MARPOL Annex II – a new regime for the carriage of bulk

chemicals and vegetable oils

Stefan Stefan MicallefMicallefMarine Environment Division Marine Environment Division

International Maritime OrganizationInternational Maritime Organization

Regulations for the protection of the marine environment from Noxious LiquidSubstances (NLS) – two main instruments

MARPOL MARPOL AnnexAnnex II II –– preventionprevention ofofpollutionpollution

SubstancesSubstances divideddivided intointo categoriescategories accordingaccording toto thethe levellevel ofofthreatthreat theythey pose pose toto thethe marine marine environmentenvironmentConditionsConditions laidlaid downdown underunder whichwhich dischargedischarge intointo thethe sea can sea can taketake placeplace

IBC IBC CodeCode –– SafetySafetyPresribesPresribes designdesign andand constructionconstruction standardsstandards forfor shipsshipsDefinitiveDefinitive sourcesource ofof thethe namesnames ofof productsproducts thatthat havehave beenbeenevalautedevalauted forfor thethe carriagecarriage by seaby sea

What are noxious liquid substances?

Can be any bulk liquid that does not meet the Can be any bulk liquid that does not meet the definition for oil as defined in MARPOL definition for oil as defined in MARPOL Annex IAnnex IMight include, inter alia:Might include, inter alia:

––petrochemicals petrochemicals ––solvents solvents ––waxes waxes ––lube oil additives lube oil additives ––vegetable oils and animal fats vegetable oils and animal fats

Regulations of Noxious Liquid Substances(NLS) – two main instruments

MARPOL MARPOL AnnexAnnex II II –– preventionprevention ofofpollutionpollution

SubstancesSubstances divideddivided intointo categoriescategories accordingaccording toto thethe levellevel ofofthreatthreat theythey pose pose toto thethe marine marine environmentenvironmentConditionsConditions laidlaid downdown underunder whichwhich dischargedischarge intointo thethe sea can sea can taketake placeplace

IBC IBC CodeCode –– SafetySafetyPresribesPresribes designdesign andand constructionconstruction standardsstandards forfor shipsshipsDefinitiveDefinitive sourcesource ofof thethe namesnames ofof productsproducts thatthat havehave beenbeenevalautedevalauted forfor thethe carriagecarriage by seaby sea

MARPOL Annex IISubstances divided into pollution categories according to Substances divided into pollution categories according to the level of threat they pose the environment the level of threat they pose the environment Conditions established for each pollution category under Conditions established for each pollution category under which discharge into sea is permittedwhich discharge into sea is permitted““Stripping LimitsStripping Limits”” defined for each pollution categorydefined for each pollution categoryProcedures and Arrangements (P and A) ManualsProcedures and Arrangements (P and A) ManualsCargo record bookCargo record bookEntered into force 6 April 1987Entered into force 6 April 1987

HOWEVER……?

By the time of entry into force the By the time of entry into force the provisions of Annex II were already provisions of Annex II were already 14 years old14 years old…………..

………….soon recognised that the document was .soon recognised that the document was rather unwieldyrather unwieldy

………….suggestions that editorial revision .suggestions that editorial revision necessary in order to make document more necessary in order to make document more useruser--friendlyfriendly

Technological Advances

Developments in pump design and technology Developments in pump design and technology made it possible to consider much stricter made it possible to consider much stricter controls on the amount of residues that can be controls on the amount of residues that can be discharged into the marine environment discharged into the marine environment (stripping limits)(stripping limits)

Advances in knowledge on marine pollution Advances in knowledge on marine pollution meant that it was becoming clear that meant that it was becoming clear that properties not previously considered in the properties not previously considered in the categorization of products should be given categorization of products should be given more weight while others were perhaps not so more weight while others were perhaps not so important as had been thoughtimportant as had been thought

Changing Attitudes

Public expectations in terms of:Public expectations in terms of:

Protection of ecosystemsProtection of ecosystems

Provision of healthy, Provision of healthy, uncontaminated fooduncontaminated food

Clean seas for recreational Clean seas for recreational purposespurposes

Exacerbated by incidents of Exacerbated by incidents of lypophiliclypophilic substances washing up on substances washing up on beaches and oiling sea birdsbeaches and oiling sea birds

The revised MARPOL Annex II was The revised MARPOL Annex II was adopted by resolution MEPC.118(52) in adopted by resolution MEPC.118(52) in October 2004October 2004The amended IBC Code was adopted by The amended IBC Code was adopted by resolution MEPC.119(52) in October 2004 resolution MEPC.119(52) in October 2004 and MSC.176(79) in December 2004and MSC.176(79) in December 2004Both entered into force on 01 January Both entered into force on 01 January 20072007

