Our Mission

The mission of ABS is to serve the public interest as well as the needs of our clients by promoting the security of life, property and the natural environment primarily through the development and verification of standards for the design, construction and operational maintenance of marine-related facilities.

Quality & Environmental Policy

It is the policy of ABS to be responsive to the individual and collective needs of our clients as well as those of the public at large, to provide quality services in support of our mission, and to provide our services consistent with international standards developed to avoid, reduce or control pollution to the environment. All of our client commitments, supporting actions, and services delivered must be recognized as expressions of Quality. We pledge to monitor our performance as an on-going activity and to strive for continuous improvement. We commit to operate consistent with applicable environmental legislation and regulations and to provide a framework for establishing and reviewing environmental objectives and targets.

Understanding
the Revisions to

MARPOL IBC

Annex II
and the

Code

A Guide for Owners

Copyright 2006 American Bureau of Shipping ABS Plaza 16855 Northchase Drive Houston, TX 77060 USA

Executive Summary
A number of very important recent regulatory changes affecting oil products tankers, chemical carriers, offshore supply vessels and tankers carrying noxious liquid substances and oil like substances take effect on 1 January 2007. The changes are wide ranging in their effect. This document is intended to assist owners/operators and designers of these ship types with the process of compliance by providing a synopsis of the changes and identifying practical options available to the owner and designer. ABS can assist the shipowner by providing advice on the substances that may be carried without changes to the ship or on the necessary steps to be taken for the re-certification of the ship. Where changes are required to continue carrying certain substances, ABS can provide advice and guidance to help the shipowner comply with the revised regulations.

ABS Guide to Owners Understanding the Revisions to MARPOL Annex II and the IBC Code

Contents
1. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4 2. Substance Re-classification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .6 3. Re-certification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8 4. Procedures & Arrangements Manual . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10 5. Capacity Limitations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11 6. Damage Stability and Tank Arrangements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .12 7. Tank Stripping Limits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .13 8. Discharge . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .16 9. Conversions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .17 10. Support Services . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .18

Appendices
Appendix 1: New Ships . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .20 Appendix 2: List of Re-classified Substances . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .21 Appendix 3: List of Substances to Which the IBC Code Does Not Apply . . . . . . . . . . . . . . . . . . . . . . . .24 Appendix 4: Ship Type Definition . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .25 Appendix 5: Frequently Asked Questions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .27

-----------------------------------------------------------------------------Disclaimer: This document has been developed to provide a general overview of the recent changes in the requirements of MARPOL Annex II and the IBC Code. This document is intended solely as guidance on the new requirements, and readers should refer to the applicable sections of MARPOL and the IBC Code as necessary. Users are also urged to consult with their local ABS engineering office should more detailed interpretations be required. Any variation between applicable regulations and the information provided in this document is unintentional, and, in the case of such variations, the requirements of the regulations govern. This guidance does not constitute advice by ABS and may not be relied upon to create a contractual right or benefit enforceable by any person.

ABS Guide to Owners Understanding the Revisions to MARPOL Annex II and the IBC Code

1. Introduction
Amendments to MARPOL Annex II and the International Bulk Chemicals (IBC) Code1 come into force on 1 January 2007. The requirements are applicable, to varying extents, to all new2 and existing ships carrying Noxious Liquid Substances (NLS) and oil-like substances which will be treated as NLS. The main technical change is that substances have been re-classified into new pollution categories. Some substances have been removed from the list of NLS, others have had their carriage requirements upgraded from Type 3 to Type 2 and others have been included in the list for the first time. This is critical since the carriage requirements are based upon the classification of the substance i.e. this change affects the substances that may be carried in particular ships. The impact of the re-classification may not be immediately apparent and ship modifications may be required if the vessel is to continue carrying the re-classified substances after 1 January 2007. Importantly there are a group of substances that may previously have been carried in a single hulled ship that now, because of the re-classification and application of IBC Code/MARPOL Annex II requirements, must be transported in double hulled chemical carriers. For example, a ship operator previously carrying Xylene in an oil tanker as an oil-like substance will not be able to do so as of 1 January 2007 since Xylene has been re-classified and its carriage is restricted to Type 2 chemical tankers. Type 2 classification requires that cargo quantities in any one tank are limited to 3,000 m3. and the ship, if less than 225m in length, will have to meet the more onerous extent of damage required by Type 2 classification. To continue carrying the same substances the ship may need to be modified. Ships operating in US waters carrying Annex II substances that are considered to be oil (petroleum, animal and vegetable) for the purposes of the Clean Water Act and OPA90 are still subject to the provisions of that domestic legislation. The US Coast Guard will be issuing an NVIC to cover the implementation of the revisions to the IBC Code and MARPOL Annex II. In addition, vegetable oils which were previously categorized as category D and therefore not covered by the IBC Code are now included in Chapter 17 as individual substances according to their unique name. As of 1 January 2007 these substances must now also be carried in double hulled chemical carriers. The revision to MARPOL Annex II also requires revised lower limits for the residue remaining within the tanks after stripping and has revised limitations on discharge of residues. An OSV should only carry substances listed in IMO Resolution A673(16)3. A673(16) is tailored for OSV operation and a final draft revision by IMO to harmonize it with the revisions to the IBC Code and MARPOL Annex II is scheduled to be approved by IMO in late 2006. For ships involved solely in domestic trades of noxious liquid substances and oil-like substances, shipowners and operators should refer to the relevant flag State for applicable requirements. Domestic trade is defined in MARPOL Annex II to mean a trade solely between ports or terminals within the State the flag of which the ship is entitled to fly, without entering into the territorial waters of other States.

