marpol annex ii revisions intertanko seminar houston, tx 15 march 2006

MARPOL Annex II Revisions MARPOL Annex II Revisions INTERTANKO SeminarINTERTANKO Seminar

Houston, TX Houston, TX

15 March 2006 15 March 2006

AGENDA AGENDA

Annex II Revisions Deadline Remains!Annex II Revisions Deadline Remains! IMO Ship Type Reviewed IMO Ship Type Reviewed Products Still Missing DataProducts Still Missing Data Practical Implications of the Revisions Practical Implications of the Revisions Biofuels and the RevisionsBiofuels and the Revisions IMO 2006 Schedule IMO 2006 Schedule Conclusions and PredictionsConclusions and Predictions

MARPOL Annex II MARPOL Annex II RevisionsRevisions

The long-time ongoing revision work The long-time ongoing revision work on MARPOL Annex II and the on MARPOL Annex II and the Chemical Carrier Code concluded Chemical Carrier Code concluded with the adoption of the revised with the adoption of the revised MARPOL Annex II by MEPC 52 (in MARPOL Annex II by MEPC 52 (in October 2004) and the adoption of October 2004) and the adoption of the revised IBC Code by both MEPC the revised IBC Code by both MEPC 52 and MSC 79 (in December 2004). 52 and MSC 79 (in December 2004).

The revised requirements The revised requirements WILLWILL enter into force and take effect from enter into force and take effect from 1 January 2007.1 January 2007.

Re-categorisation of the existing Re-categorisation of the existing pollution categories within MARPOL pollution categories within MARPOL Annex II has been a longstanding Annex II has been a longstanding issue at IMOissue at IMO

Currently there exist 5 categories A, Currently there exist 5 categories A, B, C, D and an Appendix III. (Appendix B, C, D and an Appendix III. (Appendix III lists products to which the IBC III lists products to which the IBC Code does not apply). Code does not apply).

Due to the re-evaluation process of Due to the re-evaluation process of the existing MARPOL Annex II the existing MARPOL Annex II products by GESAMP/EHS, existing products by GESAMP/EHS, existing products will be re-categorised into a products will be re-categorised into a new “3 plus 1” category systemnew “3 plus 1” category system

MARPOL Annex II RevisionsMARPOL Annex II Revisions


The revision of Annex II replaces The revision of Annex II replaces the current 5-category system the current 5-category system with pollution categories A, B, C with pollution categories A, B, C and D and Appendix III products and D and Appendix III products with a 4-category system with with a 4-category system with pollution categories X, Y and Z pollution categories X, Y and Z and OS (Other Substances).and OS (Other Substances).


In 2003 At MEPC 49 a 3 + 1 category In 2003 At MEPC 49 a 3 + 1 category system (X,Y,Z + OS) was agreed upon. system (X,Y,Z + OS) was agreed upon. The fourth category includes Apple The fourth category includes Apple juice, Clay slurry, Coal slurry, juice, Clay slurry, Coal slurry, Dextrose solution, Glucose solution, Dextrose solution, Glucose solution, Kaoline slurry, Molasses, and WaterKaoline slurry, Molasses, and Water

Vegetable oils will be specified and Vegetable oils will be specified and are upgraded from Appendix III (of are upgraded from Appendix III (of the IBC Code) to Category Y.the IBC Code) to Category Y.


The revision of Annex II replaces The revision of Annex II replaces the current 4-category system the current 4-category system with new pollution categories. with new pollution categories. This has also affected what This has also affected what products can be carried in the products can be carried in the different IMO Ship Type.different IMO Ship Type.

IMO Ship TypeIMO Ship Type

What is considered IMO Type Space?What is considered IMO Type Space?

The IBC Code provides standards for The IBC Code provides standards for the construction of three types of the construction of three types of chemical tankers (Types 1, 2 and 3) chemical tankers (Types 1, 2 and 3)

A Type 1 ship is a chemical tanker A Type 1 ship is a chemical tanker intended for the transportation of intended for the transportation of products considered to present the products considered to present the greatest overall hazard and Type 2 greatest overall hazard and Type 2 and Type 3 for products of and Type 3 for products of progressively lesser hazardsprogressively lesser hazards

Tank Type Tank Type ConfigurationsConfigurations


IMO Type 2 Space

A Type 2 tank is intended to transport products with appreciably severe environmental and safety hazards which require significant preventive measures to preclude escape of such cargo


