The Revisions to
MARPOL Annex II
(entry into force 1/1/2007)
A Practical Guide
November 2006
INTERTANKO would like to thank
Stolt-Nielsen Transportation Group BV
for sponsoring this publication.
The Revisions to MARPOL Annex II
(entry into force 1/1/2007)
A Practical Guide
Contents
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11
12.
13.
14.
15.
16.
17.
Disclaimer/copyright notice
Preface
INTERTANKO Chemical Tanker Committees
INTERTANKO
Market analysis section
INTERTANKO MARPOL Annex II tonnage impact study
Joint INTERTANKO, CCA, Norwegian stripping limitation survey
MARPOL Annex II Summary and Overview
IMO Circular Letter 2730
Pollution category/ship type changes
USCG NVIC
MEPC 55 Working Paper 8
Tripartite Agreement for the provisional assessment of liquid substances
INTERTANKO MARPOL Annex II waste reception facility survey
Possible scenarios for existing ships under the Amended IBC Code requirements
P&A Manual application and Certificates of Fitness
Biofuels – an update
Page
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1. Disclaimer/copyright notice
No 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 Guide
November 2006
1
2. Preface
The 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).
Figure 1
Chemical tanker fleet by hull – number
DWT cat
5,000-10,000
10,000-19,999
20,000-29,999
30,000-39,999
40,000 +
Total
DB
174
94
41
46
35
390
DH
360
369
101
313
271
1,414
DS
4
3
1
10
10
28
SH
37
40
23
20
11
131
DS
29,556
39,070
29,900
391,355
447,058
936,939
SH
258,679
592,957
668,084
690,802
518,147
2,728,669
No info
47
2
1
50
Total
622
506
168
390
327
2,013
Chemical tanker fleet by hull – dwt
DWT segment
5,000-10,000
10,000-19,999
20,000-29,999
30,000-39,999
40,000 +
Grand Total
DB
1,245,535
1,399,329
1,058,239
1,636,298
1,525,061
6,864,462
DH
2,656,408
5,452,673
2,573,600
11,159,267
12,511,339
34,353,287
No info.
318,488
59,996
37,314
415,798
Grand Total
4,508,667
7,484,029
4,389,819
13,915,036
15,001,605
45,299,155
NB includes tankers with IMO type that may not trade in Annex II products
Source: Chemindex (Inge Steensland)
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INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide
Figure 2
Source: Chemindex/Inge Steensland
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.
INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide
November 2006
3
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.
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November 2006
INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide
INTERTANKO MEMBERS will:
6. Lead the continuous improvement of the Tanker Industry’s performance in striving to achieve the goals of:
N
Zero pollution
N
Zero deaths
N
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.
Figure 4 (mts=million tons).
Type of change
Reclassified from to
Products and volumes
Re-categorisation of vegoils,
soft oils and fats
D to IMO type 2 (or IMO type 3 with DH
meeting operational requirements)
Palm oil
27 m ts
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
requirement to IMO ship type
IBC ch18 to IMO type IMO 3
Methanol
MTBE
UAN
MEG/TEG/DEG
Ethyl acetate, Methyl
ethyl ketone
17 m ts
5.5 m ts
5 m ts
5 m ts
1 m ts
Change of ship type requirements
IMO type 2 to 3
Xylenes
Acrylonitrile
> 5 m ts
< 1 m ts
No requirements
No change
Molasses
Ethanol
6 m ts
3 m ts
Source: Inge Steensland AS
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.
INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide
November 2006
5
Figure 5
Source: United States Department of Agriculture
Malaysia and Indonesia each account for just under one-third of the vegetable oils exported each, Argentine some 15%,
and Brazil some 5%.
Figure 6
Source: United States Department of Agriculture
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:
Figure 7
Source: United States Department of Agriculture
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November 2006
INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide
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.
Figure 8
Country
Japan
South Korea
Taiwan
China
Per capita vegetable oil
consumption (kg)
1999/00
2006/07*
16.8
17.7
13.4
17.5
24.7
26.5
9.5
17.1
Percentage growth
1999/00 to 2006/07*
5%
31%
7%
8%
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.
INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide
November 2006
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Figure 9
Malaysia/Indonesian palm oil trade by hull type
Hull type
SH
DB
DH
Unknown
Total
2005 - 27.5 m ts
m tonnes
Share
3.6
13%
8.8
32%
14.6
53%
0.5
2%
27.5
100%
2006 - 29.4 m ts
m tonnes
Share
4.1
14%
7.1
24%
17.6
60%
0.6
2%
29.4
100%
The shares were estimated based on reported spot fixtures only - approximately 5 million tonnes of the trade.
Source: Inge Steensland AS
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.
Figure 10
South American vegoil trade
Ship type
DH and IMO type tanks
DB to be converted to DH
Non-DH and IMO centertanks
Non-DH and non-IMO type
Total
M tonnes
1.9
1.8
2.8
5.5
12.0
Share
16%
15%
23%
46%
100%
Source: Inge Steensland AS
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.
Figure 11
Source: Chemindex / Inge Steensland AS
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INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide
Figure 12
Source: Chemindex / Inge Steensland AS
The graphs include tankers with IMO type that may not trade in
Annex II products
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.
Figure 13
INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide
November 2006
9
Figure 14
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.
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November 2006
INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide
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.
INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide
November 2006
11
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
Figure 15
Tank Configuration
Cargo
B/5 or 11.5m
(Whichever is
less, but no
where less than
760mm)
B/
760
mm
5
B/
15
Type I Tank Configuration
12
November 2006
B/
15
Type II Tank Configuration
Type III Tank Configuration
INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide
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."
INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide
November 2006
13
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 keellaid 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
14
Category
BCH Ships Constructed
before 31/7/1986
X
Pre Wash
Strip to 350 Litres
12 mile
25m water depth
7 knots, en-route
Pre Wash
Strip to 150 Litres
12 mile
25m water depth
7 knots, en-route
Pre Wash
Strip to 75 Litres
12 mile
25m water depth
7 knots, en-route
Carriage Prohibited
Y
Pre Wash for solidifying for
high viscosity substances
Strip to 350 Litres
12 mile
25m water depth
7 knots, en-route
Pre Wash for solidifying for
high viscosity substances
Strip to 150 Litres
12 mile
25m water depth
7 knots, en-route
Pre Wash for solidifying for
high viscosity substances
Strip to 75 Litres
12 mile
25m water depth
7 knots, en-route
Carriage Prohibited
Z
Strip to 950 Litres
12 mile
25m water depth
7 knots, en-route
Strip to 350 Litres
12 mile
25m water depth
7 knots, en-route
Strip to 75 Litres
12 mile
25m water depth
7 knots, en-route
Strip to
Maximum Extent
12 mile
25m water depth
7 knots, en-route
OS
No carriage Requirements
No Carriage Requirements
No Carriage Requirements
Underwater
Discharge
Required
Only X and Y cargoes
Only X and Y cargoes
X,Y and Z cargoes
November 2006
Existing IBC Constructed New Buildings Constructed
from 31/7/1986
from 1/1/2007
but before 1/1/2007
Ships Other than
Chemical Tankers
constructed
before 1/1/2007
Only X and Y cargoes
INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide
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:
N
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);
N
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;
N
The relative development of a new pollution categorisation system and criteria for assigning products to these new
categories;
N
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;
N
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.
