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TECHNOLOGY - TANK SERVICING
BLG 15 – report of
the ESPH working
group
The Evaluation of Safety and Pollution Hazards (ESPH) working group met between
7th and 11th February during the 15th session of the IMO’s BLG sub-committee,
with the IPTA secretariat in attendance*.
Issues of interest to the parcel tanker
sector are summarised below by the
International Parcel Tankers’
Association (IPTA).
Some amendments were made to the draft
guidelines for the carriage of blends of
petroleum oil and biofuels, which had been
agreed at ESPH 16 in October 2010.
1) The Finnish product renewable diesel was
added to the list of products in the
definition of biofuels, under the name in
which it appears in List 1 of the MEPC.2/
Circ, ie Alkanes (C10-C26) linear and
branched. It should be noted that in future
there will be two entries for this product,
one covering the low flash product and
one covering the product where the flash
point is greater than 60 deg C. Additional
generic carriage requirements were
developed to cover blends of these
products with petroleum diesel or gasoil.
2) It was agreed that in order to
accommodate any biofuels that may be
developed in the future an additional
Annex will be added to the MEPC.2/Circ.
listing biofuels that fall under the scope of
the guidelines.
3) The generic carriage requirements relating
to blends of diesel and FAME or vegetable
oil were amended to include gasoil as
another possible blending component.
4) The provision that allows for residues of
blends carried under the provisions of
MARPOL Annex I to be pumped ashore
where the vessel’s ODME has not been
approved for the blend in question was
amended to include a cut-off date of 1st
January 2016. In other words, after this
date the equipment must be certified in
order for these blends to be carried.
The association said that it urged members to
get in touch with their equipment manufacturers
in order to assure that the necessary approvals/
certification are obtained. The guidelines still
have to be formally adopted by the Maritime
Safety Committee (MSC) and Marine
Environment Protection Committee (MEPC).
IPTA pointed out that the current situation,
where there are multiple tripartite entries
within Lists 2 and 3 of the MEPC.2/Circ. for
biofuel blends from different producers, is
extremely confusing for industry and
complicates the certification process.
The association suggested that it would
therefore be beneficial to apply the provisions
of the guidelines as soon as possible. With no
support forthcoming for this suggestion,
however, it was decided that the interim
guidance should be extended until 1st
September this year.
“As members are aware, under the interim
guidance the cut-off point for the biofuel
element in a blend carried under MARPOL
Annex I is 15% and blends with a higher
percentage of biofuel have to be carried under
MARPOL Annex II under one or other of the
entries in List 2 or List 3 of the MEPC.2
/Circ.or a new tripartite agreement”, IPTA said.
The generic carriage requirements in the
guidelines for shipment of blends under
MARPOL Annex II will be included in List 1
of the next edition of the MEPC.2/Circ. (to be
issued in December this year) and will also
appear on the IMO website once agreed by the
parent committees.
The latest draft of the Guidelines can be
found at Appendix 1.
IBC Code chapters 17 and 18
As previously advised, it has been pointed out
that the IBC Code currently operates under
what is effectively a dual standard, with
products included in the last few years
evaluated under stricter safety criteria than
those included in earlier years.
The last session of the ESPH Group had
been advised that if all the products in the
code were re-evaluated according to the
current criteria around 18% would be affected,
with the majority requiring stricter carriage
requirements, primarily a higher ship type
and/or more stringent tank type requirements
(ie independent tanks).
A document had been submitted to this
session showing a representative sample of 10
products and how they would be affected if reevaluated
according the current criteria and
which particular criteria would trigger those
requirements. This demonstrated that it is the
rating for dermal toxicity that triggers the
enhanced ship type and tank type requirements.
While some member states are of the opinion
that carriage requirements should be updated to
take into account such safety hazards, IPTA
questioned whether an enhanced ship type or
tank type is the appropriate measure to deal
with a hazard that exists only when the product
comes into contact with skin.
The next intersessional meeting of the
ESPH Group (in October this year) will look
into this issue further and in particular
consider whether it is necessary to revisit the
criteria for assigning carriage requirements, or
simply amend carriage requirements according
to the current criteria.
It should be noted that under IMO
procedures if any amendments to carriage
requirements were to be agreed, the earliest
date that they could become effective is 2018,
and given the amount of work that would be
necessary the date is more likely to be 2022.
Missing product data
Members will recall the discussions some
time ago on the testing of PV valves for
products with a low MESG and the need for
some point of reference on the MESG of
products. It was decided at that time that for
these purposes reference should be made to
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