IMO Type 2 Ship Some or all tanks of stainless

steel Nitrogen for use as a blanket to

exclude air from the tank when carrying cargoes prone to ignition at ambient temperatures


IMO Type 3IMO Type 3 Ship A Type 3 ship is a chemical tanker

intended to transport products with sufficiently severe environmental and safety hazards

Require a moderate degree of containment to increase survival capability in a damaged condition


IMO Type 3 Ship Those specified in the IMO IBC

Code for a Type 3 ship are usually not listed as "hazardous"

They are petroleum products, such as gasoil, naphtha, and gasoline, if equipped with an oil/water separator with a suitable transfer pump


IMO Type 3 Ship

Damage stability and cargo containment requirements for Type 3 ships detailed in the IMO IBC Code

Cargo handling and pollution prevention provisions of MARPOL Annex II

Still a Lack of DataStill a Lack of Data December 31, 2005 has come and gone. December 31, 2005 has come and gone.

There are still products currently being There are still products currently being carried have not been re-evaluated by carried have not been re-evaluated by GESAMP because of a lack of data and GESAMP because of a lack of data and information. information.

Unless the necessary data are submitted by Unless the necessary data are submitted by the end of 2005 the bulk transport of such the end of 2005 the bulk transport of such products is likely to face substantial problems products is likely to face substantial problems from 1 January 2007 (because the required from 1 January 2007 (because the required certificate cannot be issued). certificate cannot be issued).

IMO will have to reach a compromise on this IMO will have to reach a compromise on this issue.issue.

Still a Lack of DataStill a Lack of Data

One of the solutions being proposed One of the solutions being proposed would consider carriage in the would consider carriage in the highest requirements (Pollution highest requirements (Pollution Category X /Ship type 1 or 2) until Category X /Ship type 1 or 2) until the data is received for the missing the data is received for the missing products.products.

This or any other proposal will have This or any other proposal will have to be made at IMO at MEPC 54, BLG to be made at IMO at MEPC 54, BLG 10 or MEPC 55, all meetings will be 10 or MEPC 55, all meetings will be held later this year.held later this year.

Still a Lack of DataStill a Lack of Data

The 42st session of the GESAMP The 42st session of the GESAMP Working Group on the Evaluation of the Working Group on the Evaluation of the Hazards of Harmful Substances Carried Hazards of Harmful Substances Carried by Ships (EHS 42) was held at IMO by Ships (EHS 42) was held at IMO Headquarters in London earlier this Headquarters in London earlier this year.year.

The report on this meeting has just been The report on this meeting has just been released. released. The most recent meeting The most recent meeting report of GESAMP/EHS has indicated report of GESAMP/EHS has indicated that approximately sixty products remain that approximately sixty products remain on the missing data list. on the missing data list.

Draft List of Products Still Missing Draft List of Products Still Missing Data Data

as of February 2006 as of February 2006 Alkyl(C8+)amine, Alkenyl (C12+) acid ester mixture Alkyl(C8+)amine, Alkenyl (C12+) acid ester mixture Aluminum chloride (30% or less)/Hydrochloric acid (20% or Aluminum chloride (30% or less)/Hydrochloric acid (20% or

less) solutionless) solution 2-Amino-2-hydroxymethyl-1,3-propanediol solution (40% or 2-Amino-2-hydroxymethyl-1,3-propanediol solution (40% or

less) less) Ammonium bisulphite solution (70% or less) Ammonium bisulphite solution (70% or less) Ammonium thiocyanate (25% or less)/Ammonium Ammonium thiocyanate (25% or less)/Ammonium

thiosulphate (20% or less) solution thiosulphate (20% or less) solution Benzyl chloride Benzyl chloride N,N-bis(2-hydroxyethyl) oleamide N,N-bis(2-hydroxyethyl) oleamide Butyl stearate Butyl stearate Calcium alkyl (C9) phenol sulphide/Polyolefin Calcium alkyl (C9) phenol sulphide/Polyolefin

phosphorosulphide mixture phosphorosulphide mixture Calcium long-chain alkyl phenolic amine (C8-C40)Calcium long-chain alkyl phenolic amine (C8-C40) Camphor oil Camphor oil Caramel solutions Caramel solutions Cashew nut shell oil (untreated) Cashew nut shell oil (untreated) Cobalt naphthenate in solvent naphtha Cobalt naphthenate in solvent naphtha Creosote (coal tar) Creosote (coal tar) Creosote (wood) Creosote (wood)