N
The fate of any products omitted from the amended IBC Code due to missing safety and/or pollution data. They
INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide
November 2006
15
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.
N
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.
N
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.
N
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.
Figure 17
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
after 1 January 2007
N/A
Issue a certificate under the revised MARPOL Annex II
starting as from 1 January 2007 with an identical expiry
date as the existing certificate.
Renewal survey on or
after 1 July 2006
Extend the validity of the existing
certificate to 1 January 2007.
Issue a new certificate under the revised MARPOL
Annex II with an expiry date of 5 years from the survey date.
Change of flag on or
after 1 July 2006
Replace the coversheet of the current certificate R
with an extension of the validity to 1 January 2007.
Issue a new certificate under the revised MARPOL
Annex II with an expiry date of 5 years from the renewal
survey date.
Delivery of a new vessel
(e.g. 1 July 2006)
Issue a short term certificate under the current
MARPOL Annex II valid until 1 January 2007.
Issue a full term certificate alid for 5 years after the
initial survey.
16
November 2006
INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide
10. Pollution Category/Ship type changes
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
Table 1
Product
New Poll Cat New ship type Old poll cat
Acetic acid
Z
3
D
Acetic anhydride
Z
2
D
Acetochlor
X
2
A
Acetone cyanohydrin
Y
2
A
Acetonitrile
Z
2
III
Acetonitrile (low purity grade)
Y
3
D
Acid oil mixture from soyabean, corn (maize) and sunflower oil refining
Y
2
D
Acrylamide solution (50% or less)
Y
2
D
Acrylic acid
Y
2
D
Acrylonitrile
Y
2
B
Acrylonitrile-Styrene copolymer dispersion in polyether polyol
Y
3
D
Adiponitrile
Z
3
D
Alachlor technical (90% or more)
X
2
B
Alcohol (C9-C11) poly (2.5-9) ethoxylate
Y
3
B
Alcohol (C6-C17) (secondary) poly(3-6)ethoxylates
Y
2
A
Alcohol (C6-C17) (secondary) poly(7-12)ethoxylates
Y
2
B
Alcohol (C12-C16) poly(1-6)ethoxylates
Y
2
A
Alcohol (C12-C16) poly(20+)ethoxylates
Y
3
C
Alcohol (C12-C16) poly(7-19)ethoxylates
Y
2
B
Alcohols (C13+)
Y
2
III
Alcohols (C8-C11) primary, linear and essentially linear
Y
2
Alcohols (C12-C13) primary, linear and essentially linear
Y
2
Alcohols (C14-C18) primary, linear and essentially linear
Y
2
Alkanes (C6-C9)
X
2
C
Iso- and cyclo-alkanes (C10-C11)
Z
3
18 - D
Iso- and cyclo-alkanes (C12+)
Z
3
18 -III
n-Alkanes (C10+)
Z
3
18 - III
Alkenyl (C16-C20) succinic anhydride
Z
3
D
Alkaryl polyethers (C9-C20)
Y
2
B
Alkenyl (C1 1+) amide
X
2
18 -D
Alkyl acrylate-vinylpyridine copolymer in toluene
Y
2
C
Alkylaryl phosphate mixtures (more than 40% Diphenyl tolyl
phosphate, less than 0.02% ortho-isomers)
X
1
A
Alkylated (C4-C9) hindered phenols
Y
2
D
Alkylbenzene, alkylindane, alkylindene mixture (each C12-C17)
Z
3
A
Alkyl benzene distillation bottoms
Y
2
Alkylbenzene mixtures (containing at least 50% of toluene)
Y
3
Alkyl (C3-C4) benzenes
Y
2
A
Alkyl (C5-C8) benzenes
X
2
A
Alkyl(C9+)benzenes
Y
3
III
Alkyl (C11-C17) benzene sulphonic acid
Y
2
C
Alkylbenzene sulphonic acid, sodium salt solution
Y
2
C
Alkyl (C12+) dimethylamine
X
1
A
Alkyl dithiocarbamate (C19-C35)
Y
3
D
Alkyldithiothiadiazole (C6-C24)
Y
3
D
Alkyl ester copolymer (C4-C20)
Y
2
D
Alkyl (C7-C9) nitrates
Y
2
B
INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide
Old ship Type
3
2
2
2
2
2
n/a
2
3
2
n/a
3
3
3
2
3
2
3
3
n/a
3
n/a
n/a
n/a
3
3
n/a
3
1
3
2
3
2
n/a
3
3
1
n/a
n/a
n/a
2
November 2006
17
Alkyl (C8-C10)/(C12-C14):(40% or less/60% or more)
polyglucoside solution (55% or less)
Alkyl (C8-C10)/(C12-C14):(60% or more/40% or less)
polyglucoside solution(55% or less)
Alkyl (C8-C40) phenol sulphide
Alkyl (C8-C9) phenylamine in aromatic solvents
Alkyl(C7-C1 1)phenol poly(4-12) ethoxylate
Alkyl (C9-C15) phenyl propoxylate
Alkyl (C8-C10)/(C12-C14):(50%/50%) polyglucoside
solution (55% or less)
Alkyl (C12-C14) polyglucoside solution (55% or less)
Alkyl (C8-C10) polyglucoside solution (65% or less).
