adhering to all
applicable laws which regulate INTERTANKO’s and its members’ activities in
these markets. These laws include the anti-trust/competition laws which the
United States, the European Union and many nations of the world have
adopted to preserve the free enterprise system, promote competition and
protect the public from monopolistic and other restrictive trade practices.
INTERTANKO’s activities will be conducted in compliance with its Antitrust/Competition Law Guidelines.
UPDATE ON TECHNICAL
COMMITTEE ISSUES
INTERTANKO
North American Panel
April 2010
ISSUES
1. Mercury in cargoes
2. Verification of damage stability on
tankers
3. MSDS (developing a guide)
4. Condition of class
5. Inert gas on small tankers
7. Lifeboat safety
8. Recovery systems
9. Bunker Sub-Committee issues
MERCURY IN CARGOES
• Some crude oils contain mercury (Hg)
• Amounts at parts per billion (ppb) levels but still
significant
• OCIMF has developed an awareness guide
• The scope of it is to raise awareness and provide
information and guidance on:
– mercury as a natural element, its toxicity and hazards
– what would be a hazard threshold value of mercury
content in liquid
– methods to detect and measure mercury content
– how to handle the cargo and measures of personal
protection
– safety guidance for COT cleaning & handling the wash
water/sludge
– procedures for COT decontamination
MERCURY IN CARGOES
• Apparently oil companies have own
information on crude oils with Hg
• Tankers, not aware of the Hg content on
previous cargoes, may lose contracts
• Cost of decontamination on $1 mill level
• Singapore MPA accepts hot work on their
port only for Hg decontamination of COT
• OCIMF Guide might not contain a list of
crude oils experiences with high Hg
MERCURY IN CARGOES
INTERTANKO Requests
• Include Hg content for each cargo in the MSDS
• Information to be provided well in advance of
loading
• Release an indicative list of crude oils
indentified as having (possible) high Hg
content, or
• Release an indicative list of fields/wells with
crude oils having Hg content
• List updated as soon as information on a new
crude oil or a new well with high content of
mercury is detected
• Measures for Hg decontamination of COT
indicated by charterers
DAMAGE STABILITY IN TANKERS
• Onboard stability booklet not a sufficient
tool for checking compliance
• IMO agreed to develop guidelines for
both:
– verification of compliance with the
requirements for damage stability at the
design stage of the vessel
– verification at the various operational stages
• The completion estimated in two years
• UK MCA, INTERTANKO, OCIMF and ICS
to work on the operational guidelines
DAMAGE STABILITY IN TANKERS
• Paris MoU Concentrated Inspection Campaign
(CIC) in September 2010
• Verification questionnaire ready in May 2010
• Means to prove compliance:
–
–
–
–
being loaded in a condition as per stability booklet
long-handed calculations
class-approved software onboard
another method
• INTERTANKO to comment on the Paris MoU
questionnaire
MSDS
(Material Safety Data Sheets)
• MSDS for:
– oil/fuel oil as cargo and
– bunkers
• SOLAS VI/5-1 – into force on Jan 1, 2011
• MSC 288(86) – IMO Guidelines for MSDS format and
content
• INTERTANKO to suggest guidance for tankers in case
MSDS is:
– not provided
– provided but data not sufficient/in accordance with the
IMO guidelines or generic and not specific to the cargo
• Adding a new criterion in the TVD for reports on MSDS
• C/P clause to cover issues linked to the supply of
MSDS and the accuracy of the information provided
CONDITION OF CLASS (CoC)
• Some oil companies do not accept tankers with
CoCs on the hull condition
• No matter where, no matter the extent
• Maybe an overkill type of reputation risk
management protection policy
• Penalty on transparency & integrity in
reporting
• Removes good practice of pre-drydock survey
• Pre-drydock surveys CoC to be corrected at
dry-docking but . . .
• Tankers risk losing business before that!
• Regrettable hindrance of a good industry
practice!
VIQ 2.15 - Is the vessel free of CoC or significant
recommendations, memoranda or notations?
• Record any CoC or significant recommendations,
memoranda or notations of any nature, including
due dates as an Observation.
• Where class records address structural issues of
concern, including bottom pitting, areas of
substantial corrosion, cracks, buckling or serious
indents, record the details as to the extent and the
measures taken to arrest further development.
• Where a CoC has been postponed, the details
including the CoC, original date and the new date
for completion should be recorded as an
Observation.
CONDITION OF CLASS (CoC)
Actions
• Class alternative wording for the Notes to the VIQ 2.15
• IACS invited to the OCIMF General Purpose Committee to
explain or demonstrate that VIQ 2.15 can cause more
safety problems
• OCIMF statistics from SIRE 2009 reports:
–
–
–
–
Out of 18,586 inspections (not vessels!) in SIRE database:
2,470 (13%+) contain negative comments linked to CoC
15,997 (86%+) contain no CoC related issues
119 - not applicable or not decided
OCIMF to re-run as these statistics are not representative
• INTERTANKO to substantiate the new text of VIQ 2.15 has
triggered an increase on CoC related observations
• Class review the standardisation of the language and terms
used on CoC
• Call for a workshop
AMENDED VIQ – MORE
OBSERVATIONS
New VIQ wording triggers more observations
The rate of Observations issued under the new
VIQ 2.15 increased significantly.