as of February 2006 as of February 2006 Decyl acetate Decyl acetate 1,3-Dichloropropane 1,3-Dichloropropane Diethylene glycol dibutyl ether Diethylene glycol dibutyl ether 1,4-Dihydro-9,10-dihydroxyanthracene, disodium salt 1,4-Dihydro-9,10-dihydroxyanthracene, disodium salt

solution solution Dodecenylsuccinic acid, dipotassium salt solution Dodecenylsuccinic acid, dipotassium salt solution Ethyl amyl ketone Ethyl amyl ketone N-Ethylbutylamine N-Ethylbutylamine Ethyl butyrate Ethyl butyrate o-Ethylphenol o-Ethylphenol Ethyl propionate Ethyl propionate Ferric hydroxyethylethylenediaminetriacetic acid, trisodium Ferric hydroxyethylethylenediaminetriacetic acid, trisodium

salt solution salt solution Fish solubles (water-based fish meal extract) Fish solubles (water-based fish meal extract) Fumaric adduct of rosin, water dispersion Fumaric adduct of rosin, water dispersion Glycerine (83%), Dioxanedimethanol Glycerine (83%), Dioxanedimethanol Glycerol polyalkoxylate Glycerol polyalkoxylate Icosa(oxypropane-2,3-diyl)s Icosa(oxypropane-2,3-diyl)s Long-chain polyetheramine in alkyl (C2-C4) benzenes Long-chain polyetheramine in alkyl (C2-C4) benzenes Long-chain polyetheramine in aromatic solvent Long-chain polyetheramine in aromatic solvent


as of February 2006 as of February 2006 Methyl heptyl ketone Methyl heptyl ketone 3-Methyl-3-methoxybutyl acetate 3-Methyl-3-methoxybutyl acetate Naphthenic acids Naphthenic acids Nonyl acetate Nonyl acetate Pentaethylenehexamine Pentaethylenehexamine Polyalkylene oxide polyol Polyalkylene oxide polyol Polyglycerol Polyglycerol Polyolefin amide alkeneamine/molybdenum Polyolefin amide alkeneamine/molybdenum

oxysulphide mixture oxysulphide mixture Polyolefin amide alkeneamine polyol Polyolefin amide alkeneamine polyol Poly(tetramethylene ether) glycol (mw 600-3000)Poly(tetramethylene ether) glycol (mw 600-3000) Potassium salt of polyolefin acid Potassium salt of polyolefin acid n-Propyl chloride n-Propyl chloride

Propylene-Butylene copolymerPropylene-Butylene copolymer


as of February 2006 as of February 2006 Propylene dimer Propylene dimer Rosin soap (disproportionated) solution Rosin soap (disproportionated) solution Sodium aluminate solution Sodium aluminate solution Sodium tartrates/Sodium succinates solution Sodium tartrates/Sodium succinates solution Sulpho hydrocarbon long chain (C18+) alkylamine Sulpho hydrocarbon long chain (C18+) alkylamine

mixture mixture Tall oil fatty acid, barium salt Tall oil fatty acid, barium salt Tall oil soap (disproportionated) solution Tall oil soap (disproportionated) solution Trimethylhexamethylenediamine (2,2,4- and 2,4,4-Trimethylhexamethylenediamine (2,2,4- and 2,4,4-

isomers) isomers) Trimethylhexamethylene diisocyanate (2,2,4- and Trimethylhexamethylene diisocyanate (2,2,4- and

2,4,4-isomers) 2,4,4-isomers) Trimethylolpropane polyethoxylate Trimethylolpropane polyethoxylate Trimethyl phosphite Trimethyl phosphite Urea/Ammonium mono- and di-hydrogen Urea/Ammonium mono- and di-hydrogen

phosphate/Potassium,chloride solution phosphate/Potassium,chloride solution Urea formaldehyde resin solution Urea formaldehyde resin solution

Certification of Cargoes Certification of Cargoes

All non-oil cargoes carried in bulk are All non-oil cargoes carried in bulk are classified by the International Maritime classified by the International Maritime Organization (IMO) and/or the vessel’s flag Organization (IMO) and/or the vessel’s flag state. The carriage requirements for a state. The carriage requirements for a product are then determined by these product are then determined by these entities using the guidelines set forth by entities using the guidelines set forth by GESAMP and IMO. GESAMP and IMO.