Alkyl(C 10-C20, saturated and unsaturated) phosphite
Alkyl sulphonic acid ester of phenol
Allyl alcohol
Allyl chloride
Aluminium sulphate solution
2-(2-Aminoethoxy) ethanol
Aminoethyldiethanolamine/Aminoethylethanolamine solution
Aminoethyl ethanolamine
N-Aminoethylpiperazine
2-Amino-2-methyl-1 -propanol
Ammonia aqueous (28% or less)
Ammonium hydrogen phosphate solution
Ammonium lignosulphonate solutions
Ammonium nitrate solution (93% or less)
Ammonium polyphosphate solution
Ammonium sulphate solution
Ammonium sulphide solution (45% or less)
Ammonium thiosulphate solution (60% or less)
Amyl acetate (all isomers)
n-Amyl alcohol
Amyl alcohol, primary
sec-Amyl alcohol
tert-Amyl alcohol
tert-Amyl methyl ether
Aniline
Aryl polyolefins (C1 1-C50)
Aviation alkylates (C8 paraffins and iso-paraffins BPT 95 - 120°C)
Barium long chain (C11-C50) alkaryl sulphonate
Benzene and mixtures having 10% benzene or more (i)
Benzene sulphonyl chloride
Benzenetricarboxylic acid, trioctyl ester
Benzyl acetate
Benzyl alcohol
Brake fluid base mix: Poly(2-8)alkylene (C2-C3) glycols/Polyalkylene
(C2-C10) glycols monoalkyl (C1-C4) ethers and their borate esters
Bromochloromethane
Butene oligomer
Butyl acetate (all isomers)
Butyl acrylate (all isomers)
tert-Butyl alcohol
Butylamine (all isomers)
Butylbenzene (all isomers)
Butyl benzyl phthalate
Butyl butyrate (all isomers)
Butyl/Decyl/Cetyl/Eicosyl methacrylate mixture
Butylene glycol
1,2-Butylene oxide
n-Butyl ether
18
November 2006
Y
3
B
3
Y
Z
Y
Y
Z
3
3
2
2
3
C
D
A
B
III
3
n/a
3
3
n/a
Y
Y
Y
Y
Y
Y
Y
Y
Z
Z
Z
Z
Z
Y
Z
Z
Z
Z
Z
Y
Z
Y
Z
Z
Z
Z
X
Y
Y
X
Y
Y
Z
Y
Y
Y
3
3
3
2
3
2
2
2
3
3
3
3
3
2
3
3
2
3
3
2
3
3
3
3
3
3
2
2
2
2
2
3
3
2
2
3
C
B
C
C
III
B
B
D
D
D
D
D
D
C
D
III
D
D
D
B
C
C
D
D
D
III
C
C
D
C
B
C
D
III
C
C
3
3
3
3
n/a
2
2
n/a
3
3
3
3
n/a
3
n/a
n/a
2
n/a
n/a
2
3
3
n/a
n/a
n/a
n/a
3
2
n/a
3
2
3
3
n/a
3
3
Z
Z
X
Y
Y
Z
Y
X
X
Y
Y
Z
Y
Y
3
3
2
3
2
3
2
2
2
3
2
3
3
3
D
D
B
C
B
III
C
A
A
B
D
D
C
C
n/a
3
3
3
2
n/a
2
3
2
3
3
n/a
3
3
INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide
Butyl methacrylate
n-Butyl propionate
Butyraldehyde (all isomers)
Butyric acid
gamma-Butyrolactone
Calcium carbonate slurry
Calcium hydroxide slurry
Calcium hypochlorite solution (15% or less)
Calcium hypochlorite solution (more than 15%)
Calcium lignosulphonate solutions
Calcium long-chain alkaryl sulphonate (C11-C50)
Calcium long-chain alkyl(C5-C10) phenate
Calcium long-chain alkyl(C11 -C40) phenate
Calcium long-chain alkyl phenate sulphide (C8-C40)
Calcium long-chain alkyl salicylate (C13+)
Calcium nitrate/Magnesium nitrate/Potassium chloride solution
epsilon-Caprolactam (molten or aqueous solutions)
Carbolic oil
Carbon disulphide
Carbon tetrachloride
Cashew nut shell oil (untreated)
Castor oil
Cetyl/Eicosyl methacrylate mixture
Chlorinated paraffins (C10-C13)
Chlorinated paraffins (C14-C17) (with 50% chlorine or more,
and less than 1% C13 or shorter chains)
Chloroacetic acid (80% or less)
Chlorobenzene
Chloroform
Chlorohydrins (crude)
4-Chloro-2-methylphenoxyacetic acid, dimethylamine salt solution
o-Chloronitrobenzene
1-(4-Chlorophenyl)-4,4- dimethyl-pentan-3-one
2- or 3-Chloropropionic acid
Chlorosulphonic acid
m-Chlorotoluene
o-Chlorotoluene
p-Chlorotoluene
Chlorotoluenes (mixed isomers)
Choline chloride solutions
Citric acid (70% or less)
Coal tar
Coal tar pitch (molten)
Coal tar naphtha solvent
Cocoa Butter
Coconut oil
Coconut oil fatty acid
Coconut oil fatty acid methyl ester
Copper salt of long chain (C17+) alkanoic acid
Corn Oil
Cotton seed oil
Creosote (coal tar)
Cresols (all isomers)
Cresylic acid, dephenolized
Cresylic acid, sodium salt solution
Crotonaldehyde
1,5,9-Cyclododecatriene
Cycloheptane
Cyclohexane
Cyclohexanol
INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide
Z
Y
Y
Y
Y
Z
Z
Y
X
Z
Z
Y
Z
Y
Y
Z
Z
Y
Y
Y
Y
Y
Y
X
3
3
3
3
3
3
3
2
1
3
3
3
3
2
2
3
3
2
2
2
2
2 (k)
2
1
D
C
C
D
D
III
D
C
B
III
D
C
D
D
C
III
D
A
B
B
D
D
3
3
3
3
n/a
n/a
n/a
3
3
n/a
n/a
3
n/a
n/a
3
n/a
n/a
2
2
3
n/a
n/a
A
1
X
Y
Y
Y
Y
Y
Y
Y
Z
Y
Y
Y
Y
Y
Z
Z
X
X
Y
Y
Y
Y
Y
Y
Y
Y
X
Y
Y
Y
Y
X
X
Y
Y
1
2
2
3
2
2
2
2
3
1
2
2
2
2
3
3
2
2
2
2 (k)
2 (k)
2
2
2
2 (k)
2 (k)
2
2
2
2
2
1
2
2
2
D
C
B
B
D
C
B
B
C
C
B
A
B
A
D
D
A
D
B
D
D
C
D
D
D
D
A
A
A
A
A
A
C
C
D
n/a
2
3
3
2
3
2
3
3
1
3
3
2
2
n/a
n/a
2
3
3
n/a
n/a
3
n/a
N/a
N/a
N/a
2
2
2
2
2
1
3
3
n/a
November 2006
19
Cyclohexanone
Cyclohexanone, Cyclohexanol mixture
Cyclohexyl acetate
Cyclohexylamine
1,3-Cyclopentadiene dimer (molten)
Cyclopentane
Cyclopentene
p-Cymene
Decahydronaphthalene
Decanoic acid
Decene
Decyl acrylate
Decyl alcohol (all isomers)
Decyloxytetrahydrothiophene dioxide
Diacetone alcohol
Dialkyl (C8-C9) diphenylamines
Dialkyl (C7-C13) phthalates
Dibromomethane
Dibutylamine
Dibutyl hydrogen phosphonate
2,6 -Di-tertbutylphenol
Dibutyl phthalate
Dichlorobenzene (all isomers)
3,4-Dichloro-1-butene
1,1-Dichloroethane
Dichloroethyl ether
1,6-Dichlorohexane
2,2'-Dichloroisopropyl ether
Dichloromethane
2,4-Dichlorophenol
2,4-Dichlorophenoxyacetic acid, diethanolamine salt solution
2,4-Dichlorophenoxyacetic acid, dimethylamine salt solution (70% or less)
