ipta regulatory update
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Regulatory UpdateJanet Strode
General Manager
International Parcel Tankers Association
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Founded 1987
Attained consultative status at IMO 1997 Project leader on IMO Workshops worldwide on MARPOL
Annex II
Cooperation with USCG and European Commission
EQUASIS Editorial Board
24 years on FOSFA Oils and Fats and Technical Committees
Setting up of CDI
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Application of inert gas to chemicaltankers
Damage Stability for Tankers
Review of chapters 17 and 18 of the IBC
Code
Carriage of Biofuel Blends
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APPLICATION
OF INERT GAS
TO CHEMICAL
TANKERS AND
SMALLER OIL
TANKERS
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FP 53 - 2009
recognized that the fitting of appropriate inert gas systemsto NEW oil tankers below 20,000 dwt and NEW chemical
tankers carrying low-flash cargoes would minimize the risk of
fires and explosions
. benefits of such fitting should outweigh any negative
effects of the introduction of IG systems, such as
increased fuel consumption
increased CO2 emissions
increased building costs increased complexity of procedures
possible increase of the risk associated with tank entries
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FP 54 April 2010
Joint ICS/IPTA paper with information onoperational issues
Proposes separate operational requirements for the
application of inert gas to chemical tankers
Sub-Committee agrees that where vessel is carrying
IBC Code cargoes, can have option of applying
nitrogen either on completion of loading orimmediately prior to discharge
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Lower size limit
8,000 DWT
Japan, China, Brazil, Singapore, Panama and Turkey
500 GRT
Bahamas, Norway, EU States, Intertanko, OCIMF
IPTA and ICS: seems that problems occur below 5,000 DWT,
and therefore would not support any thing below 5,000 DWT
Proponents of 500 grt eventually agree to compromise on
5,000 DWT
FP 55 to decide on lower size, based on range between 5,000
DWT and 8,000 DWT
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BLG 15 Reminds FP that some cargoes have oxygen-
dependent inhibitors
Concludes that column h of chapter 17 of the IBC
Code not appropriate for incorporating future SOLAS
inert gas requirements for new ships,
Took note that the review of Resolution A864(20) -
Recommendations for Entry into Enclosed Spaces
Aboard Ships had been completed and finalised aspecific footnote addressing entry into cargo spaces
on all tankers subject to inerting with nitrogen
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Damage Stability ofTankers
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MSC 83 (2007)
Denmark, Finland, Germany, Norway, Sweden, UK andIntertanko propose new work programme item on
damage stability of tankers
Taken in conjunction with the low margins of stability
often exhibited by the standard loading conditions in
approved stability information for tank vessels, there is a
probability that these ships are regularly operating in
loading conditions with reduced or zero levels of residual
stability, even where these loading conditions appear to
be closely related to a standard loading condition
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SLF 52 - 2010
UK - survey of 73 oil, chemical and gas tankersentering and leaving UK ports
non-compliance =
variation of more than 1% by weight in any cargoor ballast tank from conditions outlined in the
stability book
vessel not verifying that the damage stabilityrequirements were still being complied with
23 vessels not compliant
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over one third of tank ships regularly sail in conditions of
loading significantly different from those in the approved
stability information
This poses an unacceptable risk to life at sea and to the
environment and enforcement action is justified under
the existing instruments which apply to these vessels
Sub-Committee concludes that there is some ambiguity in
regulations
Agrees that guidelines should be developed for verification of
damage stability at
initial approval stage
onboard prior to sailing
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SLF 53 January 2011agrees that further discussion needed and sets up
Correspondence Group that will report back to SLF 54 in 2012
Guidance also needed for Port State Control
clarification of loaded in accordance with an approved condition
Are deviations allowed and, if so, to what extent?
methods of verification of compliance,
stability software,
KG/GM curves
shore assistance
clarification of the terms and conditions for use of stability software
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Paris MOU CIC
1 September 2010 to 30 November 2010
1065 tankers inspected in order to check:
Vessel loaded in accordance with Stability book?
If not, have checks been carried out to ensure the loaded
condition complies with damage stability regulations?
A significant number of tankers could pose a
risk to the environment
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94 (8.8%) inspections resulted in deficiencies
2 oil tankers and 2 chemical tankers detained
77 oil tankers, 84 chemical tankers and 12 gas
tankers (16.2% of total) could not demonstrate that
they were normally loaded in accordance with theStability Book
detailed results to be reviewed Port State Control
Committee in May and report to be submitted to the
IMO
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REVIEW OFCHAPTERS
17 AND 18OF THE IBC
CODE
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Changes to GESAMPhazard profiles
2007 amendmentsapplied on pollutiongrounds only
New criteria forassigning carriage
requirements appliedto new products only
Dual
standardproduct list
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Tank type 2G = Integral tank
forms part of ships hull and may be stressed in insame manner and by same forces which stress the
ships hull structure
Tank type 1G = Independent tank
not contiguous with, or part of , the hull structure.