If regulated by the IBC Code those cargoes If regulated by the IBC Code those cargoes must be authorised for carriage on that must be authorised for carriage on that particular ship, and listed on, the ship’s particular ship, and listed on, the ship’s Certificate of Fitness. Certificate of Fitness.

Certification of Cargoes Certification of Cargoes

The bulk carriage of any liquid product The bulk carriage of any liquid product other than those defined as oil (subject to other than those defined as oil (subject to MARPOL Annex I) is prohibited unless the MARPOL Annex I) is prohibited unless the product has been evaluated and categorised product has been evaluated and categorised for inclusion in Chapter 17 or 18 of the IBC for inclusion in Chapter 17 or 18 of the IBC Code (The International Code for the Code (The International Code for the Construction and Equipment of Ships Construction and Equipment of Ships Carrying Dangerous Chemicals in Bulk).Carrying Dangerous Chemicals in Bulk).

The MARPOL Annex II Revisions will result The MARPOL Annex II Revisions will result in an amended IBC Code and new in an amended IBC Code and new certification for cargoes and vessels.certification for cargoes and vessels.

Practical Implications of Practical Implications of the Revisions the Revisions

Every chemical tanker is required Every chemical tanker is required to have a Certificate of Fitness to have a Certificate of Fitness (CoF) – indicating that it is certified (CoF) – indicating that it is certified to carry certain products.to carry certain products.

The issuance of a CoF will also The issuance of a CoF will also require a revised Procedures and require a revised Procedures and Arrangements Manual. Arrangements Manual.

Companies should be thinking Companies should be thinking about these new documents - NOWabout these new documents - NOW

Certificates of FitnessCertificates of Fitness

The new P & A Manuals and the new The new P & A Manuals and the new Certificates need to be onboard each Certificates need to be onboard each ship as of the 1 January 2007 deadline. ship as of the 1 January 2007 deadline.

These documents must be These documents must be approved/issued and forwarded to the approved/issued and forwarded to the ships before this date. ships before this date.

Class societies and owners are working Class societies and owners are working diligently to ensure that in late 2006 diligently to ensure that in late 2006 both systems will be in place.both systems will be in place.

New Certificates / P & A New Certificates / P & A ManualsManuals

All Certificates of Fitness issued under the All Certificates of Fitness issued under the present requirements will become invalid present requirements will become invalid from 1 January 2007. from 1 January 2007.

This also affects Offshore Support Vessels This also affects Offshore Support Vessels and dry cargo ships with deep tanks certified and dry cargo ships with deep tanks certified for carriage of noxious liquid substances. for carriage of noxious liquid substances.

Cargoes legally loaded before 1 January 2007 Cargoes legally loaded before 1 January 2007 will be allowed to be carried to the scheduled will be allowed to be carried to the scheduled unloading port under the “old” requirements.unloading port under the “old” requirements.

To carry any noxious liquid substance in bulk To carry any noxious liquid substance in bulk from 1 January 2007 all ships will need to from 1 January 2007 all ships will need to hold a Chemical Carrier Code CoF issued hold a Chemical Carrier Code CoF issued under the revised requirements. under the revised requirements.

Two Systems Two Systems The revised requirements may not be The revised requirements may not be

used used before before 1 January 2007. 1 January 2007. This implies that for e.g. a This implies that for e.g. a

newbuilding being delivered in newbuilding being delivered in December 2006, it will be necessary December 2006, it will be necessary to certify the ship initially under the to certify the ship initially under the current requirements (with “old current requirements (with “old type” P & A Manual and CoF) and type” P & A Manual and CoF) and then again from 1 January 2007 with then again from 1 January 2007 with a “new” P & A Manual and a “new” a “new” P & A Manual and a “new” CoF with List of Products.CoF with List of Products.

The CoF ListThe CoF List

The List of Products attached to a new The List of Products attached to a new Certificate will be calculated based on the Certificate will be calculated based on the revised Pollution Categories and the ship’s revised Pollution Categories and the ship’s compliance with the revised carriage compliance with the revised carriage requirements. requirements.

Less sophisticated chemical tankers, Less sophisticated chemical tankers, including those not complying with the including those not complying with the present stripping requirements for the present stripping requirements for the current pollution category B substances, current pollution category B substances, may, under the revised requirements, lose a may, under the revised requirements, lose a very large portion of their current List of very large portion of their current List of Products.Products.