2,4-Dichlorophenoxyacetic acid, triisopropanolamine salt solution
1, 1 -Dichloropropane
1,2-Dichloropropane
1,3-Dichloropropene
Dichloropropene/Dichloropropane mixtures
2,2-Dichloropropionic acid
Diethanolamine
Diethylamine
Diethylaminoethanol
2,6-Diethylaniline
Diethylbenzene
Diethylene glycol dibutyl ether
Diethylene glycol diethyl ether
Diethylene glycol phthalate
Diethylenetriamine
Diethylenetriaminepentaacetic acid, pentasodium salt solution
Diethyl ether
Di-(2-ethylhexyl) adipate
Di-(2-ethylhexyl) phosphoric acid
Diethyl phthalate
Diethyl sulphate
Diglycidyl ether of bisphenol A
Diglycidyl ether of bisphenol F
Diheptyl phthalate
Di-n-hexyl adipate
Dihexyl phthalate
Diisobutylamine
Diisobutylene
20
November 2006
Z
Y
Y
Y
Y
Y
Y
Y
Y
X
X
X
Y
X
Z
Z
X
Y
Y
Y
X
X
X
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
X
X
Y
Y
Y
Y
Y
Y
Z
Z
Y
Y
Z
Z
Y
Y
Y
Y
X
Y
Y
X
Y
Y
Y
3
3
3
3
2
2
2
2
2
2
2
1
2
2
3
3
2
2
3
3
1
2
2
2
3
2
2
2
3
2
3
3
3
2
2
2
2
3
3
3
2
3
2
3
3
3
3
3
2
2
2
2
2
2
2
2
1
2
2
2
D
D
B
C
B
C
B
C
D
C
B
A
B
A
D
D
D
C
C
B
A
A
B
B
D
B
B
C
D
A
A
A
A
C
C
B
B
D
D
C
C
C
A
D
III
D
D
III
D
D
C
C
B
B
B
D
B
III
C
B
3
3
3
3
2
3
3
3
n/a
3
3
2
3
2
n/a
N/a
n/a
2
3
3
1
2
2
3
3
2
2
2
3
2
3
3
3
2
2
2
2
3
3
3
3
3
3
n/a
n/a
n/a
3
n/a
2
n/a
3
3
2
3
3
n/a
3
n/a
2
3
INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide
Diisobutyl ketone
Diisobutyl phthalate
Diisononyl adipate
Diisooctyl phthalate
Diisopropanolamine
Diisopropylamine
Diisopropylbenzene (all isomers)
Diisopropylnaphthalene
N,N-Dimethylacetamide
N,N-Dimethylacetamide solution (40% or less)
Dimethyl adipate
Dimethylamine solution (45% or less)
Dimethylamine solution (greater than 45% but not greater than 55%)
Dimethylamine solution (greater than 55% but not greater than 65%)
N,N-Dimethylcyclohexylamine
Dimethyl disulphide
N,N-Dimethyldodecylamine
Dimethylethanolamine
Dimethylformamide
Dimethyl glutarate
Dimethyl hydrogen phosphite
Dimethyl octanoic acid
Dimethyl phthalate
Dimethylpolysiloxane
2,2-Dimethylpropane-1,3-diol (molten or solution)
Dimethyl succinate
Dinitrotoluene (molten)
Dinonyl phthalate
Dioctyl phthalate
1,4-Dioxane
Dipentene
Diphenyl
Diphenylamine (molten)
Diphenylamine, reaction product with 2,2,4-Trimethylpentene
Diphenylamines, alkylated
Diphenyl/Diphenyl ether mixtures
Diphenyl ether
Diphenyl ether/Diphenyl phenyl ether mixture
Diphenylmethane diisocyanate
Diphenylol propane-epichlorohydrin resins
Di-n-propylamine
Dipropylene glycol
Distilled resin oil
2,6-Di-tert-butylphenol
Dithiocarbamate ester (C7-C35)
Ditridecyl adipate
Ditridecyl phthalate
Diundecyl phthalate
Dodecane (all isomers)
tert-Dodecanethiol
Dodecene (all isomers)
Dodecyl alcohol
Dodecylamine/Tetradecylamine mixture
Dodecylbenzene
Dodecyl diphenyl ether disulphonate solution
Dodecyl hydroxypropyl sulphide
Dodecyl methacrylate
Dodecyl/Octadecyl methacrylate (mixture)
Dodecyl/Pentadecyl methacrylate mixture
Dodecyl phenol
INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide
Y
X
Y
Y
Z
Y
X
Y
Z
Z
X
Y
Y
Y
Y
Y
X
Y
Y
Y
Y
Y
Y
Y
Z
Y
X
Y
X
Y
Y
X
Y
Y
Y
X
X
X
Y
X
Y
Z
Y
X
X
Y
Y
Y
Y
X
X
Y
Y
Z
X
X
Z
Z
Y
X
3
2
2
2
3
2
2
2
3
3
2
3
2
2
2
2
1
3
3
3
3
2
3
3
3
3
2
2
2
2
3
2
2
1
2
2
2
2
2
2
2
3
2
1
2
2
2
2
2
1
2
2
2
3
2
2
3
3
2
2
D
B
D
III
C
C
A
D
D
D
B
C
C
C
C
B
A
D
D
C
B
C
C
III
D
C
A
D
III
D
C
A
B
A
A
A
A
A
B
B
C
III
D
n/a
3
n/a
n/a
3
2
2
N/a
3
3
3
3
2
2
2
3
1
3
3
3
3
3
3
n/a
n/a
3
2
n/a
n/a
2
3
1
3
1
2
1
3
3
2
3
3
n/a
n/a
A
III
D
D
III
A
B
B
A
III
A
A
III
D
III
A
2
n/a
n/a
n/a
n/a
1
3
3
2
n/a
2
1
3
3
3
1
November 2006
21
Dodecyl Xylene
Drilling brines (containing zinc salts)
Drilling brines, including:calcium bromide solution, calcium
chloride solution and sodium chl soln
Epichlorohydrin
Ethanolamine
2-Ethoxyethyl acetate
Ethoxylated long chain (C16+) alkyloxyalkylamine
Ethyl acetate
Ethyl acetoacetate
Ethyl acrylate
Ethylamine
Ethylamine solutions (72% or less)
Ethyl amyl ketone
Ethylbenzene
Ethyl tert-butyl ether
Ethyl butyrate
Ethylcyclohexane
N-Ethylcyclohexylamine
S-Ethyl dipropylthiocarbamate
Ethylene chlorohydrin
Ethylene cyanohydrin
Ethylenediamine
Ethylenediaminetetraacetic acid, tetrasodium salt solution
Ethylene dibromide
Ethylene dichloride
Ethylene glycol
Ethylene glycol acetate
Ethylene glycol butyl ether acetate
Ethylene glycol diacetate
Ethylene glycol methyl ether acetate
Ethylene glycol monoalkyl ethers
Ethylene glycol phenyl ether
Ethylene glycol phenyl ether/Diethylene glycol phenyl ether mixture
Ethylene oxide/Propylene oxide mixture with an ethylene oxide
content of not more than 30% by mass
Ethylene-Vinyl acetate copolymer (emulsion)
Ethyl-3-ethoxypropionate
2-Ethylhexanoic acid
2-Ethylhexyl acrylate
2-Ethylhexylamine
2-Ethyl-2-(hydroxymethyl) propane-1,3-diol, C8-C10 ester
Ethylidene norbornene
Ethyl methacrylate
N-Ethylmethylallylamine
2-Ethyl-3-propylacrolein
Ethyl toluene
Fatty acid (saturated C13+)
Fatty acid methyl esters (m)
Fatty acids, C12+
Fatty acids, C16+ Fraction
Fatty acid (saturated C13+)
Fatty acids C8-C10 Fraction
Fatty acids, essentially linear,C6-C18, 2-ethylhexyl ester.