An independent tank is built and installed so as to
eliminate whenever possible (or in any event tominimize) its stressing as a result of stressing or
motion of the adjacent hull structure
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Representative sample of 10
products examined to establishwhich criteria trigger particular
requirements
Dermal toxicity triggersenhanced ship type and/or
tank type
Inhalation toxicity triggers
enhanced standards forventing, gauging and
vapour detection
Long term effects couldalso trigger similar
requirements
BLG 15
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Possible action:
Full review of carriage requirements
Allowing period for updating of data by industry
Partial review, based on worst case anomalies
Revisit chapter 21 of the IBC Code
ESPH 17 (October 2011) to consider further
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Carriage of Biofuel Blends
Fatty acid methylesters (FAME)
Vegetable oil
Bio-ethanol
Renewable Diesel
Biofuel
Diesel
Gasoil
Gasoline
Petroleum
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Draft Guidelines for the Carriage of Blends
of Biofuel and Petroleum
(agreed at BLG 15 in February 2011)
75% or more petroleum oil
Product subject to MARPOL Annex I
ODME to be in compliance with regulation 31 of Annex I of
MARPOL and approved for the mixture being transported
Until 1 January 2016 bio-fuel blends may be carried when theship's ODME is not approved, provided that tank residues and
all tank washings are pumped ashore
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More than 1% but less than 75% petroleum oil
Product subject to MARPOL Annex II
Pollution Category X, Ship Type 2
carriage requirements based on the generic entry
defined for the biofuel blend concerned
Generic carriage requirements will be incorporated
into List 1 of the MEPC.2/Circular
1% or less Petroleum oil
Product to be treated as the Annex II product
in the blend
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a c d e f g h i i i j k l n o
Blends of Diesel/gasoil and
FAME
(>25% but25% but25% but 60oC
(>25% but 25% but
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Draft Guidelines still to be formally adopted
by the Maritime Safety Committee and
Marine Environment Protection Committee
In the meantime the interim guidance has
been extended to 1 September this year
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Biofuel Blends in MEPC.2/Circ.16
List 2 Alcoline (Greenergy)
Etamax (SEKAB)
List 3 E85 VSS (Vertical)
E85 VWS (Vertical)
E90 (Fuelstreamers) E90 (Shell)
NOS 8
Pollution category Y
Ship Type 3
Pollution category X
Ship Type 2
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Blending on board :
the mixing of two products resulting in one singleproduct
reflects only physical mixing as distinct from any
chemical processing
Blending operations only to be undertaken within
port limits
Blending on board during a sea voyage to createnew products is prohibited (See MSC-
MEPC.2/Circ.8)
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Blending at Sea MSC-MEPC.2/Circ.8
The MSC and the MEPC noted that there were concerns that the practice ofthe physical blending of MARPOL regulated cargoes on board during thesea voyage for the purposes of creating new product blends presents clearhazards for the safety of the ship and protection of the marineenvironment. Having considered the proposal by the BLG Sub-Committeethe Committees agreed that such practices should be prohibited and that
mandatory provisions should be developed in that respect under theauspices of both Committees.
Until the matter can be further discussed in detail by the BLG Sub-Committee and approved by the Maritime Safety Committee and theMarine Environment Protection Committee,physical blending refers to theprocess whereby the ships cargo pumps and pipelines are used to internally
circulate two or more different cargoes within the ship with the intent toachieve a cargo with a different product designation. This circular does notpreclude the master from undertaking cargo transfers for the safety of theship or protection of the marine environment.
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DRAFT REGULATION 5-2 OF
SOLAS CHAPTER VI
PROHIBITION OF THE BLENDING OF BULK LIQUIDCARGOES DURING THE SEA VOYAGE
The physical blending of bulk liquid cargoes during the seavoyage is prohibited. Physical blending refers to the process
whereby the ship's cargo pumps and pipelines are used tointernally circulate two or more different cargoes with the intentto achieve a cargo with a new product designation. Thisprohibition does not preclude the Master from undertakingcargo transfers for the safety of the ship or protection of themarine environment. The prohibition does not apply to the
blending of products for use in the search and exploitation ofsea-bed mineral resources on board ships used to facilitate suchoperations.
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Thank you for your attention
The internationally recognised Non-Governmental Organisationdedicated to serving the needs of the IMO classified chemical
and product tanker fleets
www.ipta.org.uk
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http://www.ipta.org.uk/http://www.ipta.org.uk/