Stripping & Underwater Stripping & Underwater DischargeDischarge

An underwater discharge arrangement for tank An underwater discharge arrangement for tank washing water is required for pollution washing water is required for pollution categories X and Y for ships keel-laid before 1 categories X and Y for ships keel-laid before 1 January 2007. Newer ships will require such for January 2007. Newer ships will require such for all pollution categories X, Y and Z.all pollution categories X, Y and Z.

The waiver possibilities in respect of stripping The waiver possibilities in respect of stripping performance and underwater discharge performance and underwater discharge arrangement for dedicated ships engaged in arrangement for dedicated ships engaged in carriage of products not involving cleaning of carriage of products not involving cleaning of cargo tanks will remain unchanged. cargo tanks will remain unchanged.

The additional requirements for operation The additional requirements for operation within Special Areas (except the Antarctic) within Special Areas (except the Antarctic) have been deleted.have been deleted.

The Veg Oil CompromiseThe Veg Oil Compromise

As expected, products defined as "Floaters" As expected, products defined as "Floaters" and "Persistent floaters", which include the and "Persistent floaters", which include the vegetable oils, will be assigned to Category Y. vegetable oils, will be assigned to Category Y. Under the currently defined ship typing Under the currently defined ship typing criteria this will mean they have to be carried criteria this will mean they have to be carried in IMO Type 2 ship space.in IMO Type 2 ship space.

The veg oil industry expressed concern that The veg oil industry expressed concern that there would not be enough Type 2 tonnage to there would not be enough Type 2 tonnage to accommodate the post 2007 needsaccommodate the post 2007 needs

At MEPC 52 ( in 2004) a compromise was At MEPC 52 ( in 2004) a compromise was developed by the US, Netherlands and developed by the US, Netherlands and Panama and accepted by IMO. The purpose Panama and accepted by IMO. The purpose of the compromise is to alleviate concerns of the compromise is to alleviate concerns regarding a tonnage shortageregarding a tonnage shortage..

The Veg Oil Compromise The Veg Oil Compromise Accepted at MEPC 52Accepted at MEPC 52

An Administration may exempt ships from the An Administration may exempt ships from the carriage requirements under Regulation 11 for carriage requirements under Regulation 11 for ships Certified to carry individually identified ships Certified to carry individually identified vegetable oils identified by the relevant footnote vegetable oils identified by the relevant footnote in chapter 17 of the IBC Code, provided the ship in chapter 17 of the IBC Code, provided the ship complies with the following conditions:complies with the following conditions:

1. Subject to this regulation, the NLS tanker shall 1. Subject to this regulation, the NLS tanker shall meet all requirements for ship type 3 as meet all requirements for ship type 3 as identified in the IBC Code except for cargo tank identified in the IBC Code except for cargo tank location; location;

2. Under this regulation, cargo tanks shall be 2. Under this regulation, cargo tanks shall be located at the following distances inboard. The located at the following distances inboard. The entire cargo tank length shall be protected by entire cargo tank length shall be protected by ballast tanks or spaces other than tanks that ballast tanks or spaces other than tanks that carry oil as follows:carry oil as follows:

The Veg Oil Compromise The Veg Oil Compromise Accepted at MEPC 52Accepted at MEPC 52

1. 1. Wing tanks or spaces shall be arranged such Wing tanks or spaces shall be arranged such that cargo tanks are located inboard of the that cargo tanks are located inboard of the moulded line of the side shell plating nowhere moulded line of the side shell plating nowhere less than 760 mm; andless than 760 mm; and

2. Double bottom tanks or spaces shall be 2. Double bottom tanks or spaces shall be arranged such that the distance between the arranged such that the distance between the bottom of the cargo tanks and the moulded bottom of the cargo tanks and the moulded line of the bottom shell plating measured at line of the bottom shell plating measured at right angles to the bottom shell plating is not right angles to the bottom shell plating is not less than B/15 (m) or 2.0 m at the centreline, less than B/15 (m) or 2.0 m at the centreline, whichever is the lesser. The minimum whichever is the lesser. The minimum distance shall be 1.0 metre.distance shall be 1.0 metre.

The relevant certificate shall indicate the The relevant certificate shall indicate the exemption granted. exemption granted.