WHAT IS MARPOL Annex II ?Aimed at pollution created as a result of shipAimed at pollution created as a result of ship’’s operational s operational practices and covers the pollution and operational disposal practices and covers the pollution and operational disposal of Noxious liquid substancesof Noxious liquid substancesApplicable to Applicable to all vesselsall vessels irrespective of date of build or irrespective of date of build or size carrying cargoes listed in chapter 17, 18 of the IBC size carrying cargoes listed in chapter 17, 18 of the IBC Code which have been given the pollution category X, Y, ZCode which have been given the pollution category X, Y, ZNoxious liquid substances are divided into Noxious liquid substances are divided into pollution pollution categoriescategories (X, Y, Z)(X, Y, Z) according to the level of threat they according to the level of threat they pose the environmentpose the environmentConditions established for each pollution categoryConditions established for each pollution categoryunder which discharge into sea is permittedunder which discharge into sea is permitted““Stripping LimitsStripping Limits”” defined for each pollution categorydefined for each pollution categoryProcedures and Arrangements (P and A) ManualsProcedures and Arrangements (P and A) ManualsCargo record bookCargo record book

ALL VESSELS – WHAT SHIPS?

AllAll shipsships carryingcarrying bulkbulk NLS NLS oror thosethose provisional provisional assessedassessed underunder TripartiteTripartite agreementsagreementsAllAll chemicalchemical tankerstankers carryingcarrying dangerousdangeroussubstancessubstances in in bulkbulkLiquidLiquid PetroleumPetroleum Gas Gas TankersTankers carryingcarrying hazardoushazardousin in bulkbulkAllAll oil oil tankerstankers carryingcarrying pollutionpollution hazardoushazardoussubstancessubstances in in bulkbulk

Substances are divided into pollution categories according to the level of threat they pose the environment

Pollution Categorization SystemPollution Categorization SystemCategory XCategory X

Major Hazard Major Hazard –– prohibition of discharge into the prohibition of discharge into the environmentenvironmentCategory YCategory Y

Hazard Hazard –– limitation on quality and quantity of discharge limitation on quality and quantity of discharge into environmentinto environmentCategory ZCategory Z

Minor hazard Minor hazard –– less stringent restrictions on quality and less stringent restrictions on quality and quantity of dischargequantity of dischargeOther Substances (OS)Other Substances (OS)

Present no harm and not subject to any of the Present no harm and not subject to any of the requirements of the Annexrequirements of the Annex

H

A

Z

A

R

D

Conditions established for each PC under which discharge into the sea is permitted

XX All PrewashAll Prewash.. Subsequent washings to be discharged under same Subsequent washings to be discharged under same conditions as Cat Y.conditions as Cat Y.

YYHigh viscosity and Solidifying SubstancesHigh viscosity and Solidifying Substances Prewash,Prewash, the rest the rest efficient strippingefficient strippingProceeding en route at 7 knotsProceeding en route at 7 knots; ; At least 12 miles from landAt least 12 miles from land; ; Depth of at least 25 mDepth of at least 25 m; ; Discharge below waterline Discharge below waterline

ZZAll efficient strippingAll efficient strippingProceeding en route at 7 knotsProceeding en route at 7 knots; ; At least 12 miles from landAt least 12 miles from landDepth of at least 25 mDepth of at least 25 m; ; New Ships: Discharge below waterlineNew Ships: Discharge below waterline

H

A

Z

A

R

D

Stripping Limits” defined for each pollution category

New ShipsNew Ships Existing IBCExisting IBC Existing Existing BCHBCH Other ShipsOther Ships

XX 75 litres + 75 litres + prewashprewash

1100 00 litreslitres + 50+ 50litreslitrestolerancetolerance + + prewashprewash

1100 00 litreslitres + + 5050 litreslitrestolerancetolerance + + prewashprewash

No carriageNo carriage

YY 75 litres75 litres 100 100 litreslitres + 50 + 50 litreslitres tolerance tolerance

3300 00 litreslitres + + 50 50 litreslitrestolerancetolerance

No carriageNo carriage

ZZ 75 litres75 litres 3300 00 litreslitres + 50 + 50 litreslitres tolerance tolerance

9900 00 litreslitres + + 50 50 litreslitrestolerance tolerance

New ShipsNew Ships: 75 : 75 litreslitresExisting ShipsExisting Ships: : empty tanks to the empty tanks to the most most practicable practicable extentextent

OSOS UnrestrictedUnrestricted UnrestrictedUnrestricted UnrestrictedUnrestricted UnrestrictedUnrestricted

More on MARPOL Annex IIVessels must comply fully with parts of the Annex Vessels must comply fully with parts of the Annex applicable to the Category of the pollutant carried:applicable to the Category of the pollutant carried:

Underwater discharge outlet (X, Y, Z Underwater discharge outlet (X, Y, Z –– dependant dependant on date of build)on date of build)Stripping Test (X, Y, Z.)Stripping Test (X, Y, Z.)Approved procedures and arrangements manual (X, Approved procedures and arrangements manual (X, Y, Z)Y, Z)Cargo record book (X, Y, Z)Cargo record book (X, Y, Z)Shipboard marine pollution emergency plan (X, Y, Shipboard marine pollution emergency plan (X, Y, Z)Z)

Ventilation of cargo residuesVentilation of cargo residuesUse of cleaning agents/additivesUse of cleaning agents/additivesSpecial areasSpecial areasSlop tanks Slop tanks

Summary Entered into force 1 January 2007Entered into force 1 January 2007Editorial revision making it simpler to useEditorial revision making it simpler to useDevelopment of a new 4Development of a new 4--pollution categories and pollution categories and criteria for assigning products to these criteriacriteria for assigning products to these criteriaRevised conditions for each pollution category Revised conditions for each pollution category under which discharge into sea is permittedunder which discharge into sea is permittedDefined stripping requirements for new ships Defined stripping requirements for new ships ––75 litres75 litresConsequential amendments to the IBC code, Consequential amendments to the IBC code, in particular the criteria for ship typingin particular the criteria for ship typing

IBC CodeInternational standard for the safe carriage by sea International standard for the safe carriage by sea in bulk of dangerous and noxious liquid substancesin bulk of dangerous and noxious liquid substances

Mandatory under both SOLAS and MARPOLMandatory under both SOLAS and MARPOL

Defines the construction and equipment of ship Defines the construction and equipment of ship carrying Dangerous Chemicals in Bulkcarrying Dangerous Chemicals in Bulk

Divided into 21 chaptersDivided into 21 chapters

•• Applies to Applies to ““ships, regardless of size, including those ships, regardless of size, including those of less than 500 of less than 500 gtgt, engaged in the carriage of bulk , engaged in the carriage of bulk cargoes of dangerous chemicals or noxious liquid cargoes of dangerous chemicals or noxious liquid substances (NLS), other than petroleumsubstances (NLS), other than petroleum…”…”

IBC CODE

Contains a set of basic requirements (19) all of which must Contains a set of basic requirements (19) all of which must be satisfied to some degree and a set of be satisfied to some degree and a set of ““Special Special RequirementsRequirements”” which are complied with at the Owners which are complied with at the Owners discretion.discretion.Compliance with the lowest level of the basic requirements Compliance with the lowest level of the basic requirements will result in a vessel being restricted to carrying a few will result in a vessel being restricted to carrying a few NLSNLSBy increasing the level of compliance and by complying By increasing the level of compliance and by complying with some of the with some of the ““Special |RequirementsSpecial |Requirements”” the cargo list the cargo list can be expended until at the highest level of compliance, can be expended until at the highest level of compliance, all cargoes can be carriedall cargoes can be carried

Ship Type 1

Ship Type 2

Ship Type 3

BIGGER TANKS

MORE PROTECTION

Each tanker is assigned a ship Each tanker is assigned a ship type according to the degree of type according to the degree of hazards of the products to be hazards of the products to be carried carried

Chapter 17 of the Code lists those Chapter 17 of the Code lists those products which are subject to the products which are subject to the Code, together with carriage Code, together with carriage requirementsrequirements

Chapter 18 contains products Chapter 18 contains products which have been evaluated and which have been evaluated and found not to present significant found not to present significant safety or pollution hazardssafety or pollution hazards

Chapter 18 Chapter 18 Type 3 Type 2Type 3 Type 2

AcetoneAcetoneEthyl acetate Ethyl acetate Ethyl alcohol Ethyl alcohol Ethylene glycolEthylene glycolFatty acidsFatty acidsHexanolHexanolMethyl alcohol Methyl alcohol Methyl ethyl Methyl ethyl ketoneketoneMethyl isobutyl Methyl isobutyl ketoneketoneMTBEMTBEParaffin WaxParaffin WaxUrea/Ammonium Urea/Ammonium

Nitrate SolutionNitrate SolutionVegetable oils

Ethyl acetateEthyl acetate

Ethylene GlycolEthylene Glycol

HexanolHexanolMethyl alcoholMethyl alcoholMethyl ethyl Methyl ethyl ketoneketoneMethyl isobutyl Methyl isobutyl ketoneketoneMTBEMTBE

