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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 1 2 3 4 5 10 10 11 15 17 30 30 31 33 38 39 40

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
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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 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 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. 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.
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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 INTERTANKOs 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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INTERTANKO: The Revisions to MARPOL Annex II A Practical Guide

INTERTANKO MEMBERS will: 6. Lead the continuous improvement of the Tanker Industrys performance in striving to achieve the goals of:
N N N

Zero pollution Zero deaths 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 Re-categorisation of vegoils, soft oils and fats Reclassified from to D to IMO type 2 (or IMO type 3 with DH meeting operational requirements) Products and volumes 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) Methanol MTBE UAN MEG/TEG/DEG Ethyl acetate, Methyl ethyl ketone Xylenes Acrylonitrile 17 m ts 5.5 m ts 5 m ts 5 m ts 1 m ts > 5 m ts < 1 m ts

Other products with no previous requirement to IMO ship type

IBC ch18 to IMO type IMO 3

Change of ship type requirements

IMO type 2 to 3

No requirements
Source: Inge Steensland AS

No change

Molasses Ethanol

6 m ts 3 m ts

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.
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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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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.

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November 2006

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
Source: Inge Steensland AS

M tonnes 1.9 1.8 2.8 5.5 12.0

Share 16% 15% 23% 46% 100%

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.

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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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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.
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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
B/5 or 11.5m (Whichever is less, but no where less than 760mm) B/ 5 Cargo

760 mm

B/

15

B/

15 Type III Tank Configuration

Type I Tank Configuration

Type II Tank Configuration

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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."
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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
Category BCH Ships Constructed before 31/7/1986 Existing IBC Constructed New Buildings Constructed from 31/7/1986 from 1/1/2007 but before 1/1/2007 Pre Wash Strip to 150 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 Strip to 350 Litres 12 mile 25m water depth 7 knots, en-route No Carriage Requirements Only X and Y cargoes Pre Wash Strip to 75 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 Strip to 75 Litres 12 mile 25m water depth 7 knots, en-route No Carriage Requirements X,Y and Z cargoes Only X and Y cargoes Ships Other than Chemical Tankers constructed before 1/1/2007 Carriage Prohibited

Pre Wash Strip to 350 Litres 12 mile 25m water depth 7 knots, en-route Pre Wash for solidifying for high viscosity substances Strip to 350 Litres 12 mile 25m water depth 7 knots, en-route Strip to 950 Litres 12 mile 25m water depth 7 knots, en-route No carriage Requirements Only X and Y cargoes

Carriage Prohibited

Strip to Maximum Extent 12 mile 25m water depth 7 knots, en-route

OS Underwater Discharge Required

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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);

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; The relative development of a new pollution categorisation system and criteria for assigning products to these new categories; 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; 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.

The fate of any products omitted from the amended IBC Code due to missing safety and/or pollution data. They
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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.

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.

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 Issue a certificate under the revised MARPOL Annex II starting as from 1 January 2007 with an identical expiry date as the existing certificate. Issue a new certificate under the revised MARPOL Annex II with an expiry date of 5 years from the survey date. Issue a new certificate under the revised MARPOL Annex II with an expiry date of 5 years from the renewal survey date. Issue a full term certificate alid for 5 years after the initial survey.

Certificate valid until after 1 January 2007

N/A

Renewal survey on or after 1 July 2006 Change of flag on or after 1 July 2006

Extend the validity of the existing certificate to 1 January 2007. Replace the coversheet of the current certificate R with an extension of the validity to 1 January 2007.

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.

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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 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

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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 - 120C) 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

Y Y Z Y Y Z 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 Z Z X Y Y Z Y X X Y Y Z Y Y

3 3 3 2 2 3 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 3 3 2 3 2 3 2 2 2 3 2 3 3 3

B C D A B III 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 D D B C B III C A A B D D C C

3 3 n/a 3 3 n/a 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 n/a 3 3 3 2 n/a 2 3 2 3 3 n/a 3 3

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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

Z Y Y Y Y Z Z Y X Z Z Y Z Y Y Z Z Y Y Y Y Y Y X 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

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 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 C D D III D C B III D C D D C III D A B B D D A 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

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 1 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

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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

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

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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

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 A III D D III A B B A III A A III D III A

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 2 n/a n/a n/a n/a 1 3 3 2 n/a 2 1 3 3 3 1

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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

Y X 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 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 2 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 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

III B 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 C III C D B B D B D C A B III D

n/a 3 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 2 n/a 3 n/a 3 2 n/a 3 3 2 3 3 n/a n/a

III D C C D C C D

n/a n/a 3 2 n/a 3 3 n/a

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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

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 D D

3 3 3 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

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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

Z X Z Y X Y Y Y Z Z Y Y Y Y X Z X Y 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 3 2 (k) 2 2 2 2 3 3 2 2 3 2 (k) 2 3 1 3 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

III B III D A C D III D III D D D D B D A D D D D III D 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 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 n/a 2 2 n/a n/a 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

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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

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 C B C B B C B B

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 3 3 3 3 3 3 3 3

C A D D

2 2 n/a n/a

D C D D

n/a 3 n/a n/a

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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)

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

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

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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

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 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 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 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

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 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 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 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

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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

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 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 III C D III A D B B B B D C III III C D III C C D

3 3 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 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

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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

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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 N N

1. The port state of the shipper. 2. The flag state of the carrier 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
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& 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.

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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)
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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 todays 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.

We do not report the lack of reception facilities as we doubt anything would be done this also applies to Annex I facilities.

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Reporting contact details are not readily available 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 vessels future ports.

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, receivers facility) are not concerned by categories. 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.

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.

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)

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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 todays 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)

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.

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)

On the condition that the reception facilities also accept trade names This may also be beneficial to vessels needing to discharge materials. Its 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.
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Biofuel is derived from "biomass" - recently living organisms or their metabolic by-products, such as waste streams (agricultural, domestic or municipal).

It is a renewable energy, unlike other natural resources such as petroleum, coal and nuclear fuels. 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.

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:
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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.

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.

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.