Material Safety Data Sheets
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.
2020 Sulphur Cap – Discussions at PPR 6
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.
Carriage of High Viscosity and Persistent Floating Substances
Amendements to MARPOL Annex II have been agreed to require a prewash for vegetable oils and waxes after unloading in ports in Western and Northern Europe. The products covered will be indicated in column o of chapter 17 of the IBC Code by a reference to a new regulation 16.2.7. The text of the amendments can be found in the Members’ Area. The amendment text still has to be adopted by the Marine Environment Protection Committee and is now expected to enter into force in January 2021, rather than 2020, as had originally been anticipated.
EU Ship Recycling Regulation
EU Regulation 1257/2013 is intended to bring forward application of the Hong Kong Convention on Ship Recycling. It will become effective on 31 December 2018, unless the annual ship recycling output of the recycling facilities in the EU approved list has reached 2.5 million LDT before then, and will apply primarily to new EU flagged ships. Existing ships and ships flying third party Flags trading in EU waters will be requred to comply with the requirements for an Inventory of Hazardous Materials by the end of 2020.
Carriage of Used Cooking Oil
In February 2015 the PPR Sub-Committee agreed to assign carriage requirements on the basis of a “worst case scenario” pending receipt of the data required for the product to be evaluated. Pollution Category X was therefore assigned, with other carriage requirements the same as for vegetable oils. Data on the product was subsequently submitted and a paper submitted to the 21st sessin of the ESPH Group proposing that the pollution category be changed to Y. Concern was expressed by a number of member states, however, that Used Cooking Oil, by definition, can be made up of many different products and there is no guarantee that a product offered for shipment is the same as that submitted for evaluation. It was therefore decided that the next edition of the MEPC.2/Circ. should contain 2 entries, namely a generic entry for Used cooking oil, with pollution category X, and a second entry, “Used cooking oil, triglycerides C16-C18 and C18 unsaturated”, with pollution category Y. Only if there is evidence (such as through the MSDS) that the product is the same as that described under this second entry can it be shipped as pollution category Y.
Adoption of IGF Code
The 95th session of the IMO’s Maritime Safety Committee adopted the text of the International Code of Safety for Ships using Gases or other Low Flashpoint Fuels (IGF Code), together with amendments to SOLAS to make it mandatory. Both will enter into force on 1 January 2017. The Code sets out provisions for the arrangement, installation, control and monitoring of machinery, equipment and systems using low flashpoint fuels, and concentrates, in the first instance, on the use of LNG. MSC 95 agreed that the Code should not apply to Gas Carriers complying with the IGC Code and appropriate adjustments were made to the SOLAS amendments to reflect this. Guidance for ships using other low flash fuels such as Ethanol or Methanol and measures for ships using low flashpoint diesel are under development for inclusion in the Code in the future as appropriate. The measures for gas carriers may have to be revised in the light of inclusion of any such fuels into the IGF Code. The text of the IGF Code can be found in the Members’ Area.
Polar Code
The text of the International Code for Ships Operating in Polar Waters has now been adopted by both the Maritime Safety Committee and the Marine Enviornment Protection Committee, together with the amendments to SOLAS and MARPOL that are necessary to make it mandatory. The Code will apply to internationally trading ships operating in polar regions and contains measures addressing design, construction, equipment, operational measures, training, search and rescue and environmental protection. It will enter into force on 1 January 2017, with existing ships being required to comply by the first intermediate or renewal survey, whichever occurs first, after 1 January 2018. The text of the Code can be found in the Members’ Area
Application of Inert Gas to Chemical Tankers
In May 2014 the IMO’s Maritime Safety Committee approvedamendments to SOLAS and the Fire Safety Systems Code to mandate the use of inert gas on new oil tankers of below 20,000 dwt and new chemical tankers. The amendments provide for a lower lower size limit of 8,000 dwt and allow for vessels of less than 20,000 dwt to use shore-supplied inert gas rather than install an inert gas system where appropriate. There is also a provision for chemical tankers to have the option of dispensing with the inerting of tanks prior to loading, providing that inert gas is applied for the discharge and thereafter throughout the tank cleaning phases. Consequential amendments have also been made to the IBC Code, including regulation 15.13.5 in relation to the use of inert gas with cargoes requiring oxygen-dependent inhibitors. When such products are being carried the vessel will not inert until immediately prior to discharge and the shipper of the cargo will be required to provide details of the level of xygen necessary for the functioning of the inhibitor. The regulations will enter into force on 1 January 2016. The text of the amendments can be found in the Members’ Area.