ABS Guide to Owners Understanding the Revisions to MARPOL Annex II and the IBC Code

Operators of existing ships: 1. Must re-certify each ship for the regulated substances intended to be carried which may include more onerous extents of damage more efficient stripping systems and enhanced underwater discharge systems; 2. Must prepare, develop and obtain approval from the flag Administration, or ABS where authorized, for updated Procedures and Arrangements Manuals; 3. Must demonstrate that tank residues after stripping, comply with the reduced limits, as relevant; and 4. May consider conversion and equipment retrofit options to carry relevant substances which have had their carriage requirements upgraded or to expand the list of available substances that can be carried as of 1 January 2007. Builders of new chemical tankers and those involved in conversions to chemical tankers must re-assess current designs in light of the re-classification of substances taking into account the following, as relevant: 1. Assess the more onerous extent of damage requirements that may apply; 2. Determine if more efficient stripping systems may be needed to meet the new cargo residue and underwater discharge requirements; and 3. Verify arrangement requirements for compliance with upgrades from a Type 3 to Type 2 ship for certain substances. Comments relevant to new ships are noted in Appendix 1. The full text of the updated regulations can be found at: http://www.eagle.org/regulatory/newsroom.html#abs. The documents will also be made available via the ABS Rules Manager (subscription based): http://www.eagle.org/prodserv/applications/rulemanager/index.html

-----------------------------------------------------------------------------1 The revised MARPOL Annex II was adopted on 15 October 2004 as Resolution MEPC.118(52), and the 2004 amendments to the IBC Code were adopted on 10 December 2004 as Resolution MSC.176(79).

2 This includes ships currently under construction or modification and new contracts for construction after 1 January 2007. However, the regulations are applicable to varying extents and each changed requirement must be considered, e.g. tank residue limits after stripping are reduced depending on the substance and the ships date of build/conversion.

3 IMO Resolution A673(16), as amended Guidelines for the Transport and Handling of Limited Amounts of Hazardous and Noxious Liquid Substances in Bulk on Offshore Supply Vessels.

ABS Guide to Owners Understanding the Revisions to MARPOL Annex II and the IBC Code

2. Substance Re-classification
Substance categories were previously addressed in a five tier system (A,B,C,D and Appendix III). Under the revised MARPOL Annex II, this has been replaced by a new four tier system based on the Global Harmonized System (GHS): X Y Z OS Substances considered a major hazard Substances considered a hazard Substances considered a minor hazard Substances considered not to be a hazard to the marine environment

Each substance in the previous IBC chapters 17 and 18 has been re-categorized. In the process of re-classification the marine pollution hazards of each substance have been re-evaluated based on GHS and now include effects such as bio-accumulation, bio-degradation, acute toxicity, chronic toxicity, long-term human health effects and any possible effect on marine wildlife/habitats. A list of the substances that have been re-classified at the time of writing can be found in Appendix 2 of this document1. All substances listed in Chapter 17 of the IBC Code are subject to the new requirements. There are an additional 34 substances listed in Chapter 18 to which these regulations do not apply see Appendix 3 hereto. For substances that are not listed in either Chapter 17 or 18, and/or in MEPC 2/Circulars that may be issued2, the standard industry tripartite procedures, as allowed under the current MARPOL Annex II Regulation 6.3, (contact the relevant flag State for details) are to be used. This may be a lengthy administrative process and consequently has to be dealt with well in advance of loading a cargo to verify the suitability of the designated ship. Once this process is completed, an addendum to the Certificate of Fitness may be issued to allow the cargo to be carried. The practical result of the revisions to the list of NLS in Chapter 17 of the IBC Code is that a much broader range of substances will, in future, be required to be carried in chemical tankers. Specifically: Carriage of any oil-like substance in oil tankers (previously allowed in ships certified under MARPOL Annex I and subject to compliance with the damage stability requirements of the IBC or BCH Code) is no longer permitted unless the tanker is modified and certified to fully comply with the special and operational requirements associated with the new Categories of substances listed in the revised IBC Code. Vegetable Oils are now classified under the IBC Code and require a double hull tanker for their carriage3. Certain vegetable oils can be carried in Type 2 ships and other vegetable oils can be carried in double hull Type 3 ships see Table 3 of Appendix 4 hereto. For an existing ship, capacity restrictions will prevail as a result of cargoes previously carried in a Type 3 ship now being required to be shipped in a Type 2 ship. As a result of the additional damage stability requirements further capacity restrictions may develop.

As an aid to understanding the ship type requirements a note on the IBC definition is included in Appendix 4 hereto.

ABS Guide to Owners Understanding the Revisions to MARPOL Annex II and the IBC Code

Bio-Fuels Bio-fuels are currently under consideration by IMO as to their carriage and discharge requirements. Proposed guidance4 for the carriage of certain substances remains to be developed by IMO as follows: bio-fuels, bio-diesel, (source product) fatty acid methyl esters, B100 and ethanol, ethyl alcohol E100 are to be transported under the requirements of Annex II of MARPOL 73/78 and the IBC Code. certain blends of bio-fuels and base petroleum fuels can be carried under Annex I of MARPOL 73/78.

Shipowners and operators should contact the relevant flag State for further details.

-----------------------------------------------------------------------------1 MEPC is expected to approve a final list of Chapter 17 substances in October 2006 for adoption by IMO in December 2006. This Advisory will be updated at the soonest opportunity.

BLG.1/Circ.19 dated 20 June 2006 and BLG.1/Circ.19/Corr.1 dated 18 July 2006.

3 Vegetable oils carried in deep tanks or independent tanks in existing dry cargo ships have been legislated separately in MEPC 48(54) to allow them to continue carrying vegetable oils annotated with 2k in the IBC Code after 1 January 2007 on specially identified trades and where such oils are carried in deep tanks or independent tanks located no closer than 760 mm from the shell plating. Note MEPC.120(52)) was revised and published as resolution MEPC.148(54) - Guidelines for the Transport of Vegetable Oils in General Cargo Ships.