Ferric chloride solutions
Ferric nitrate/Nitric acid solution
Fish oil
Flourosilic acid (20-30%) in water solution
Formaldehyde solutions (45% or less)
Formamide
22
November 2006
Y
X
2
2
III
B
n/a
3
Z
Y
Y
Y
Y
Z
Z
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Z
Z
3
2
3
3
2
3
3
2
2
2
3
2
3
3
2
2
2
2
3
2
3
2
2
3
3
3
3
3
3
3
3
III
A
D
C
D
D
D
A
C
C
C
B
C
C
C
D
C
C
D
C
D
B
B
D
D
C
C
C
D
D
D
n/a
2
3
3
n/a
n/a
n/a
2
2
2
3
3
3
3
3
3
3
2
3
2
n/a
2
2
n/a
n/a
3
3
3
3
n/a
n/a
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
2
3
3
3
3
2
2
2
3
2
2
2
2
2
3
2
2
2
2
3
2
2 (k)
3
3
3
C
III
C
D
B
B
D
B
D
C
A
B
III
D
2
n/a
3
n/a
3
2
n/a
3
3
2
3
3
n/a
n/a
III
n/a
D
C
C
D
C
C
D
n/a
3
2
n/a
3
3
n/a
INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide
Formic acid
Furfural
Furfuryl alcohol
Glucitol/glycerol blend propoxylated (containing less than 10 % amines)
Glutaraldehyde solutions (50% or less)
Glycerol monooleate
Glycerol propoxylated
Glycerol propoxylated and ethoxylated
Glycerol/Sucrose Blend propoxylated and ethoxylated
Glyceryl triacetate
Glycidyl ester of C 10 trialkylacetic acid
Glycine, sodium salt solution
Glycolic acid solution (70% or less)
Glyoxal solution (40% or less)
Glyoxylic acid solution (50 % or less)
Glyphosate solution (not containing surfactant)
Groundnut oil
Heptane (all isomers)
n-Heptanoic acid
Heptanol (all isomers) (d)
Heptene (all isomers)
Heptyl acetate
1-Hexadecylnaphthalene / 1,4-bis(hexadecyl)naphthalene mixture
Hexamethylenediamine adipate (50% in water)
Hexamethylenediamine (molten)
Hexamethylenediamine solution
Hexamethylene diisocyanate
Hexamethylene glycol
Hexamethyleneimine
Hexane (all isomers)
1,6-Hexanediol, distillation overheads
Hexanoic acid
Hexanol
Hexene (all isomers)
Hexyl acetate
Hydrochloric acid
Hydrogen peroxide solutions (over 8% but not over 60% by mass)
Hydrogen peroxide solutions (over 60% but not over 70% by mass)
2-Hydroxyethyl acrylate
N-(Hydroxyethyl)ethylenediaminetriacetic acid, trisodium salt solution
2-Hydroxy-4-(methylthio)butanoic acid
Illipe oil
Isoamyl alcohol
Isobutyl alcohol
Isobutyl formate
Isobutyl methacrylate
Isophorone
Isophoronediamine
Isophorone diisocyanate
Isoprene
Isopropanolamine
Isopropyl acetate
Isopropylamine
Isopropylamine (70% or less) solution
Isopropylcyclohexane
Isopropyl ether
Lactic acid
Lactonitrile solution (80% or less)
Lard
Latex, ammonia (1% or less), inhibited
INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide
Y
Y
Y
Z
Y
Y
Z
Z
Z
Z
Y
Z
Z
Y
Y
Y
Y
X
Z
Y
Y
Y
Y
Z
Y
Y
Y
Z
Y
Y
Y
Y
Y
Y
Y
Z
Y
Y
Y
Y
Z
Y
Z
Z
Z
Z
Y
Y
X
Y
Y
Z
Y
Y
Y
Y
Z
Y
Y
Y
3
3
3
3
3
2
3
3
3
3
2
3
3
3
3
2
2 (k)
2
3
3
3
2
2
3
2
3
2
3
2
2
3
3
3
3
2
3
3
2
2
3
3
2 (k)
3
3
3
3
3
3
2
3
3
3
2
2
2
3
3
2
2 (k)
3
D
C
C
3
3
3
D
D
3
n/a
III
B
III
D
D
D
D
D
C
D
C
C
B
III
D
C
C
B
III
C
C
C
D
D
C
B
D
C
C
B
D
C
D
D
III
D
D
C
D
B
C
C
D
C
C
C
D
D
B
D
D
n/a
3
n/a
3
n/a
3
n/a
n/a
3
n/a
3
3
3
n/a
n/a
2
3
2
n/a
2
3
3
n/a
n/a
3
3
3
3
2
2
n/a
3
n/a
n/a
n/a
n/a
3
3
3
2
3
3
n/a
2
2
3
3
n/a
2
n/a
n/a
November 2006
23
Latex: Carboxylated styrene-Butadiene copolymer;
Styrene-Butadiene rubber
Lauric acid
Ligninsulphonic acid, sodium salt solution
Linseed oil
Liquid chemical wastes
Long-chain alkaryl polyether (C11-C20)
Long-chain alkaryl sulphonic acid (C16-C60)
Long-chain alkylphenate/Phenol sulphide mixture
L-Lysine solution (60% or less)
Magnesium chloride solution
Magnesium long-chain alkaryl sulphonate (C11-C50)
Magnesium long-chain alkyl salicylate (C1 1+)
Maleic anhydride
Mango kernel oil
Mercaptobenzothiazol, sodium salt solution
Mesityl oxide
Metam sodium solution
Methacrylic acid
Methacryclic acid - alkoxypoly (alkylene oxide) methacrylate copolymer,
sodium salt aqueous solution (45% or less)
Methacrylic resin in Ethylene dichloride
Methacrylonitrile
3-Methoxy-1-butanol
3-Methoxybutyl acetate
N-(2-Methoxy-1-methyl ethyl)-2-ethyl-6-methyl chloroacetanilide
Methyl acetate
Methyl acetoacetate
Methyl acrylate
Methyl alcohol
Methylamine solutions (42% or less)
Methylamyl acetate
Methylamyl alcohol
Methyl amyl ketone
Methylbutenol
Methyl tert-butyl ether
Methyl butyl ketone
Methylbutynol
Methyl butyrate
Methylcyclohexane
Methylcyclopentadiene dimer
Methylcyclopentadienyl manganese tricarbonyl
Methyl diethanolamine
2-Methyl-6-ethyl aniline
Methyl ethyl ketone
2-Methyl-5-ethyl pyridine
Methyl formate
2-Methyl-2-hydroxy-3 -butyne
Methyl isobutyl ketone
Methyl methacrylate
3 -Methyl-3 -methoxybutanol
Methyl naphthalene (molten)
2-Methyl-1,3-propanediol
2-Methylpyridine
3-Methylpyridine
4-Methylpyridine
N-Methyl-2-pyrrolidone
Methyl salicylate
alpha-Methylstyrene
3-(methylthio)propionaldehyde
24
November 2006
Z
X
Z
Y
X
Y
Y
Y
Z
Z
Y
Y
Y
Y
X
Z
X
Y
3
2
3
2 (k)
2
2
2
2
3
3
2
2
3
2 (k)
2
3
1
3
III
B
III
D
A
C
D
III
D
III
D
D
D
D
B
D
A
D
n/a
3
n/a
n/a
2
3
n/a
n/a
n/a
n/a
n/a
n/a
3
n/a
3
3
2
3
Z
Y
Y
Z
Y
X
Z
Z
Y
Y
Y
Y
Z
Z
Y
Z
Y
Z
Y
Y
Y
X
Y
Y
Z
Y
Z
Z
Z
Y
Z
X
Z
Z
Z
Z
Y
Y
Y
Y
3
2
2
3
3
1
3
3
2
3
2
2
3
3
3
3
3
3
3
2
2
1
3
3
3
3
2
3
3
2
3
2
3
2
2
2
3
3
2
2
D
D
D
III
D
n/a
2
2
n/a
n/a
III
D
B
D
C
C
C
B
D
D
D
D
C
C
B
A
D
C
III
B
D
III
D
D
III
A
III
D
C
D
D
B
A
B
n/a
n/a
2
n/a
2
3
3
3
n/a
n/a
n/a
n/a
3
3
3
1
3
3
n/a
3
2
3
n/a
2
n/a
2
n/a
2
2
2
n/a
3
3
3
INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide
Molybdenum Polysulfide Long Xhain Alkyl Dithocrabamide Complex
Morpholine
Motor fuel anti-knock compounds (containing lead alkyls)
Myrcene
Naphthalene (molten)
Naphthalenesulphonic acid-Formaldehyde copolymer, sodium salt solution
Neodecanoic acid
Nitrating acid (mixture of sulphuric and nitric acids)
Nitric acid (70% and over)
Nitric acid (less than 70%)
Nitrilotriacetic acid, trisodium salt solution
Nitrobenzene
Nitroethane
Nitroethane(80%)/ Nitropropane(20%)
Nitroethane, 1-Nitropropane (each 15% or more) mixture
o- or p-Nitrotoluenes
o-Nitrophenol (molten)
1- or 2-Nitropropane
Nitropropane (60%)/Nitroethane (40%) mixture
Nonane (all isomers)
Nonanoic acid (all isomers)
Nonene (all isomers)
Nonyl alcohol (all isomers)
Nonyl methacrylate monomer
Nonylphenol
Nonylphenol poly(4+)ethoxylate
Noxious liquid, NF, (1) n.o.s. (trade name ...., contains ....) ST1, Cat. X
Noxious liquid, F, (2) n.o.s. (trade name ...., contains ....) ST1, Cat. X
Noxious liquid, NF, (3) n.o.s. (trade name ...., contains ....) ST2, Cat. X
Noxious liquid, F, (4) n.o.s. (trade name ...., contains ....) ST2, Cat. X
Noxious liquid, NF, (5) n.o.s. (trade name ...., contains ....) ST2, Cat. Y
Noxious liquid, F, (6) n.o.s. (trade name ...., contains ....) ST2, Cat. Y
Noxious liquid, NF, (7) n.o.s. (trade name ...., contains ....) ST3, Cat. Y
Noxious liquid, F, (8) n.o.s. (trade name ...., contains ....) ST3, Cat. Y
Noxious liquid, NF, (9) n.o.s. (trade name ...., contains ....) ST3, Cat. Z
Noxious liquid, F, (10) n.o.s. (trade name ...., contains ....) ST3, Cat. Z
Octane (all isomers)
Octanoic acid (all isomers)
Octanol (all isomers)
Octene (all isomers)
n-Octyl acetate
Octyl aldehydes
Octyl decyl adipate
Olefin-Alkyl ester copolymer (molecular weight 2000+)
Olefin mixtures (C5-C7)
Olefin mixtures (C5-C15)
alpha-Olefins (C6-C18) mixtures
Olefins (C13+, all isomers)
Oleic acid
Oleum
Oleylamine
Olive oil
Oxygenated aliphatic hydrocarbon mixture
Palm acid oil
Palm fatty acid distillate
Palm kernel oil
Palm kernel acid oil
Palm kernel olein
Palm kernel stearin
Palm mid fraction
INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide
Y
Y
X
X
X
Z
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
X
Y
Y
Y
Y
X
Y
X
X
X
X
Y
Y
Y
Y
Z
Z
X
Z
Y
Y
Y
Y
Y
Y
Y
X
X
Y
Y
Y
X
Y
Z
Y
Y
Y
Y
Y
Y
Y
2
3
1
2
2
3
2
2
2
2
3
2
3
3
3
2
2
3
3
2
3
2
2
2
1
2
1
1
2
2
2
2
3
3
3
3
2
3
2
2
3
2
2
2
3
2
2
2
2
2
2
2 (k)
3
2
2
2 (k)
2
2 (k)
2 (k)
2(k)
C
A
D
A
D
C
C
C
C
D
B
D
D
D
B
B
D
D
C
D
B
B
D
A
B
A
A
A
A
B
B
B
B
C
C
C
3
1
n/a
2
n/a
3
2
2
2
n/a
2
3
3
3
2
2
3
3
3
n/a
3
3
n/a
2
3
1
1
2
2
2
2
3
3
3
3
3
C
B
C
B
B
3
3
3
3
3
C
B
B
3
3
3
C
A
D
D
2
2
n/a
n/a
D
C
D
D
n/a
3
n/a
n/a
November 2006
25
Palm oil
Non-edible industrial grade palm oil
Palm oil fatty acid methyl ester
Palm olein
Palm stearin
Paraffin wax
Paraldehyde
Paraldehyde-ammonia reaction product
Pentachloroethane
1,3-Pentadiene
Pentane (all isomers)
Pentanoic acid
n-Pentanoic acid (64%)/2-Methyl butyric acid (36%) mixture
Pentene (all isomers)
n-Pentyl propionate
Perchloroethylene
Petrolatum
Phenol
1-Phenyl-1-xylyl ethane
Phosphate esters, alkyl (C12-C14) amine
Phosphoric acid
Phosphorous, yellow or white
Phthalic anhydride (molten)
alpha-Pinene
beta-Pinene
Pine oil
Polyacrylic acid solution (40% or less)
Polyalkyl (C18-C22) acrylate in xylene
Poly(2-8)alkylene glycol monoalkyl(C1-C6) ether
Poly(2-8)alkylene glycol monoalkyl (C1-C6) ether acetate
Polyalkyl (C10-C20) methacrylate
Polyalkyl (C10-C18) methacrylate/ethylene-propylene copolymer mixture
Polybutene
Polybutenyl succinimide
Poly(2+)cyclic aromatics
Polyethylene glycol
Polyethylene glycol dimethyl ether
Polyethylene polyamines
Polyferric sulphate solution
Poly(iminoethylene)-graft-N-poly(ethyleneoxy) solution (90% or less)
Polyisobutenamine in aliphatic (C10-C14) solvent
Polyisobutenyl anhydride adduct
Poly(4+)isobutylene
Polymethylene polyphenyl isocyanate
Polyolefin (molecular weight 300+)
Polyolefin amide alkeneamine (C17+)
Polyolefin amide alkeneamine borate (C28-C250)
Polyolefinamine (C28-C250)
Polyolefinamine in alkyl (C2-C4) benzenes
Polyolefinamine in aromatic solvent
Polyolefin aminoester salts (molecular weight 2000+)
Polyolefin anhydride
Polyolefin ester (C28-C250)
Polyolefin phenolic amine (C28-C250)
Polyolefin phosphorosulphide, barium derivative (C28-C250)
Poly(20)oxyethylene sorbitan monooleate
Poly(5+)propylene
Polypropylene glycol
Polysiloxane
Potassium chloride solution (10% or more)
26
November 2006
Y
Y
Y
Y
Y
Y
Z
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Z
X
Y
X
X
X
Z
Y
Z
Y
Y
Y
Y
Y
X
Z
Z
Y
Y
Z
Y
Z
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Z
Y
Z
2 (k)
2
2
2 (k)
2 (k)
2
3
2
2
3
3
3
2
3
3
2
2
2
3
2
3
1
2
2
2
2
3
2
3
2
2
2
2
2
1
3
3
2
3
3
3
3
2
2
2
2
2
2
2
2
2
2
2
2
2
2
3
3
3
3
D
n/a
D
D
III
C
C
B
C
C
D
D
C
C
B
III
C
C
B
D
A
C
A
B
C
III
C
D
D
D
D
III
D
A
III
III
C
C
III
C
III
III
D
III
D
D
C
C
C
D
D
D
D
C
III
III
D
III
III
n/a
n/a
n/a
3
2
2
3
3
n/a
2
3
3
3
n/a
2
3
3
3
1
3
3
3
3
n/a
3
n/a
n/a
n/a
n/a
n/a
n/a
2
n/a
n/a
3
3
n/a
3
n/a
n/a
2
n/a
n/a
n/a
3
3
3
n/a
n/a
n/a
n/a
3
n/a
n/a
n/a
n/a
n/a
INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide
Potassium hydroxide solution
Potassium oleate
Potassium thiosulphate (50% or less)
