Tanker Related Issues

Hydrostatic Balanced Loading

Based on an INTERTANKO submission calling for the need to safely and uniformly implement MEPC’s Guidelines for HBL, contained in Resolution MEPC.64(36), it was decided to task the Bulk Liquids and Gases Sub-committee to approve the action taken by industry in the development of such interpretations. Given the number of tankers reported by INTERTANKO that will soon be subject to the possible application of HBL (see Figure 1), MEPC42 was advised that IACS had finalized the development of such interpretations and that a submission would be made shortly. The IACS interpretations have been preliminarily accepted by INTERTANKO.

These interpretations standardize the calculation of the three Equivalent Oil Spill (EOS) indices and specifies that the EOS indices need only be determined once to validate the conceptual arrangement and nominal operating conditions. To simplify the calculation methodology and the presentation of information to the ship’s master, cargo heights for actual loading conditions and arrangements need only be evaluated according to the HBL criteria and not directly against the EOS criteria. An overview of IACS interpretation’s methodology is shown on the attached flow chart “Application of MARPOL Regulation 13G(7) and Resolution MEPC.64(36)”.

Reception Facilities

A lengthy discussion addressed the inadequacy of numerous facilities provided by some port States having jurisdiction of waters categorized as special areas under MARPOL. Part of the problem relates to the inadequate communication to the ship operator of the facilities’ characteristics and the lack of information identifying the capacity relative to the type (oily water, solid shipboard generated garbage, sewage) and rate of discharge it can process. MEPC agreed that at its 42nd session in November 1998, work should begin to develop an action plan for countries to evaluate the adequacy of their reception facilities and to determine how to improve communication between the user and provider. It was also noted that information on reception facilities would soon be published by IMO on the INTERNET.

Reclassification of Oil

Based on the difficulty and significant costs (in excess of USD $200 million), which may in part be due to the ineffectiveness off the available equipment used to clean up persistent oil spilled from the Nakhodka accident, Japan submitted a proposal that would reclassify oil into three categories. This would require all product carriers between 20k and 30k deadweight carrying persistent oils (oils with properties similar to crude oil but currently classified as other oil by MARPOL) to be subject to the phaseout provisions of MARPOL Regulation 13G at 25 years of age, as is now applicable for product carriers > 30K deadweight.

Non-persistent (Group I) oils contain hydrocarbon fractions of which: (1) at least 50% by volume distill at 340o C and (2) at least 95% by volume distill at 370o C.

INTERTANKO challenged the cost benefit of the proposal by providing information which indicated that the reclassification of oil into three categories (crude, persistent and other oil) would cost the industry approximately five times the estimated cost of USD $375/barrel of oil associated with implementing MARPOL Regulation 13G for existing single hull tankers. This was based in part on the 1995 U.S. Regulatory Assessment which showed an estimated 19% cargo shut-out average for this size of tanker. It was also indicated that of the 226 product carriers between 20K and 30K deadweight that are subject to the proposed regulation, only 10 vessels would be actually be effected. This considers the development and implementation of such regulation would take 3 to 4 years, during which time a good portion of tankers would have reached 30 years of age. It was also noted that 50% of these product carriers are State owned operating in cabatage trade and therefore not subject to MARPOL. Finally, it was noted that many product carriers are already certified for the dedicated carriage of crude oil. MEPC agreed to task its subsidiary sub-committee on Bulk Liquids and Gases to assess Japan’s proposal.