The+A+to+Z+Annex+II+revision

In April, IMO MEPC 49 finally agreed on how MARPOL Annex II should be revised, with a scheduled formal adoption at MEPC 52 later this year, in October. The changes are scheduled to enter into force on 1 January 2007, together with a revised Chemical (IBC) Code.

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Xanthia is a product/chemical tanker, under DNV Class and owned by Anders Utkilens Rederi AS. But what IMO ship type is she and what products can she carry?

The objective of the revision is to adapt the carriage of chemicals to the new GESAMP procedure, with fewer non-regulated cargoes, a reduction in the number of pollution categories, and to generally simplify the operational requirements.

For the new pollution category all cargoes will be re-evaluated with regard to their marine-pollution hazard profile. This will be based on new category changes, proposed as follows:

  • Most pollution Category A substances are to become Category X
  • Most pollution Category B and C substances are to become Category Y
  • Most pollution category D and Appendix III (non-regulated) substances are to become Category Z
  • A few Appendix III (non-regulated) substances are to become OS (other substances).

The important issue, however, is that the new amendments, if adopted, will cover operational aspects and will be applicable to all (both new and existing) ships from a date to be established in time, although it is likely that the new amendments will work hand-in-hand with existing requirements until the original Annex has been successfully phased out.

In line with the improvements made in stripping performance over the past few years, these requirements will be changed as follows:

  • All Chemical/NLS tankers (keel laid after 1 May 2007):
    75l for XYZ (no tolerance)
  • Existing IBC ships:
    150l for pollution category XY (incl. 50l tolerance)
    350l for pollution category Z (incl. 50l tolerance)
  • BCH ships:
    350l for pollution category XY (incl. 50l tolerance)
    950l for pollution category Z (incl. 50l tolerance)
  • Existing ships with NLS Certificate should strip as good as possible.

The most likely outcome is that cargoes previously transported on oil tankers may in future have to be carried by chemical tankers. Other cargoes, which up to now have been carried on IMO Type 3 chemical tankers, may be shifted to IMO Type 2 chemical tankers from 1 January 2007.

For instance, vegetable oils are likely to become Category Y cargoes and carried on Ship Type 2/3. They will also have to be carried only under individual names. Methanol is likely to become a Category Y product and transported in IMO Ship Type 3, while MTBE is likely to fall under Category Z and transported in an IMO Ship Type 3. Caustic Soda is likely to become a Category Y product and have to be transported by an IMO Type 3 vessel, which will need an upgrade in stripping performance according to age as per above.

Oil-like substances will no longer be able to be carried on product tankers, with Toluene likely to become a Category Y product for IMO Ship Type 3. Xylenes are likely to fall under Category Y and fall under Ship Type 2.

This will limit the number of cargoes that can be transported by existing ships and should be seriously considered when planning newbuildings. DNV offers advice both to shipowners and yards about the revised requirements, and so far DNV offices around the world have held a number of presentations.