n-Propanolamine
beta-Propiolactone
Propionaldehyde
Propionic acid
Propionic anhydride
Propionitrile
n-Propyl acetate
n-propyl alcohol
n-Propylamine
Propylbenzene (all isomers)
Propylene glycol methyl ether acetate
Propylene glycol monoalkyl ether
Propylene glycol phenyl ether
Propylene oxide
Propylene tetramer
Propylene trimer
Pyridine
Pyrolysis gasoline (containing benzene)
Rapeseed oil
Rape seed oil fatty acid methyl esters
Rice bran oil
Rosin
Safflower oil
Shea butter
Sodium alkyl (C14-C17) sulphonates (60-65% solution)
Sodium aluminosilicate slurry
Sodium benzoate
Sodium borohydride (15% or less)/Sodium hydroxide solution
Sodium carbonate solution
Sodium chlorate solution (50% or less)
Sodium dichromate solution (70% or less)
Sodium hydrogen sulphide (6% or less)/Sodium
carbonate (3% or less) solution
Sodium hydrogen sulphite solution (45% or less)
Sodium hydrosulphide/Ammonium sulphide solution
Sodium hydrosulphide solution (45% or less)
Sodium hydroxide solution
Sodium hypochlorite solution (15% or less)
Sodium nitrite solution
Sodium petroleum sulphonate
Sodium poly(4+)acrylate solutions
Sodium silicate solution
Sodium sulphide solution (15% or less)
Sodium sulphite solution (25% or less)
Sodium thiocyanate solution (56% or less)
Soyabean oil
Styrene monomer
Sulphohydrocarbon (C3-C88)
Sulpholane
Sulphonated polyacrylate solution
Sulphur (molten)
Sulphuric acid
Sulphuric acid, spent
Sulphurized fat (C14-C20)
Sulphurized polyolefinamide alkene (C28-C250) amine
Sunflower seed oil
Tall oil, crude
INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Z
Y
Z
Z
Z
Y
X
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Z
Z
Y
Z
Z
Y
3
2
3
3
2
3
3
3
2
3
3
2
3
3
3
3
2
2
2
2
2
2 (k)
2
2 (k)
2
2 (k)
2 (k)
2
3
3
3
3
3
2
C
C
C
C
D
C
D
C
C
D
III
C
A
D
D
D
C
B
B
D
B
D
D
D
B
D
D
B
III
D
D
D
III
C
3
3
3
3
2
3
3
3
2
n/a
n/a
2
3
n/a
n/a
n/a
2
3
3
3
3
n/a
n/a
n/a
3
n/a
n/a
3
n/a
n/a
3
n/a
3
2
Z
Z
Y
Z
Y
Y
Y
Y
Z
Y
Y
Y
Y
Y
Y
Y
Y
Z
Z
Y
Y
Z
Z
Y
Y
3
3
2
3
3
2
2
2
3
3
3
3
3
2 (k)
3
2
3
3
3
3
3
3
3
2 (k)
2
B
D
B
B
D
C
B
B
III
C
B
C
B
D
B
D
D
D
III
C
C
D
D
D
B
3
3
2
3
3
3
2
2
n/a
3
3
3
3
n/a
3
n/a
n/a
n/a
3
3
3
n/a
n/a
n/a
3
November 2006
27
Tall oil, distilled
Tall oil fatty acid (resin acids less than 20%)
Tall oil pitch
Tallow
Tallow fatty acid
Tetrachloroethane
Tetraethylene glycol
Tetraethylene pentamine
Tetrahydrofuran
Tetrahydronaphthalene
Tetramethylbenzene (all isomers)
Titanium dioxide slurry
Toluene
Toluenediamine
Toluene diisocyanate
o-Toluidine
Tributyl phosphate
1,2,3-Trichlorobenzene (molten)
1,2,4-Trichlorobenzene
1, 1, 1 -Trichloroethane
1,1,2-Trichloroethane
Trichloroethylene
1,2,3-Trichloropropane
1,1,2-Trichloro-1,2,2-Trifluoroethane
Tricresyl phosphate (containing less than 1% ortho-isomer)
Tridecane
Tridecanoic acid
Tridecyl acetate
Triethanolamine
Triethylamine
Triethylbenzene
Triethylenetetramine
Triethyl phosphate
Triethylphosphite
Triisopropanolamine
Triisopropylated phenyl phosphates
Trimethylacetic acid
Trimethylamine solution (30% or less)
Trimethylbenzene (all isomers)
Trimethylol propane propoxylated
2,2,4-Trimethyl-1,3-pentanediol diisobutyrate
2,2,4-Trimethyl-1,3-pentanediol-1 -isobutyrate
1,3,5-Trioxane
Tripropylene glycol
Trixylyl phosphate
Tung oil
Turpentine
Undecanoic acid
1-Undecene
Undecyl alcohol
Urea/Ammonium nitrate solution
Urea/Ammonium nitrate solution (containing less than 1% free ammonia)
Urea/Ammonium phosphate solution
Urea solution
Valeraldehyde (all isomers)
Vegetable acid oils (m)
Vegetable fatty acids distillates(m)
Vinyl acetate
Vinyl ethyl ether
Vinylidene chloride
28
November 2006
Y
Y
Y
Y
Y
Y
Z
Y
Z
Y
X
Z
Y
Y
Y
Y
Y
X
X
Y
Y
Y
Y
Y
Y
Y
Y
Z
Z
Y
X
Y
Z
Z
Z
X
Y
Z
X
Z
Z
Y
Y
Z
X
Y
X
Y
X
X
Z
Z
Y
Z
Y
Y
Y
Y
Z
Y
2
2
2
2 (k)
2
2
3
2
3
2
2
3
3
2
2
2
3
1
1
3
3
2
2
2
2
2
2
3
3
2
2
2
3
3
3
2
2
2
2
3
3
2
3
3
2
2 (k)
2
2
2
2
3
3
2
3
3
2
2
3
2
2
B
C
3
3
D
D
B
III
D
D
C
A
III
C
C
C
C
B
A
B
C
C
C
C
C
A
III
B
III
D
C
A
D
B
B
III
A
D
C
A
n/a
n/a
3
n/a
3
3
3
3
n/a
3
2
2
2
3
1
2
3
3
3
2
3
2
n/a
3
n/a
3
2
2
3
2
3
n/a
2
3
2
3
III
C
D
III
A
D
B
B
B
B
D
C
III
III
C
D
III
C
C
D
n/a
3
3
n/a
1
n/a
3
3
3
3
n/a
3
n/a
n/a
3
n/a
n/a
3
2
2
INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide
Vinyl neodecanoate
Vinyltoluene
Waxes
White spirit, low (15-20%) aromatic
Xylenes
Xylenes/ethylbenzene (10% or more) mixture
Xylenol
Zinc alkaryl dithiophosphate (C7-C16)
Zinc alkenyl carboxamide
Zinc alkyl dithiophosphate (C3-C14)
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
2
2
2
2
2
2
2
2
2
2
B
A
D
B
C
B
B
C
D
B
3
3
n/a
2
3
3
3
3
n/a
3
Chapter 18 – as amended by MEPC 52 and the MSC 79 – reflects products listed in MEPC 55 wp.8 as amended
CHAPTER 18
Pollution Category Ship Type
Acetone
Z
NA
Alcoholic beverages, n.o.s.
Z
NA
Apple juice
OS
NA
n-Butyl alcohol
Z
NA
sec-Butyl alcohol
Z
NA
Calcium nitrate solutions (50% or less)
Z
NA
Clay slurry
OS
NA
Coal slurry
OS
NA
Diethylene glycol
Z
NA
Ethyl alcohol
Z
NA
Ethylene carbonate
Z
NA
Glucose solution
OS
NA
Glycerine
Z
NA
Glycerol monooleate
Z
NA
Hexamethylenetetramine solutions
Z
NA
Hexylene glycol
Z
NA
Hydrogenated Starch Hydrolysate
OS
NA
Isopropyl alcohol
Z
NA
Kaolin slurry
OS
NA
Lecithin
OS
NA
Magnesium hydroxide slurry
Z
NA
Maltitol Solution
OS
NA
