MARINE ENVIRONMENT PROTECTION COMMITTEE MEPC 56/6/XX 4 May 2007 Original: ENGLISH th 56 session Agenda item 6 INTERPRETATIONS AND AMENDMENTS OF MARPOL 73/78 AND RELATED INSTRUMENTS Submitted by the International Association of Independent Tankers Owners (INTERTANKO) SUMMARY Executive Summary: Action to be taken: Related documents: INTERTANKO proposes that BLG Circular BLG.1/Circ.18 be amended to include viscosity data for vegetable oils being transported under the Revised MARPOL Annex II and the amended IBC Code Paragraph 3 BLG.1/Circ.18 1. Background 1.1 This document is submitted in accordance with the Guidelines of the organization and method of work contained in MSC-MEPC.1/Circ.1 1.2 The IBC Code requires that cargoes be referred to in the shipping document by the product name as it appears in chapter 17 or 18 of the IBC Code or the MEPC.2/Circular. The term “shipping document” has never been defined in this context in order to allow maximum flexibility for industry. However, this can sometimes lead to confusion, particularly where products are referred to by different names on various documents. 1.3 Last year the Organization developed an example of an optional shipping document that may be used where owners feel it necessary to clarify the names of products carried on board their vessels. Member States were invited to bring BLG.1/Circ.18 to the attention of interested parties and provide feedback to the Organization on its use. 2. Discussion 2.1 INTERTANKO concurs with the intent of BLG.1/Circ.18. However, as industry has seen, since the MARPOL Annex II Revisions came into effect, there are recurring problems with the lack of information and documentation relative to vessels carrying vegetable oils. Difficulties in complying with the amended IBC Code occurs when a vessel arrives in port without the required information for carriage of certain Category Y products that reference “special requirements” in the amended IBC Code more specifically paragraphs 16.2.6 / 16.2.9, which states; 16.2.6 Where column o in the table of Chapter 17 refers to this paragraph, the cargo's viscosity at 20 degrees C shall be specified on a Shipping Document, and if the cargo's viscosity exceeds 50 mPa.s at 20 degrees C, the temperature at which the cargo has a viscosity of 50 mPa.s shall be specified in the Shipping Document. 16.2.9 Where column o in the table of Chapter 17 refers to this paragraph, the cargo's melting point shall be indicated in the Shipping Document. 2.2 BLG/1 Circ 18 contains a template for a "shipping document". The intent of this document was to encourage the use of the proper shipping name. The attached revised document as set out in Annex I has been drafted for the purpose of providing the viscosity / melting point information and uses BLG.1/Circ.18 as the base document. 3 Action requested of the Committee 3.1 The Committee is invited to take action as appropriate. Annex 1 SHIPPING DOCUMENT For the purposes of MARPOL Annex II and the IBC Code Vessels Name: Shipper: B/L # / CGO # Cargo Description (Trade Name) Flag: Voyage: Product Name (as per IBC code*) Loaded in tank(s) # Load Port Discharge Port Signature Title Company/Organisation * Official name as it appears in IBC Code or MEPC.2/Circ and Ship’s Certificate of Fitness. For Marpol Category Y products with reference to IBC 16.2.6 (viscosity) / 16.2.9 (melting point): Temperature Viscosity at where viscosity Melting point 20 °C is 50 mPa.s (°C) (°C) (mPa.s) Optional Shipping Document Guidance Note The IBC Code requires that cargoes be identified in the shipping document by the product name as it appears in Chapter 17 or 18 of the IBC Code, or the MEPC.2/Circular. For practical purposes, this shipping document is normally the Bill of Lading (B/L). However, as there may be reluctance on part of the shipper or receiver in having this information on the B/L, this optional shipping document has been developed. With the upgrade of numerous products in the amended IBC Code, notably vegetable oils and oleo chemicals, the following IBC Code special requirements now apply: 16.2.6 Where column o in the table of chapter 17 refers to this paragraph, the cargo’s viscosity at 20°C shall be specified on a shipping document, and if the cargo’s viscosity exceeds 50 mPa.s at 20°C, the temperature at which the cargo has a viscosity of 50 mPa.s shall be specified in the shipping document. 16.2.9 Where column o in the table of chapter 17 refers to this paragraph, the cargo’s melting point shall be indicated in the shipping document. Both paragraphs require that information about viscosity and melting point is also stated on the shipping document. As there also may be reluctance on part of the shipper or receiver in having this information on the B/L, this optional shipping document has been developed. Since the viscosity and melting point for many products, particularly vegetable oils and oleo chemicals, may vary from shipment to shipment, port state authorities may require these values for the specific product in question, instead of some generic value. This document can be used for that purpose when necessary. It is the intention that the shipper or a responsible party on behalf of the shipper shall complete this document. It is not the place of the ship Master to verify cargo identification or specifications.