INERT GAS ON SMALL TANKERS
• Draft amendments to SOLAS regulation II-2/4.5.5
• IG plant for 5000 DWT <all new tankers < 20,000 DWT
carrying liquid cargoes having flashpoint < 60°C
• For Chemical Tankers, application of inert gas may
take place after the tank has been loaded but
– before [the ship leaves the berth of loading or in the event of
loading at anchorage] [arrival at the discharge port] [prior to
commencing of discharge], before the ship leaves the
anchorage position (alt.1)
– before commencement of discharge and must continue to be
applied until that cargo tank is next gas free (kept inerted
during discharge, during tank cleaning)(alt.2)
• For chemical tankers, nitrogren as inerting medium
• INTERTANKO policy:
– all tankers to have an IG plant
– study to consider feasibility of IG plant on smaller tankers
LIFBOAT SAFETY
• IMO develops guidelines for evaluating existing
hooks against the new hook design criteria:
– when the hook is fully reset in the closed position, the
weight of the lifeboat does not cause any force to be
transmitted to the operating mechanism, which could
cause the inadvertent release of the lifeboat;
– locking devices cannot turn to open position due to
forces from the hook load; and
– if a hydrostatic interlock is provided, it shall
automatically reset upon lifting the boat from the water
• Design review by administrations and take into
account wear and tear of the critical parts (no
criteria given though)
LIFEBOAT SAFETY
• IMO develops guidelines to include a hook stability test
• The hooks should remain closed throughout the hook
stability test while under load
• If any hook opens during the test, all other hooks of the
same type should be tested in the case of cargo ships
• If the hooks do not remain closed throughout the test while
under load, the hooks should be replaced at the earliest
available opportunity and no later than the next scheduled
dry-docking. Until the hooks are replaced, additional safety
measures must be taken, including use of fall preventer
devices
• ISTEC: responsibility for testing & evaluating existing hooks
not with manufacturers but with Flag/RO
• Hook replacement should be a transparent, achievable and
practical evaluation process
RECOVERY SYSTEMS
• IMO develops performance standards on recovery
systems
• Suggestions that all ships have systems "capable to
recover unconscious persons from the sea with
significant wave heights of at least 3 metres, with a
rate of 10 persons per hour ".
• Performance standards are unrealistic
• Pragmatic approach for procedures in using existing
equipment rather than introducing new equipment
• Urge Coastal States to improve their respective SAR
responsibilities and capabilities rather than imposing
unrealistic and cumbersome equipment onboard
merchant ships
REGULATIONS ON BUNKERS
• ANNEX VI TO MARPOL CONVENTION
– limits the sulphur content in marine fuels
– different sulphur limits in open sea and in ECAs
– requires quality criteria for the marine fuels
• EU SULPHUR DIRECTIVE
– additional provision: use of 0.10% sulphur content
fuel when ships ”at berth” (1 January 2010)
– MGO/MDO on the EU market should have < 0.1% S
content (1 January 2010)
• CALIFORNIA AIR RESOURCE BOARD (CARB)
– use marine distillates within 24nm of the shore
– sulphur content in the marine distillates:
• before 1 January 2012 – MDO < 0.50% ; MGO <1.50%
• after 1 January 2012 - MDO/MGO< 0.10%
CARB
MGO
2.5
MDO/MGO
MGO
MDO
0.5
EU
3
2
1.5
LSFO
SULPHUR CAP (%)
APPLICATION DATES & CAPs
4.5
1
IMO/Global
HFO
4
IMO/ECA
3.5
0
01
01
01
01
01
01
01
01
nu
Ja
nu
Ja
nu
Ja
nu
Ja
nu
Ja
nu
Ja
nu
Ja
nu
Ja
y
ar
y
ar
y
ar
y
ar
y
ar
y
ar
y
ar
y
ar
24
20
22
20
20
20
18
20
16
20
14
20
12
20
10
20
CHALLENGES FOR SHIPS
• Switching between at least 3 grades of fuel
• Calling at EU ports, ships need to use:
– Deep sea fuel (HFO)
– ECA fuel (LSFO)
– EU - ”at berth”/”at anchor” fuel (MGO)
•
•
•
•
•
Onboard storage & segregation capacity
Increase risk of fuel incompatibility
Increases the risks of boiler incidents
Safety requires upgrading/modifications
Viscosity, lubricity, flash point temp.
OPTIONS FOR SHIP OWNERS
• CARB/EU regulations (2009/2010)
– use of MGO
– alternative technology not available
– shore power – little supply; safety & legal
liability issues for tankers
– fuel supply: so far no problems reported
• IMO/ECA (1 Jan. 2015)
– will have a greater impact
– MGO increase demand
– alternative technologies? existing ships?