BLG 10/3/9 8 February 2006 - Evaluation of safety and pollution hazards of chemicals and preparation of consequential amendments.

ABS Guide to Owners Understanding the Revisions to MARPOL Annex II and the IBC Code

3. Re-certification
The substances that may be carried by a chemical tanker are defined by its Certificate of Fitness1. The original of this certificate, updated for the re-categorized substances, must be placed on-board the ship to which it relates by 1 January 2007. In line with the short-term transitional arrangements agreed at IMO, Table 1 shows how ABS will deal with the certification leading up to the effective date. Upon verification of compliance with the new requirements for the substances to be carried on-board, and where authorized by the flag Administration, ABS will re-issue certificates to vessels holding one or more of the following: International Certificate of Fitness for the Carriage of Dangerous Chemicals in Bulk applicable to all IBC Code certified chemical tankers carrying IBC Code Chapter 17 and, if appropriate, Chapter 18 substances; International Pollution Prevention Certificate for the Carriage of Noxious Liquid Substances in Bulk applicable to all ships, which may include gas carriers, carrying IBC Code Chapter 18 substances only under MARPOL Annex II; and Certificate of Fitness for the Carriage of Dangerous Chemicals in Bulk applicable to all BCH Code certified chemical tankers carrying IBC Code Chapter 17 and, if appropriate, Chapter 18 substances.

Note that when a substance is loaded prior to 1 January 2007 the classification at the time of loading remains legal until the substance has been unloaded and all operational requirements have been met. A ship may be denied port entry without the correct documentation. To assist owners obtain the new Certificate of Fitness, ABS has developed software to evaluate the different substance carriage requirements required in the IBC Code and MARPOL Annex II. Hence the local ABS Engineering Office can create the List of Substances and, where authorized, issue the Certificate of Fitness for any ABS class chemical tanker using the capacity, loading and pumping plans and the current Certificate of Fitness. The Certificate of Fitness can also be derived for non-ABS class ships that may be considered for transfer of class. ABS Assistance ABS can help shipowners and operators by: Determining the categorization of chemicals on an existing Certificates of Fitness under the new criteria. This needs to be completed before the Procedures & Arrangements Manual can be submitted; Issuing an amended List of Cargoes that may be carried; and Issuing a Certificate of Fitness if so authorized by the flag State.

-----------------------------------------------------------------------------1. The Certificate of Fitness is issued by either the flag State or the Classification Society acting as a Recognized Organization. The Classification Society must be authorized by the flag State for certification according to the IBC Code. ABS is currently authorized by over 70 flag States for IBC Code certification.

ABS Guide to Owners Understanding the Revisions to MARPOL Annex II and the IBC Code

Certification Scenario
Existing certificate valid until after 1 January 2007

Action Existing Certification

Existing certificate is valid only for cargoes lifted prior to 1 January 2007 and is no longer valid after discharge of those cargoes.

Action New Certificate*

Issue a new certificate with the same expiry date as the existing certificate so as to allow cargoes to be lifted on/after 1 January 2007.

Renewal survey after 1 August 2006 but before 1 January 2007

Extend the validity of the existing certificate to 1 January 2007 upon satisfactory completion of the renewal survey.+ Issue an interim certificate valid until 1 January 2007 upon satisfactory completion of the required survey.+ Issue an interim certificate valid until 1 January 2007 upon satisfactory completion of the revised initial survey.+

Change of Flag survey after 1 August 2006 but before 1 January 2007

Issue the new full term certificate valid from 1 January 2007 with an expiry date of 5 years after the renewal survey date.

Delivery of a new ship between 1 August 2006 and 1 January 2007

Issue the new full term certificate valid from 1 January 2007 with an expiry date of 5 years after the initial survey date.

+ Retain on-board until such time as cargoes lifted prior to 1 January 2007 have been discharged. * Revised certificate(s) can not be issued until a revised P & A Manual is submitted and approved, until any new or additional technical requirements that may be required as a consequence of re-categorized substances have been met and, if necessary, performance testing of the stripping system has been satisfactorily completed. Note: The certificates and surveys are those required by MARPOL Annex II, IBC, BCH, as appropriate. Table 1 - Certification Scheme for MARPOL Annex II and Revised MARPOL Annex II Requirements - MEPC.118(52)

ABS Guide to Owners Understanding the Revisions to MARPOL Annex II and the IBC Code

4. Procedures & Arrangements Manual

Existing vessels will require a revised Procedures and Arrangements (P & A) Manual to comply with the revised MARPOL Annex II requirements that enter into force on 1 January 2007. It is necessary to review the current Manual against the revised MARPOL Annex II to determine those sections that will require amendment, in particular with respect to the stripping requirements. The List of Substances is no longer required to be included in the Manual, but the List, with the category of substance, still needs to supplement the certificate. The revised and approved Manual is required to be placed on board on or before 1 January 2007. The relevant text from the updated MARPOL Annex II is as follows: Regulation 14 Procedures and Arrangements Manual 1. Every ship certified to carry substances of Category X, Y or Z shall have on board a Manual approved by the Administration. The Manual shall have a standard format in compliance with Appendix 4 to this Annex. In the case of a ship engaged in international voyages on which the language used is not English, French or Spanish, the text shall include a translation into one of these languages. 2. The main purpose of the Manual is to identify for the ships officers the physical arrangements and all the operational procedures with respect to cargo handling, tank cleaning, slops handling and cargo tank ballasting and deballasting which must be followed in order to comply with the requirements of this Annex. ABS Assistance ABS can review and, where so authorized, approve the P & A Manual upon verifying compliance with the revised requirements of MARPOL Annex II and the IBC Code. To help owners in compiling the P & A Manual a template is available from your local ABS Plan Approval office or from the ABS website at http://www.eagle.org/regulatory/newsroom.html.

