Keeping up with regulations as IBC code implementation looms

Intertanko chemical manager and regional manager for the Americas, Patrick Keffler and Eaglestar Marine Holdings head of customer relationship management Captain Sanjay Patil laid out some of the major changes set to be rolled out in the revised Internatonal Bulk Chemical (IBC) code.

Chapter 21 of the code deals with carriage requirements. 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.

Two major changes are updating ship types which impacts where products can be carried on a tanker and the vapour detection requirements, specifically which products have picked up toxicity (T) ratings.

Over 400 products in Chapter 17 have T-ratings with 236 new entries on the list, and 101 products will now require emergency equipment on board vessels carrying them.
Mr Keffler said that UN scientific advisory panel Joint Group of Experts on the Scientific Aspects of Marine Environmental Protection (GESAMP), through IMO’s Evaluation of Harmful Sustances 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.

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.

Captain 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 existing issues with regards to toxicity testing practices, Mr Patil said.

“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.”

Captain Patil and Mr Keffler both voiced considerable concern, as did 51% of webinar attendees, regarding the availability of reception facilities for pre-cargo washes. Another 23% of attendees said they were “extremely concerned” about the issue, putting high levels of concern about the issue in the majority at nearly three quarters (74%) over the total of those who felt moderate to no concern at 26%.

Captain Patil said it is 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 certifcate 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.

A slim majority – 52% – of attendees were concerned or very concerned about their 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 delve into the changes that will take place and/or seek expert advice and work with classification societies.

Nearly all (97%) of webinar attendees said there is a need to provide alternative compliance options to meet tank atmosphere testing requirements for enclosed spaces in the IBC code, and the majority (78%) of respondents said they expect some negative commercial impact on operations with respect to the change in product carriage requirements.

Ultimately, Captain Patil said vessel managers are well advised to continue to monitor regulatory changes to stay ahead of the curve, work with the crew to ensure compliance on the ground and liaise with the different stakeholders and regulatory bodies as “these are practical issues and ongoing”.

The amendments to the IBC Code have now been formally accepted and will enter into force on 1 January 2021.

You can view this webinar and all of the webinars from Riviera’s Tanker Shipping & Trade Webinar Week, in full, in our webinar library.

And you can sign up to attend our upcoming webinars on our events page.