N-Methylglucamine solution (70% or less)
Z
NA
Methyl propyl ketone
Z
NA
Molasses
OS
NA
Noxious liquid, (11) n.o.s. (trade name ...., contains ....) Cat. Z
Z
NA
Non-noxious liquid, (12) n.o.s. (trade name ...., contains ....) Cat. OS
OS
NA
Polyaluminium chloride solution
Z
NA
Polyglycerin, sodium salt solution (containing less than 3% sodium hydroxide)
Z
NA
Potassium formate solutions
Z
NA
Propylene carbonate
Z
NA
Propylene glycol
Z
NA
Sodium acetate solutions
Z
NA
Sodium sulphate solutions
Z
NA
Sorbitol solution
OS
NA
Sulphonated polyacrylate solution
Z
NA
Tetraethyl silicate monomer/oligomer (20% in ethanol)
Z
NA
Triethylene glycol
Z
NA
Vegetable protein solution (hydrolysed)
OS
NA
Water
OS
NA
INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide
November 2006
29
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
30
November 2006
INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide
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
N
1. The port state of the shipper.
N
2. The flag state of the carrier
N
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
INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide
November 2006
31
& 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.
N
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 submitted
to the IMO for inclusion in the IBC Code; or where there is no expiration date, they are candidates for the next formal
amendment of the Code and will be included in the Code at the next publication.
N
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.
N
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.
N
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.
32
November 2006
INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide
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.
INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide
November 2006
33
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)
34
November 2006
INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide
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?”
N
“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”.
N
“We do not report the lack of reception facilities as we doubt anything would be done – this also applies to Annex
I facilities”.
INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide
November 2006
35
N
“Reporting contact details are not readily available”
N
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.
N
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:
N
“Most reception barges (other than cargo charterers, receiver’s facility) are not concerned by categories”.
N
“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:
N
“Detailed reception conditions must also be described: barge, pipe, which berth, when, availability receiving rate &
quantity, cost, etc”.
N
“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”.
N
“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”)
36
November 2006
INTERTANKO: The Revisions to MARPOL Annex II – A Practical Guide
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:
N
“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) “
N
“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”.
N
“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)”
N
“On the condition that the reception facilities also accept trade names”
N
“This may also be beneficial to vessels needing to discharge materials”.
N
“It’s important that the “Viscosity” according to temperature is clearly made available in the GISIS system”.
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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:
N
Existing product tankers carrying IBC Code Chapter 18 cargoes
These ships will be able to carry the cargoes left in the revised Chapter 18.
N
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.
N
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.
N
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…..":
N
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).
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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 MTPNO880@dnv.com 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 jonathan.morley@lr.org, who is
the Head of the MARPOL Group in Lloyd's Register, London.
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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.
N
Biofuel is derived from "biomass" - recently living organisms or their metabolic by-products, such as waste streams
(agricultural, domestic or municipal).
N
It is a renewable energy, unlike other natural resources such as petroleum, coal and nuclear fuels.
N
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.
N
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
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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:
N
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.
N
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.
N
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.
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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.
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Outside back cover image courtesy Odfjell ASA.