The Vegoil CompromiseThe Vegoil Compromise

Regulation 4.1.3 of the revised MARPOL Annex II, Regulation 4.1.3 of the revised MARPOL Annex II, an administration might allow the carriage of these an administration might allow the carriage of these substances in a ship Type 3 “ONLY” if the ship substances in a ship Type 3 “ONLY” if the ship complies with all requirements for a ship Type 3, complies with all requirements for a ship Type 3, as identified in the IBC Code, except for cargo tank as identified in the IBC Code, except for cargo tank location. location.

The cargo tank location shall be in accordance with The cargo tank location shall be in accordance with regulation 4.1.3.2 of the revised MARPOL Annex II regulation 4.1.3.2 of the revised MARPOL Annex II but these ships must be constructed with double but these ships must be constructed with double sides meeting the requirements for IMO ship Type sides meeting the requirements for IMO ship Type 2 vessels and double bottom requirements of B/15 2 vessels and double bottom requirements of B/15 or 2 meters (whichever is the lesser) and the or 2 meters (whichever is the lesser) and the Certificate of Fitness shall indicate the exemption Certificate of Fitness shall indicate the exemption granted. granted.

The Vegoil CompromiseThe Vegoil Compromise

Next to each of these product Next to each of these product listings in Chapter 17 letter “k” listings in Chapter 17 letter “k” referring to regulation 4.1.3 of the referring to regulation 4.1.3 of the revised MARPOL Annex II. revised MARPOL Annex II.

INTERTANKO has received may INTERTANKO has received may enquiries regarding converting enquiries regarding converting product tankers to Type 3 ships but product tankers to Type 3 ships but we have no concrete evidence we have no concrete evidence indicates that this is being carried indicates that this is being carried out.out.


Despite the rumours Despite the rumours

veg oils veg oils willwill move move As of today, no extensions or delays As of today, no extensions or delays

have been accepted by IMO. have been accepted by IMO. On 1 January 2007 veg oils will On 1 January 2007 veg oils will

have to be carried in IMO Type 2 or have to be carried in IMO Type 2 or 3 space. 3 space.

MARPOL Annex II Revisions MARPOL Annex II Revisions

What Else?What Else? Oil like substances will not exist (e.g Oil like substances will not exist (e.g

xylene requires chemical code xylene requires chemical code certificate)certificate)

75 litre stripping required for all 75 litre stripping required for all tankers (Chemical Code/NLS) for tankers (Chemical Code/NLS) for keels laid after 1 January 2007 keels laid after 1 January 2007 (Existing IBC ships 100 litres XY- 350 (Existing IBC ships 100 litres XY- 350 litres Z, existing NLS as good as litres Z, existing NLS as good as possible)possible)

How Does the IMO Decide on Ship Type?

Ship Type Criteria - based on GESAMP hazard profiles in table 4.5.1 of Annex 7 to MEPC 51/11 (Criteria for Assigning Carriage Requirements from Products Subject to the IBC code).

What is Moving Where:

There are approximately 150 products from the IBC Code that are moving to Type 2. Here are just a few in alphabetical

order:

Ammonia, aqueous Carbon tetrachloride

Chlorobenzene Decanoic acid Decyl alcohol

Dodecyl alcohol Fatty acid (saturated C13+)

Hexane Lauric acid

Nonene Octanol

Oleic acid Perchloroethylene Propylene tetramer

Pyridine Pyrolysis gasoline

Turpentine Undecanoic acid Undecyl alcohol

Chemicals Current Proposed Current Proposed

Phenol C Y 2 2

Phosphoric Acid D Z 3 3

Caustic Soda D Y 3 3

Sulphuric acid C Y 3 3

Benzene C Y 3 3

Toulene C Y 3 3

Cumene (Propylbenzene) A Y 3 3

Acetic Acid D Z 3 3

Methanol D Y N/A 3

Ethylene Glycol D Y N/A 3

Xylenes C Y 3 2

Acrylonitrile B Y 2 2

MTBE D Z N/A 3

Urea Ammonia Nitrate Soln (UAN) C Y 3 3

Ethylene Dichloride (EDC) B Y 2 2

Big Movers – ChemicalsBig Movers – Chemicals

Big Movers – Veg Oils & Big Movers – Veg Oils & FatsFats

Vegetable Oils & Fats

Palm Oil D Y N/A 2

Palm Kernal Oil D Y N/A 2

Soyabean Oil D Y N/A 2

Cottonseed Oil D Y N/A 2

Groundnut Oil D Y N/A 2

Sunflower Oil D Y N/A 2

Rapeseed Oil D Y N/A 2

Corn Oil D Y N/A 2

Coconut Oil D Y N/A 2

Olive Oil D Y N/A 2

Castor Oil D Y N/A 2

Linseed Oil D Y N/A 2

Tallow D Y N/A 2

Lard III Y N/A 2

Fish Oil\ D Y N/A 2

MARPOL Annex II and US Implementation

The USCG is initiating a regulatory project to implement MARPOL Annex II revision. However, these regulations will not be completed in time for their entry into force date of 1 January 2007. The USCG regulations that will be in effect on that date will be the current regulations for the transport of Annex II substances.

