After years of discussion, amendments to MARPOL Annex II and the IBC Code enter into force on 1 January 2021. These will have profound implications for the shipboard and commercial aspects of chemical tanker operations
Intertanko chemical manager and regional manager for the Americas, Patrick Keffler and Eaglestar Marine Holdings head of customer relationship management Capt Sanjay Patil, discuss some of the major changes set to be rolled out in the revised International Bulk Chemical (IBC) Code.
Mr Keffler, who has over 30 years’ experience in the USCG, joined INTERTANKO in September 2018 as the chemical manager. He acts as secretary for INTERTANKO’s Chemical Tanker Committee and Chemical Tanker Sub-Committee Americas. These technical bodies provide members a forum to discuss national and global regulatory developments and pollution prevention and pollution liability issues, as well as developing best practices to improve safety standards on chemical tankers. He also represents INTERTANKO at IMO meetings that discuss chemical tanker standards.
Mr Keffler explained that the IBC Code has now been formally accepted and will enter into force on 1 January 2021 and the relevant changes occur in Chapter 21, the part that deals with carriage requirements.
“This captures the safety aspects of the ICB Code,” said Mr Keffler. “Chapter 21 is how the carriage requirements are created and with Chapter 21 bringing changes, the IMO’s working group on Evaluation of Safety and Pollution Hazards (ESPH) redrafted the carriage requirements in Chapter 17 and 18 of the code in full,” he said.
Two major changes are the updating of ship types, which impacts the location where products can be carried on a products tanker or a chemical carrier, and the vapour detection requirements, specifically which products have been assigned a toxicity rating (T-rating). This includes:
Over 400 products in Chapter 17 now have T-ratings with 236 new entries, previously not toxic, now on the list. These require vapour detection: 236 products now have a T-rating; 42 products move from toxic to non-toxic; and 101 products that previously did not require emergency equipment now require emergency escape packs for each crew member.
Mr Keffler said that the UN scientific advisory panel Joint Group of Experts on the Scientific Aspects of Marine Environmental Protection (GESAMP), through IMO’s Evaluation of Harmful Substances working group, continues to investigate properties related to inhalation toxicity and has also discussed dropping the T-rating for some products that currently carry the label at some point in the future.
The other issue is that there is a gap between IBC Code Chapter 17 and MEPC.2/Circular. “It’s a challenge for the industry to deal with the changes when products are placed in the MEPC.2/Circular that do not align with what is currently in Chapter 17 of the (IBC) Code,” said Mr Keffler.
Mr Keffler said he also expects some chemical companies to reach out to GESAMP with updated testing information and to ask for a new hazard class for those products. It is a process that will take time, he noted, and there needs to be a way to flag up that a product has been reclassed – such as date and a qualifier.
“Shippers will be able to use that classification and those carriage requirements, provided that they add the qualifier on the Certificate of Fitness,” he said.
The next stage is the continued investigation into cargoes that have been given toxic cargo ratings. “One of the items in that rating process is C3 rating for inhalation toxicity,” said Mr Keffler. It is felt by some in GESAMP that some products could be downgraded, “But that is a work-in-progress,” he said.
Capt Patil spoke from the perspective of a vessel manager preparing for the implementation of the code. Eaglestar has worked with classification societies to understand the changes that will occur, such as on existing issues with regards to toxicity testing practices, Mr Patil said.
“Safety and well-being of the crew is at the top of the agenda,” said Capt Patil, noting the company started the process early. “We sought a gap analysis from the classification society,” he said. “We wanted to understand the changes that impacted our vessels. If we wanted to continue to carry those products, what changes will need to be implemented,” he said.
“We are now at the stage where we are very clear what needs to be done and what are the deliverables”
“We are now at the stage where we are very clear what needs to be done and what are the deliverables,” he said. However, there are still issues outside the control of ship operators. For instance, as at August 2020, IMO had not yet approved the revised Certificate of Fitness.
“While we have identified what items are toxic, what we do not have is the information about the testing equipment or the testing regime and as a vessel manager it is crucial to have this information,” said Capt Patil.
Capt Patil and Mr Keffler** both voiced considerable concern regarding the availability of reception facilities for pre-cargo washes. Capt Patil said it was important for vessel managers to record and report insufficient facilities: “There is no point in just knowing about this. If there has to be a solution, it has to be a collective [discussion]. Then we can approach it through an industry body and try and resolve it.”
Mr Keffler said shippers are advised to go through their certificate of fitness (COF) and perform a gap analysis on carriage requirements for their cargoes. They may not necessarily have to amend their COF, but they do need to be aware that the method of segregating cargoes may likely be changed for some products on the COF.
IBC Code – ready or not, here it comes
Is the industry ready to cope with the revised IBC Code? In a survey on the subject conducted during a Riviera Maritime Media webinar titled Chemical tanker operations: gearing up for implementation of the 2021 Revision of the IBC Code, a slim majority (52%) were concerned or very concerned about a potential inability to comply with the implementation of the IBC 2021 revision by the 1 January 2021 deadline; 48% were neutral or only slightly concerned. Mr Keffler said it is important that shippers consider the changes that will take place and/or seek expert advice and work with classification societies.
Nearly all (97%) of those surveyed said there is a need to provide alternative compliance options to meet tank atmosphere testing requirements for enclosed spaces in the IBC code. The majority (78%) of respondents said they expect some negative commercial impact on operations with respect to the change in product carriage requirements.
Capt Patil said that vessel managers are well advised to continue to monitor regulatory changes and stay ahead of the curve, work with crew to ensure compliance on the ground and liaise with different stakeholders and regulatory bodies.
Captain Sanjay Patil has served at sea from junior officer to Master on product tankers, gas carriers and chemical carriers. In his current role at Eaglestar, he is part of the centre of excellence, and provides support and assistance to vessels (Chemical, CPP, Crude Oil, LNG) operating west of Suez (focusing on Europe). He is also a member of INTERTANKO’s Chemical Tanker, Gas Tanker and Vetting Committees.
**Mr Keffler joined INTERTANKO in September 2018 as the chemical manager. He acts as secretary for INTERTANKO’s Chemical Tanker Committee and Chemical Tanker Sub-Committee Americas.