Urea Ammonium Urea Ammonium Nitrate solution

Fatty acidsFatty acids

Paraffin waxParaffin wax

Vegetable oilsNitrate solutionVegetable oils Vegetable oils

SummaryEntered into Force 01 January 2007Entered into Force 01 January 200744--Category system rather than 5Category system rather than 5--CategoryCategoryNumber of cargoes not subject to discharge Number of cargoes not subject to discharge requirements reduced from 115 to a handfulrequirements reduced from 115 to a handfulNew ships must strip to 75 litresNew ships must strip to 75 litresNeed for special areas (other than Antarctic) Need for special areas (other than Antarctic) eliminatedeliminatedFar greater number of products require carriage in Far greater number of products require carriage in chemical tankers than in the past provisionschemical tankers than in the past provisionsNo longer provision for oilNo longer provision for oil--like substances to be carried like substances to be carried on vessels other than chemical tankerson vessels other than chemical tankersName appearing in the IBC Code is the name that must Name appearing in the IBC Code is the name that must be used in documentationbe used in documentation

Carriage ofvegetable oils

MARRPOL Annex II

And

IBC Code

Products used to be Products used to be listed in Chapter 18 of listed in Chapter 18 of the IBC Code as generic the IBC Code as generic entries and not as entries and not as individual products individual products

Full data did not need to Full data did not need to be providedbe provided

All vegetable oils and animal All vegetable oils and animal fats evaluated have resulted fats evaluated have resulted in an assignment of in an assignment of Pollution Category Y and Pollution Category Y and Ship type 2Ship type 2

HOWEVER, Ship Type 3 vessels will HOWEVER, Ship Type 3 vessels will be allowed to carry vegetable oils be allowed to carry vegetable oils providing they have double bottom and providing they have double bottom and double sides and satisfy the operational double sides and satisfy the operational criteria criteria –– Regulation 4.1.3 of Regulation 4.1.3 of MARPOL Annex IIMARPOL Annex II

Oleochemicals

Pollution Category YPollution Category Y

Ship Type 2 Ship Type 2

Therefore not eligible Therefore not eligible for carriage under for carriage under regulation 4.1.3regulation 4.1.3

BIODIESELBIODIESEL

Fatty Acid Methyl Fatty Acid Methyl Esters(mEsters(m))

Palm oil Fatty Acid Methyl Palm oil Fatty Acid Methyl EsterEsterCoconut Oil Fatty Acid Methyl Coconut Oil Fatty Acid Methyl EsterEsterRapeseed Oil Fatty Acid Methyl Rapeseed Oil Fatty Acid Methyl EsterEster

((m)Fromm)From vegetable oils specified in the IBC Codevegetable oils specified in the IBC Code

Biofuel Blends (first generation)

BiodieselBiodiesel blended with blended with mineral dieselmineral diesel

BioBio--alchoholalchohol blended with blended with gasoline (gasohol)gasoline (gasohol)

PROPOSED GUIDANCE FOR CARRIAGE OF BIOFUEL BLENDS CONSIDERED BY IMO (shipper shipper should contact his Administration for a decision on how should contact his Administration for a decision on how the product is to be carried the product is to be carried )

11 If the proportion of If the proportion of bioalcoholbioalcohol or or biodieselbiodiesel in the blend in the blend does not exceed 15% then carry it under MARPOL does not exceed 15% then carry it under MARPOL Annex IAnnex I

2.2. If the proportion of If the proportion of bioalcoholbioalcohol or biodiesel in the blend or biodiesel in the blend exceeds 15% then the shipper should contact his exceeds 15% then the shipper should contact his Administration for a decision on how the product is to be Administration for a decision on how the product is to be carriedcarried..

IMO´ RESPONSE TO THE ISSUE OF BIOFUELS/BIOFUEL BLENDS

1.1. IMOIMO´́ss MEPC 55 agreed to add a new item to the work MEPC 55 agreed to add a new item to the work programme of the BLG Subprogramme of the BLG Sub--Committee to deal with the Committee to deal with the carriage of biofuels and biofuel blendscarriage of biofuels and biofuel blends

2.2. IMOIMO´́ss BLG SubBLG Sub--Committee identified another issue that Committee identified another issue that needs addressing within the context of needs addressing within the context of biofuelsbiofuels i.ei.erenewable diesel oil (second generation renewable diesel oil (second generation biofuelsbiofuels))

Responsibilities of Port States

Revised Annex II to MARPOL 73/78 Revised Annex II to MARPOL 73/78 and Amended IBC Codeand Amended IBC Code

RECEPTION FACILITIESRECEPTION FACILITIES

Regional ArrangementsGuidelinesGuidelines for Ensuring the Adequacy of Port for Ensuring the Adequacy of Port Reception Facilities (Resolution MEPC.83(44)Reception Facilities (Resolution MEPC.83(44)

Port State ControlPort State Control

Questions?Questions?