MARPOL Annex II and US Implementation

The USCG intends to develop a Navigation and Vessel Inspection Circular (NVIC), a guidance document to industry that will provide the industry with an elective (or alternative) method of complying with the regulations in effect. This elective method will reflect the revised Annex II. It It will be the guidance used by will be the guidance used by industry and regulators.industry and regulators.

MARPOL Annex II and the Carriage of Biofuels

The term biofuel encompasses a diverse range of products such as bio-gas, biodiesel and bioethanol. Any fuel made from a renewable biological source is considered a biofuel. Biofuels include ethanol, biodiesel, and methanol. Biofuel is derived from recently living organisms or waste streams (agricultural, domestic or municipal).

Carriage of Biofuels BIODIESEL

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 useable by-product. These products cannot be shipped under MARPOL Annex II using these trade names.


Most of the discussion recently regarding the classification of bio-fuels under Annex II has been predominantly about bio-diesel.

The majority of biodiesel cargoes are fatty acid methyl esters (FAME) with 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 currently

Category D and Chapter 18.


Any new data that has been submitted on these products will be considered at BLG 10 in April 2006.

If approved by BLG 10 they will be included on List 1 of the 2006 edition of the MEPC.2/Circ., most likely as Category Y and Ship Type 2.

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.

Carriage of Biofuels BIOETHANOL

Bioethanol is a readily available, clean fuel that can be utilized in combustion engines in different ways such as anhydrous (or dehydrated) ethanol which is free of water and at least 99 percent pure.

This ethanol can be blended with conventional fuel in proportions up to 85 percent (E85). Blends up to 20 percent can be used in modern engines without modification.

Traditionally, 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 US ethanol market has grown from 2.3 to 4 billion gallons in the last three years.

Carriage of Bio-Fuels BIOETHANOL

Higher blends require modified engines that run as flexible fuel vehicles (FFVs). There are currently over a million FFVs on the road in the US with an increasing number added each year, and there are a small but growing number of E85 gas stations, primarily in the Midwest.

Bioethanol 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 US most the 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. In the US, for example in the state of New York, which uses a 10% ethanol blend, a terminal south of Albany receives 100% ethanol by barge and mixes it with gasoline from a pipeline.


The US Congress has recently passed a Renewable Fuel Standard (RFS) that requires a minimum percent 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.

Carriage of Biofuels How will they be

classified?

Most bio-ethanol cargoes (and some biodiesels) containing any blend containing 85% or more of a mineral diesel oil or gasoline qualify as Annex I product. The issue of the carriage of bio-fuels will become more prevalent as more of this product is shipped. Classification of these products needs to be discussed in greater detail and resolved to ensure the trade can continue after 1 January 2007.

Carriage of Biofuels Proposals

A proposal has been made to the IMO that will act as an interim measure in classifying the expanse of biofuels out there. This focuses on both bioethanol and biodiesels (most likely FAME products)

IMO and the 2006 IMO and the 2006

ScheduleSchedule

There are many loose ends that need to be tended to before December 31, 2006 IMO has three meetings scheduled for 2006 where these matters can be discussed:

1.MEPC 54 – March 2006 2.BLG – 10 – April 2006 3.MEPC 55 – October 2006

Predictions Predictions /Conclusions /Conclusions

The MARPOL Annex II Revisions have been in the works for decades and they will take effect 1 January 2007. That is a safe prediction.

The implementation of these regulations will require action by all stakeholders including the tanker industry, IMO member states, product manufacturers, shippers, class societies, etc.

Predictions Predictions /Conclusions /Conclusions

INTERTANKO will continue to be closely involved to ensure that the transition is as smooth as possible for industry.

The only other possible prediction to be made at this time is…..

BOSTON RED SOX WIN BOSTON RED SOX WIN 2006 World Series2006 World Series

marpol annex ii revisions intertanko seminar houston, tx 15 march 2006

Documents