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ABS Guide to Owners Understanding the Revisions to MARPOL Annex II and the IBC Code

5. Capacity Limitations
Although there is no specific design requirement within the IBC Code for cargo tank size there is an operational limitation on the amount of substance that can be loaded into a single cargo tank according to the ships designation as Type 1 or Type 2. (See Appendix 4 of this document.) This is applicable to new and existing chemical tankers. If the ship is to transport substances requiring a Type 1 or Type 2 ship, the quantity of substance per tank must be limited as indicated below (quoting from Chapter 16 of the revised IBC Code). There is no limit for Type 3 ships. 16.1 16.1.1 16.1.2 Maximum allowable quantity of cargo per tank The quantity of a cargo required to be carried in a Type 1 ship shall not exceed 1,250 m3 in any one tank. The quantity of cargo required to be carried in a Type 2 ship shall not exceed 3,000 m3 in any one tank.

A substance that was previously categorized for carriage in a Type 3 ship and is re-categorized for carriage in a Type 2 ship now has to comply with all requirements for Type 2 including the capacity limitations of Type 2. Ship owners may wish to consider tank re-configuration or conversion in order to maximize cargo carriage in particular tanks. There may be opportunities for conversion of existing double hull product carriers into chemical tankers. A sloshing assessment may be required to assess structural strength to withstand impact pressures in slack tanks. ABS Assistance ABS can review the cargoes to be carried and advise if there are any tank capacity issues according to the revised requirements of MARPOL Annex II and the IBC Code.

ABS Guide to Owners Understanding the Revisions to MARPOL Annex II and the IBC Code

11

6. Damage Stability and Tank Arrangements

The requirements for damage stability and cargo location have not been modified in the IBC Code. As a result of the substance re-categorization, it may be that, for certain cargoes, a Type 2 ship is required for transportation. Thus, as a Type 2 ship, damage to the engine room may also have to be considered along with damage to the aftermost cargo tank. Also the location of the cargo tank must be a minimum of 760 mm from the shell. (See Table 3 of Appendix 4 hereto for the definition of the double hull requirements, damage extent and parcel size limits for IBC Code ship types). The capacity limitations in section 5 above are likely to create additional damage stability considerations especially if slack tanks result. The resultant additional free-surface from slack tanks may create difficulties in ships complying with the existing requirements, especially if the ship has little margin in meeting the stability criteria on certain critical cases. ABS Assistance ABS can review the results of the damage stability analysis and the tank arrangements and advise on compliance with the revised requirements of MARPOL Annex II and the IBC Code. This needs to be completed before the P & A Manual can be submitted.

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ABS Guide to Owners Understanding the Revisions to MARPOL Annex II and the IBC Code

7. Tank Stripping Limits

Regulation 12 of the revised MARPOL Annex II requires that existing ships shall meet the following reduced tank residue criteria after stripping in order to prove the ship can achieve the carriage requirements for X, Y and Z substances: Ships built after 1 July 1986 (IBC) and before 1 January 2007: Category X and Y substances 100+50 liters tolerance Category Z substances 300+50 liters tolerance Ships built before 1 July 1986 (BCH): Category X and Y substances 300+50 liters tolerance Category Z substances 900+50 liters tolerance Other ships carrying Z type substances listed in Chapter 18 are to be empty to the maximum extent (and hence do not need to perform a tank stripping test).

Table 2 summarizes these requirements. The +50 liters in the criteria above is an allowable tolerance which should not be interpreted as a standard relaxation. The residue includes all substance remaining in the tank, pump and associated piping up to the manifold. A performance test shall be carried out, the details for which are specified in Appendix 5 of the revised MARPOL Annex II and may be summarized as: 1. Clean the tank and piping prior to testing. 2. Ensure the ship trim (maximum 3 degrees by the stern) and heel (maximum 1 degree) give favorable drainage to the suction point in the tank. 3. Fill the tank with water to the depth representing the normal end of unloading condition i.e. the point at which stripping is usually commenced. 4. Provide 100kPa (1 atmosphere) back pressure (usually a constant pressure valve) at the unloading manifold see Figure 1. 5. Discharge and strip the tank according to the designated procedure. 6. The time taken for the stripping procedure is to be recorded. 7. Close the manifold valve and open all valves and remove drain plugs. 8. The residue is then collected and measured. 9. The stripping performance details are to be entered in the P & A Manual. It may be necessary or desirable to conduct more than one test. For groups of tanks that are identical in size, internal structure, pump and sump locations, types and capacities of pumps and stripping equipment and methods and that carry the same substances, only one tank (furthest from the manifold) needs to be tested. The residue criterion for the highest pollution category to be carried in the tank(s) shall be applicable. Depending on the substances and ships date of build/conversion, the amended IBC Code requires more stringent stripping arrangements. As a result certain substances previously certified for carriage will be disqualified unless the ship upgrades its stripping arrangements. The work involved may include redesign and re-approval of the cargo stripping system. Obtaining timely delivery of stripping equipment may be an issue.

