The latest edition of the MEPC.2/Circ. was issued on 1 December 2018. This circular acts as something of a supplement to the IBC Code and is made up of a series of lists showing products that have been evaluated and will be included in the next edition of the IBC Code, Tripartite agreements, carriage requrements for mixtures, and information on a number of issues such as contacts for tripartite agreements, lists of biofuels etc. This edition also includes a list of the products known as "Energy Rich Fuels" which must be carried under the provisions of MARPOL Annex I rather than Annex II.
Where products appear in the last edition of the circular (MEPC.2/Circ.23) but have been deleted from the latest edition, they can continue to be carried until 31st December 2018.
The Circular can be accessed in the Members' Area.
The 10th IPTA-Navigate Chemical and Product Tanker Conference took place on 5th and 6th of March with representatives of the shipping industry, major charterers and some IMO member states in attendance. The keynote address was given by Mr Ki Tack Lim, Secretary General of the International Maritime Organization, who highlighted the work being undertaken by the IMO in relation to the forthcoming cap on emissions of sulphur dioxide and measures to reduce Geeenhouse Gas emissions from ships. Panel discussions on these issues delved deeper into these issues, with delegates being encouraged to participate as much as possible.
Subsequent sessions covered amendments to the IBC Code and forthcoming regulatory changes for the carriage of vegetable oils and waxes, as well as operational issues and market analyses, providing an interesting and informative day and ahalf for delegates.
The IMO's Data Collection System will become effective on 1 January 2019, and under this system vessels of 5,000 gt and above will be required to collect information on the amount of fuel they consume, distance travelled and hours underway. The data collected over the course of a calendar year must be aggregated and reported to the Flag Administration for submission to a central databse managed by the IMO.
The EU had initially indicated its willingness to align its system to a global system tht might be developed by the IMO. The system that has now been developed by the IMO, however, is much less detailed than the EU system and will only make anonymised data available to analysis by IMO member states. The EU, by contrast, plans to make data on the supposed efficeincy of individual ships available to the general public. The European Commission is currently engaged on a consultation exercise to determine whether or not the two systems should be aligned.
International legislation prescribes that bulk liquids offered for shipment by sea must be accompanied by an MSDS based on the format agreed by the UN Globally Harmonised System of Labelling of Chemicals but IPTA Members report continuing issues associated with the provision of MSDS, including missing or incorrect information on topics such as physical characteristics and transport information of products being shipped. The MSDS Information Paper put together by IPTA, Intertanko, CDI, CEFIC and DGAC sets out the regulatory environment surrounding MSDS and provides information on the format and content of MSDS for products being shipped under the IBC code. We would suggest that ship oeprators bring this to the attention of charterers and shippers and encourage them to follow its recommendations.
The 6th session of the PPR Sub-Committee considered various issues in relation to the implementation of the 2020 sulphur cap, including control measures by Port states, possible non-availability of compliant fuel and possible safety implications related to the use of low sulphur fuels. Guidelines for Consistent Implementation of the 0.5% Sulphur Limit were finalised for adoption at MEPC 74, including information on identified potential safety implications associated with compliant fuels and a format for a Fuel Oil Non-Availability Report (FONAR) to be used in circumstances where a vessel has been unable to source compliant fuel.
Discussions on how to treat vessels that are found to have non-compliant fuel, even though they have stemmed and paid for compliant fuel and have a BDN confirming it to be so, were inconclusive. Guidance was developed for port states on contingency measures for addressing non-compliant fuel, but it will be necessary for MEPC to give some consideration to concrete proposals for measures in this regard.
Proposals for ad-hoc sampling of fuels by port state authorities prior to delivery to ships were rejected, on the grounds that this would create too much of an administrative burden. Amendments to MARPOL Annex VI were developed, however, in relation to sampling by port states on board ships of both the in-use fuel and of fuel in bunker tanks that is not yet being used. Guidelines have been agreed for sampling of in-use fuel and further guidance needs to be developed for sampling of bunker tanks.