– alternative fuels – if any, for local trade only
OPTIONS FOR SHIP OWNERS
• IMO Global (1 Jan. 2020/2025)
– complete change to marine distillates (?)
– expected demand in range of 500 mill. t/year
– gradual phase-in due to ECAs
• Scrubbers dilemma
– availability & Coastal States policies on scrubbers
– use HFO but more cleaning installations and more
hazardous waste to dispose; or
– use MGO but remove cleaning installations and
minimise onboard generated waste; less incidents
• Alternative fuels
– natural gas: possible but not yet for long voyages
– bio fuels: not recommended for shipping
NORTH AMERICAN ECA
Entry into force 1 August 2012
Challenges:
•Extent
•Fuel availability
•Ship bunker capacity
200 nm
200 nm
Will Mexico join ?
Caribs?
N AMERICAN ECA - COST IMPACT*
• Extra costs of a VLCC (2 m bbls) for a
round trip of 400 nm : $40k to $100k
(premiums for MGO of $200/t and $500/t
respectively)
• 0.8% to 2.0% increase in transportation
costs for a 2 m bbls VLCC from Persian
Gulf to US Gulf
• Apparently US and Canada will have
minimal problems to ensure supply
* Poten Fuel Oil Monthly Opinion, 6 April 2010
GLOBAL BUNKERING
Marine distillates on EU market: < 0.10% sulphur content
USA 12.70%
Canada & Mexico
0.30%
Baltic Sea 3%
North Sea 18%
Rest of the World
66%
Source: Poten & Partners
FUEL OIL QUALITY - REGULATION 18
• blend of HC derived from petroleum refining
• free from inorganic acid
• should not include any substance or chemical
waste which:
– jeopardise ship safety and adversely affects
machinery
– is harmful to personnel
– contributes to overall addition to the air emissions
• Annex VI – Regulation 18 does not define
parameters for a fuel oil standard
• Annex VI – Regulation 18 requires MARPOL
sample & BDN guaranteeing fuel compliance
FUEL OIL QUALITY - REGULATION 18
• Ship owners buy a product (i.e. bunker)
• Bunkers cannot be used as bought and
need onboard treatment
• Ship owners still do not know what they
receive and test the product they buy
against a very short specification
• Ship engines – only engines in
transportation being damaged by the fuel
used!
TANKER ENGINE INCIDENTS
Year
<10 years
10-24 years
>25 years
TOTAL Average age
2002
4
15
3
22
17.5
2003
3
8
3
14
18.4
2004
2
7
3
12
18.8
2005
9
20
5
34
17.6
2006
12
17
3
32
14.3
2007
20
25
3
48
13.2
2008
25
24
10
59
15.6
2009
18
13
22
53
16.4
2010*
5
4
5
14
17.5
82
126
30
238
15.5
TOTAL
*102 days
Based on data from LMIU, + others
COMPLIANCE - BDN INFORMATION
•
•
•
•
•
•
•
•
Name and IMO Number of receiving ship
Port
Date of commencement of delivery
Name, address, & tel. number of marine fuel oil supplier
Product name(s)
Quantity in metric tons
Density at 15°C, kg/m3
Sulphur content (%m/m)
• A declaration signed and certified by the fuel oil
supplier’s representative that the fuel oil supplied
is in conformity with the applicable
subparagraph of regulation 14.1 or 14.4 and
regulation 18.3 of this Annex.
HOW IS THIS ASCERTAINED?
ACTUAL or TYPICAL VALUES?
CONTROL OF FUEL OIL
• Port Authority obligations:
–
–
–
–
take measures to promote availability
require suppliers to provide BDN and sample
maintain a register of local suppliers
supplier certifies fuels meet Reg. 14 & 18
• BUT
• No official authority involved in control and
monitoring prior to fuel delivery
• Control by commercial fuel tests only
• Responsibility for quality compliance and
control should not be left with ships
• Quality/type of fuel has become very relevant
• Bio-contamination, catfines & ignition quality
INTERTANKO SUGGESTS
• MARPOL Annex VI includes relevant safety
parameters from ISO 8217
• Registers of local suppliers with IMO
• Control of bunkers before supply
• No onboard blending during delivery
• Monitoring reports from Administrations on
non-compliant fuel deliveries
• Keep updated list of these reports on the web
• Set up a web page where INTERTANKO
Members can record their experiences with
suppliers
CONCLUDING REMARKS
•
•
•
•
•
•
European refining has to catch up on efficiency
Switch to MGO most probable and possible
Marine distillates will be provided if required
Alternative fuels – long term solution
Technologies – long term solutions
Onboard sulphur cleaning is not the real
solution to environmental challenges
• Business will stay but will change significantly
in terms of:
– quality control
– type of products
THANK YOU
For more information please visit
www.intertanko.com
dragos.rauta@intertanko.com