ABS Guide to Owners Understanding the Revisions to MARPOL Annex II and the IBC Code

13

Owners and operators of OSVs should note that there are no requirements for stripping under IMO Resolution A.673(13), as amended, because residues of substances allowed to be carried by A.673(16) must be discharged to reception facilities. ABS Assistance ABS can witness the tests and advise on compliance with the revised requirements of MARPOL Annex II and the IBC Code. The owner should be satisfied that the quantity of residue does not exceed the required limits before requesting class attendance to witness such tests.
Test Hose or Pipe

Flange Manifold Valve Constant Pressure Valve Set at 100 kPa Manifold Valve Flange

> 10m

Cargo Piping

Cargo Piping

Pressure Gauge Ships Deck Ships Side Ships Deck Ships Side

Figure 1 Suggested back pressure manifold arrangements

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ABS Guide to Owners Understanding the Revisions to MARPOL Annex II and the IBC Code

Requirement Pollution Category Maximum Residue After Stripping X < 1/7/86 (BCH Ships) X < 1/7/86 (BCH Ships) X
[1] > 1/1/2007 (IBC Ships) [1] [1]

Current MARPOL Annex II

Revised MARPOL Annex II (1/1/2007)

A
Major Hazard

B
Hazard

C
Minor Hazard

D
Recognizable Hazard

X
Major Hazard

Y
Hazard

Z
Minor Hazard

Ship Details IBC/BCH 300 +50* liters# 100 +50* liters# 900 +50* liters# 300 +50* liters# No minimum 300 + 50* liters# 100 + 50* liters# 75 liters# 300 + 50* liters# 100 + 50* liters# 75 liters# 900 +50* liters# 300 +50* liters# 75 liters# Other If Z and in IBC Ch.18, empty to maximum extent. If OS and in IBC Ch.18, not applicable

Not Applicable

No minimum

Not Applicable
* performance test tolerance

# performance test required

Discharge Any residue to reception facility, except 0.1% by weight or below. Any residue to reception facility, except 0.1% by weight or below.

Concentration

<1 ppm

< 10 ppm

< 1 part NLS to 10 parts water

Any residue to sea

Any residue to sea

En Route Piping Outlet Location Nearest Land

> 7 Knots Underwater Not Applicable

> 7 Knots Underwater (not mandatory for ships with X [1] < 1/1/2007 carrying Cat. Z) > 12 nautical miles and water depth > 25m

> 12 nautical miles and water depth > 25m X

[1]

- keel laying date or commencement date of conversion to a chemical carrier.

Table 2 - Comparison of current MARPOL Annex II and Revised MARPOL Annex II Requirements - MEPC.118(52)

ABS Guide to Owners Understanding the Revisions to MARPOL Annex II and the IBC Code

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8. Discharge
The at-sea discharge limits of more than 12 miles from land in depth of water exceeding 25 meters at a speed greater than or equal to 7 knots remain. The requirements are summarized in Table 2 herein. Underwater discharges are required to be fitted. Because of the reduced stripping limits and cargo re-categorization, any residue of substance Y and Z can be discharged to the sea. However, residues for highly viscous and solidifying category Y substances must be discharged to a reception facility. The residue for category X substances must also be discharged to a reception facility and only 0.1 percent by weight or less can be discharged to the sea. Existing chemical ships authorized to carry A, B and C substances under the previous IBC Chapter 17 are already fitted with underwater discharge outlets. However existing ship Type 3 chemical ships carrying category D substances will have a substantially reduced cargo list if no modifications are carried out. An example of the changes is the need to retrofit underwater discharges in order to fulfill the carriage requirements for sodium hydroxide (caustic soda has been re-classified to category Y). Owners and operators of OSVs should refer to the relevant flag State for possible exemptions on the underwater discharge requirements since A673(16), as amended, does not allow discharge to the sea. Residues of substances allowed to be carried by A.673(16) must be discharged to reception facilities. ABS Assistance ABS can review the list of cargoes to be carried and the discharge arrangements currently installed and advise on compliance with the revised requirements of MARPOL Annex II and the IBC Code. Where material changes are necessary, and the owner wishes to continue carriage of certain substances then ABS will require: submittal of appropriate plans to approve the changes proposed; and a survey of the ship to verify the work carried out.

Any other statutory certificates that may be affected by the changes will be dealt with simultaneously.

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ABS Guide to Owners Understanding the Revisions to MARPOL Annex II and the IBC Code

9. Conversions
All actions discussed in Sections 2 through 8 herein must be completed prior to to 1 January 2007 if the vessel is to continue hauling NLS (which will include oil-like substances) on and after that date. It is for owners to consider the viability of converting a ship so that it can continue in the current trades which the ship is engaged in and/or to widen the range of chemical cargoes that can be carried. The situation for each ship type is slightly different in terms of upgrading its capabilities to meet the more stringent environmental and safety requirements of the IBC Code and MARPOL Annex II. For owners with a double hull (MARPOL Annex I Reg. 13F) oil tanker that also complies with the IBC Code as a Type 3 there are two options: flag State exemptions under MARPOL Annex II Regulation 4.1.3 may be granted for carriage of identified vegetable oils. The relevant flag State should be contacted for the initial exemption of the ship from a Type 2 chemical tanker. upgrade to carry Type 2 chemicals. This is dependant on the configuration of the ship and the current certification the local ABS plan approval office will be pleased to provide guidance on specific ships. Compliance with the criterion in Table 1 of Appendix 4 hereto for double side width, double bottom depth, extent of damage requirements and parcel sizes will be required. (See also Section 6 herein.)

Fire Fighting Most chemical carriers are fitted with deck foam systems suitable for low flash point cargoes but certain specialized trade ships with high flash point cargoes such as a molten sulphur or sulphuric acid do not have them fitted. Where it is intended to carry alternative cargoes it is important also to review the fire fighting systems required. Tank Ventilation Certain substances have specific venting requirements e.g. P/V valves required rather than open venting. The venting requirements for each substance likely to be carried should be evaluated. ABS Assistance ABS can review the list of cargoes to be carried and provide guidance on possible conversion solutions to comply with the revised requirements of MARPOL Annex II and the IBC Code. Where material changes are necessary, and the owner wishes to continue carriage of certain substances, then ABS will require: submittal of appropriate plans to approve the changes proposed; and survey of the ship to verify the work carried out.

Any other statutory certificates that may be affected by the changes will be dealt with simultaneously.

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10. Support services

Through its affiliate ABS Consulting, ABS can offer the following services for any owner or operator to meet the revised requirements of MARPOL and the IBC Code, regardless of the class of the ship: 1. Review and revise P & A Manuals, verify that the manuals and the software packages are compatible, and submit the revised manuals for class and regulatory approval. (Section 4) 2. Verify capacity limitations of potential cargoes. (Section 5) 3. Confirm that any changes resulting from these modifications to the cargo classification do not adversely affect the damage stability/tank arrangements of the ship, and if they do, provide guidance on possible alternative economical means to modify the ship to carry these cargoes. (Section 6) 4. Provide technical review of existing systems and provide suggested modifications intended to optimize these systems, as well as providing on scene representation to assess the condition of the ship for compliance and to verify that all modifications are accurately performed and meet the owners intent. (Sections 7 and 8) 5. Perform additional services that may be required when it is apparent that, to best comply with the new MARPOL and IBC requirements, it would be necessary to modify the ship if it is to continue its operational life. (Section 9) a. Engineering Technical Support These additional services may include but are not be limited to: Developing bid documentation and providing assistance in the review of proposals from shipyards Reviewing drawings and technical data to owners specifications Interfacing with the owner, builder and regulatory authorities Advising owners of findings through regular communication b. On-site Representation This may include but shall not be limited to: Inspecting hull, machinery, equipment and electrical systems and witnessing specified testing Inspecting surface preparations and monitoring the application of coatings Witnessing of and attendance during dock and sea trials Coordinating inspection teams Inspecting and witnessing testing of material and/or equipment at suppliers facilities For further information on the services of ABS Consulting relative to Chemical Carriers and support in meeting these upcoming requirements please contact Thomas M. Nolan, Director, Maritime Services, ABS Consulting, 281-673-2740, or at tnolan@absconsulting.com.

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Appendices
1. New ships 2. List of re-classified substances 3. List of substances to which the IBC Code does not apply 4. Ship type definition 5. Frequently Asked Questions

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Appendix 1 New Ships

The requirements in the revised IBC Code and MARPOL Annex II regulations are also applicable to ships under construction and to new contracts placed after 1 January 2007. The following comments are intended to address considerations for new ships: Capacity Limitations Ship designers may wish to re-assess the capacities of the tank arrangements for the designs currently offered to prospective owners. It is likely that some configuration changes will result in order to offer designs that more closely meet the owners commercial needs. Damage Stability The designer may need to review the current damage stability compliance for existing designs and consider tank re-configuration where the compliance maybe jeopardized as a result of the cargo re-categorization in order to avoid the issues existing ships are facing. Tank Stripping Limits The limits are considerably reduced in MARPOL Annex II compared to the previously allowed residues. This reflects the advances made by the industry in tank stripping. Regulation 12 of the amended MARPOL Annex II requires that new ships contracted after 1 January 2007 shall have no more than 75 liters of cargo residue after stripping. There is no tolerance applicable. This includes the tank and its associated piping up to the manifold. A performance test shall be carried out in a similar manner to existing ships. (See Section 7 and Table 2) Fire Fighting The designer should review the substance fire fighting requirements. Tank Ventilation The designer should review the substance tank venting requirements. Discharge Underwater discharges are required for all new ships intended to carry X, Y or Z substances.

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Appendix 2 List of Re-classified Substances

Comparison of Current and Revised Pollution Categories and Ship Types for Principal Substances+ Pollution Category
Current Acetic Acid Acetone Acrylonitrile Benzene Coconut Oil Coconut Oil Fatty Acid Dodecyl Alcohol Ethanolamine Ethyl Acetate Ethyl Acrylate Ethyl Alcohol Ethylbenzene Ethylene Cyanohydrin Ethylenediamine Ethylene Dichloride Ethylene Glycol Fatty Acid (Saturated C13+) Formic Acid Furfural Furfuryl Alcohol Heptene (All Isomers) Hexamethylene Diamine Solution Hexane (All Isomers) Hexanol Hexene (All Isomers) Isopropyl Alcohol Methyl Alcohol Methyl Ethyl Ketone Methyl Isobutyl Ketone Methyl Methacrylate D III B C D D B D D A III B (D) C B D III D C C C C (C) D (C) III D III D D Revised Z Z Y Y Y Y Y Y Z Y Z Y Y Y Y Y Y Y Y Y Y Y Y Y Y Z Y Z Z Y

Product

Ship Type
Current 3 Chapter 18 2 3 Chapter 18 Chapter 18 3 3 Chapter 18 2 Chapter 18 3 3 2 2 Chapter 18 Chapter 18 3 3 3 3 3 3 Chapter 18 3 Chapter 18 Chapter 18 Chapter 18 Chapter 18 2 Revised 3 Chapter 18 2 3 2(k)* 2 2 3 3 2 Chapter 18 2 3 2 2 3 2 3 3 3 3 3 2 3 3 Chapter 18 3 3 3 2

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Appendix 2 Continued
Product
Methyl Tert-Buytl Ether (MTBE) Molasses Nonene (All Iisomers) Octanol (All Iisomers) Olefins (C5-C7) ** Olefins (C5-C15) ** Olefins (C13+, All Isomers) Palm Kernel Oil Palm Oil Palm Olein Palm Stearin Paraffin Wax Pentene (All Isomers) Perchloroethylene Phenol Phosphoric Acid Pine Oil Potassium Hydroxide Solution Propyl Benzene (All Isomers) Propylene Glycol Rapeseed Oil Sodium Hydroxide Solution Soyabean Oil Styrene Monomer Sulphuric Acid Sunflowerseed Oil Tall Oil, Crude *** Tall Oil, Distilled *** Tall Oil Fatty Acids *** Tall Oil Pitch *** Tallow D D D D D III C B C D C C A III D D D B C D (C) (C) (C)

Pollution Category
Current D III B C C B Revised Z OS Y Y Y X Y Y Y Y Y Y Y Y Y Z X Y Y Z Y Y Y Y Y Y Y Y Y Y Y

Ship Type
Current Chapter 18 Chapter 18 3 3 3 3 Revised 3 Chapter 18 2 2 3 2 2 Chapter 18 Chapter 18 Chapter 18 Chapter 18 Chapter 18 3 3 2 3 3 3 3 Chapter 18 Chapter 18 3 Chapter 18 3 3 Chapter 18 3 3 2 2(k)* 2(k)* 2(k)* 2(k)* 2 3 2 2 3 2 3 3 Chapter 18 2(k)* 3 2(k)* 3 3 2(k)* 2 2 2 2 Chapter 18 2(k)*

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Appendix 2 Continued
Product
Tetrahydrofuran Toluene Toluene Diisocyanate Trichloroethylene Triethanolamine Urea/Ammonium Nitrate Solution Urea Solution Vegetable Acid Oils*** (m)**** Vegetable Fatty Acid Distillates*** (m)**** Vinyl Acetate Xylenes C C

Pollution Category
Current D C C C D D III Revised Z Y Y Y Z Z Z Y Y Y Y 3 3

Ship Type
Current 3 3 2 3 3 Chapter 18 Chapter 18 Revised 3 3 2 2 3 3 3 2 2 3 2

+ Information provided by International Parcel Tankers Association (IPTA) based on cargoes identified by owners as of interest on account of their volume or frequency of liftings. * The footnote (k) by ship type in Chapter 17 denotes those products whose carriage might be subject to regulation 4.1.3 of Annex II of MARPOL. ** Pollution category and ship type in accordance with BLG.1/Circular 19 dated 20 June 2006. *** Pollution category and ship type in accordance with the IMOs Evaluation of Safety and Pollution Hazard Working Group session 12 report (ESPH 12) subject to formal approval by the Marine Environment Protection Committee. **** The footnote (m) by the product name denotes that such product must derive from vegetable oils specified in the IBC Code. Products with underlined text indicate ship type will change.

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Appendix 3 List of Substances to Which the IBC Code Does Not Apply

Chapter 18
Substance
Acetone Alcoholic beverages, n.o.s. Apple juice n-Butyl alcohol sec-Butyl alcohol Clay slurry Coal slurry Diethylene glycol Ethyl alcohol Ethylene carbonate Glucose solution Glycerine Glycerol monooleate Hexamethylenetetramine solutions Hexylene glycol Isopropyl alcohol Kaolin slurry Magnesium hydroxide slurry N-Methylglucamine solution (70% or less) Methyl propyl ketone Molasses Noxious liquid, (11) n.o.s. (trade name ...., contains ....) Cat. Z Non-noxious liquid, (12) n.o.s. (trade name ...., contains ....) Cat. OS Polyaluminium chloride solution Potassium formate solutions Propylene carbonate Propylene glycol Sodium acetate solutions Sodium sulphate solutions Sulphonated polyacrylate solution Tetraethyl silicate monomer/oligomer (20% in ethanol) Triethylene glycol Vegetable protein solution (hydrolysed) Water

Category
Z Z OS Z Z OS OS Z Z Z OS Z Z Z Z Z OS Z Z Z OS Z OS Z Z Z Z Z Z Z Z Z OS OS

OS = not regulated by MARPOL II Z = regulated by MARPOL II n.o.s. = not otherwise specified and is used to determine how pollution hazard only mixtures are to be annotated. The component of the mixture that is assessed in accordance with MARPOL Annex II procedures and found to provide the greatest pollution potential (X, Y, Z) should be specified following the word Contains in the Shipping Name. For example, if the trade name of a substance is IMO 1234 and it contains the component Calcium long-chain alkyl salicylate (C13+) which has the greatest pollution potential, then the correct product name would be Noxious liquid, N.F (5) n.o.s. (IMO 1234 contains ., Calcium long-chain alkyl salicylate (C13+)) ST. 2, Cat. Y. Therefore, a Type 2 ship certified to carry n.o.s. 5 products can carry IMO 1234 without concerns as to fire, toxicity and other safety hazards as it is a pollution category only.

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ABS Guide to Owners Understanding the Revisions to MARPOL Annex II and the IBC Code

Appendix 4 Ship Type Definition

The IBC Code defines the ship types and survivability requirements in Chapter 2. The ship types are in a hierarchy of containment according to the safety and environmental hazard assigned to the substance to be carried, e.g. Type 1 offering the highest level of containment to the cargo and Types 2 and 3 having progressively lower containment requirements. The containment requirements consider the extent of damage: to the ship from outer hull penetration due to collision and grounding. Hence the further the inner hull from the outer shell the greater the protection afforded. Ship Types 1 and 2 have limits specified on double side width and double bottom width. Ship Type 3 does not, except for the carriage of vegetable oils. If carriage of oil cargoes is also required, a ship Type 3 will require compliance with MARPOL 73/78 Annex I Reg. 13G and hence these limits are applied for double side width and double bottom width (a lesser standard than for Type 2). along the length of the ship. The greater the extent of damage considered, the greater the protection afforded. The greater the size of ship, the greater extent of damage can be sustained and thus the greater degree of protection is afforded.

Further hazard control is applied by limiting the parcel size of cargoes hence, the greater the hazard, the smaller the parcel size allowable in any one tank: Type 1 - 1,250 m3 Type 2 3,000 m3 Type 3 no limit

Chemical tankers can offer a variety of degrees of protection e.g. centre tanks of a double-hulled ship can be designated suitable for Type 1 cargoes and the cargo wing tanks (for cargo other than that required to be inboard of the side shell) may offer suitable protection for either Type 2 or Type 3 cargoes.

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Double Side Width Type 1

B/5 or 11.5 m whichever is less At least 760 mm

Double Bottom Depth

B/15 or 6 m at CL. whichever is less but not less than 760 mm B/15 or 6 m at CL. whichever is less but not less than 760 mm

Damage Extent
Damage anywhere in length Length >150 m damage anywhere in length Length < 150 m damage anywhere in length except ER bulkhead

Parcel Size Maximum

1,250 m3

3,000 m3

Type 2

a.

a.

Length > 225 m damage anywhere in length Length > 125 m but < 225 m damage anywhere in length except including ER bulkheads Length <125 m damage anywhere in length except machinery space

No limit

Type 3

a. An administration may permit some vegetable oils (as indicated with 2(k) in column e of IBC Code Chapter 17) to be carried in Type 3 chemical tankers, except that the entire cargo block length must then be protected by double hulls that comply with the following dimensions; 760mm wing tank width, and B/15 or 2 m double bottom height, whichever is lesser but not less than 1 m. Table 3 IBC Code ship type definition

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Appendix 5 Frequently Asked Questions

Question: The Procedures & Arrangement Manual will need to be updated and approved for the MARPOL Annex II Regulations that enter into force 1 January 2007. What can ABS do to assist in gaining the necessary flag State approval of the revised Manual? Answer: ABS has taken several steps to assist owners and operators to gain approval of the revised Manual. All the ABS engineering offices around the world have established programs to advise owners and to expedite review and, where authorized by the flag State, approve the Manuals. It is recommended that owners follow the instructions contained in the ABS P & A template so that all issues are addressed prior to submitting the Manual for review. In particular, owners should note that the List of Cargoes is no longer required to be included in the Manual, but still needs to supplement the certificate. Hence, the NLS including condition of carriage (tank number, etc.) and pollution category are to be specified on the revised NLS Certificate of Fitness. In preparing your Manuals, it is recommended that you review the substances to be carried and any updates to their carriage requirements by comparing the revised IBC Code Chapter 17 and 18 lists with your current cargo lists. Since the IMOs cargo re-classification process has increased the protection requirements for most substances, many cargoes can now not be carried unless all the requirements of the revised IBC Code are met. Substances listed in Chapter 18 can be carried without complying with the IBC Code provisions but, for most substances, the revised MARPOL Annex II applies. This list is much shorter than before. The list of Type 3 substances is also much shorter. Many substances now require a Type 2 ship. Many substances also have increased carriage requirements for ventilation and fire fighting. Owners should also pay particular attention to the changes in stripping requirements. All ships carrying Category X, Y or Z substances are now required to conduct stripping tests which are to meet reduced limits. And all ships carrying Category X, Y or Z substances must now meet revised discharge requirements. The revised NLS Certificate will be issue after the P & A Manual review is satisfactorily completed. Question: What is the stripping limit for a ship that carries a category Z cargo that is listed in Chapter 18? Answer: If a category Z substance is also listed in Chapter 18 of the revised IBC Code there is no specific stripping limit if the ship is built before 1 January 2007, except that the tanks is to be emptied to the maximum extent possible. For ships contracted on/after 1 January 2007, the stripping limit is 75 liters.

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Question: Subject Type 3 vessels carry vegetable oils what is needed to comply with the new requirements? Answer: After 1 January 2007 vegetable oils will be required to be carried in chemical tankers complying with the revised IBC Code as a Ship Type-2 (double hull). A flag Administration may allow identified vegetable oils (indicated with 2 (k) in ship type in Chapter 17 of the Revised Code) to be carried in Ship Type-3 chemical tankers provided the entire cargo block length is protected by double hulls that comply with following dimensions: 760mm wing tank width, and B/15 or 2m bottom height, whichever is the lesser but not less than 1m. If the vegetable oils are now listed as 2k in the revised IBC Code then, if not already double hulled, the ship will need to be converted to continue carrying the listed vegetable oils.

Question: With reference to Resolution MSC. 176 (79), do vessels need to comply with the new IBC code for carriage of Xylenes, particularly since the COT coating (EPICON T 500) is compatible for Xylenes? Answer: Since Xylenes are listed in Chapter 17 of the new IBC Code, the general requirement and special requirements of the new Code are to be complied with.

Question: Since the adoption of the new IBC in December 2004 there are approximately 200 additional chemicals that may be carried which do not show up in the 2007 IBC Code. How can I get a list of authorized cargoes based on the 2007 IBC Code. Answer: After adoption of the revised IBC Code, IMO continued to evaluate existing and new substances which are identified in BLG.1/Circ 19. This Circular together with the results of IMOs Working Group on the Evaluation of Safety and Pollution Hazards (ESPH 12) was to be reviewed and approved at MEPC 55 in October 2006. A complete list will be made available soonest thereafter by the IMO. ABS will update this advisory as new categorizations become available.

Question: Stripping tests were conducted two years ago and witnessed by ABS is it necessary to repeat the tests? Answer: If the previous tests confirmed that the revised stripping limits are complied with and an adequate sample of tanks was covered, there is no need to repeat the tests for the subject ship. It is important that the test results are recorded in the revised P & A Manual.

Question: The IBC certificate was renewed for the subject vessel on 6th July, 2006 based on the revised cargo categorizations. All the cargoes mentioned in the intended cargo list are characterized as X/Y/Z/OS and not as A/B/C/D. Can the subject vessels load Type 2 cargoes for the remainder of 2006? Answer: The subject vessel can carry the ship Type 2 cargoes for the period specified and A/B/C/D cargoes loaded prior to 31 December 2006 can remain onboard after that date until they are discharged.

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