The IMO is reassessing carriage requirements for products listed in the IBC Code. This means the current list of cargo with the Certificate of Fitness will change for chemical tankers. The amendments are expected to take effect 1 July 2020, subject to approval. This news helps owners consider early actions.
Relevant for shipyards, design offices, flag states and ship owners/managers of chemical tankers.
The modified IBC Code – ensuring consistency
During the 2004 amendments to MARPOL Annex II and the IBC Code, which introduced new pollution categories, all existing products were assessed based on pollution aspects only. Due to time constraints, it was decided not to apply the safety criteria at the time. As a consequence, we currently have a two-tier IBC Code product list, where products after 2004 have been assessed differently and, in most cases, more strictly than previously assessed products. To close this gap, it was later decided to also reassess pre-2004 products using the new criteria given in chapter 21 of the IBC Code.
However, during this process it was soon recognized that before starting the reassessment of each individual product, a fine tuning of chapter 21 was necessary, especially for the ship type and tank type criteria. The revised chapter 21 was finalized in January 2017 and is subject to approval at MSC and MEPC in mid-2017. The next step is now to reassess all the products by applying the revised criteria. The product assessment is expected to be finalized in 2018, with entry into force on 1 July 2020 at the earliest.
Be prepared for the new restrictions
The biggest implication is assumed to be for products changing their ship type or tank type, particularly if changing to Ship Type 1 and/or Tank Type 1G (independent tanks), as such tonnage is somewhat limited. There are also volume restrictions for Ship Type 1 and 2 cargoes, which, in order to better utilize the tank capacity, may favour smaller and multiple tanks for products given a stricter ship type.
In addition to above, there are also a considerable number of products (+200) not currently deemed as toxic but which now will be classified as such. This typically implies additional requirements for toxic vapour detection, cargo tank vent position, increased P/V (pressure valve) opening set point, cargo and vent piping systems, use of stern line arrangements, and the cargo tank location relative to oil fuel tanks. For most of these requirements, compliance may be achieved with minor modifications, but for cargo tanks located adjacent to fuel oil tanks, compliance may not be feasible, further reducing the range of products which may be carried in these tanks.
The implication for a specific vessel will depend of the design, arrangement and equipment of the vessel.
Prior to the entry-into-force date, all chemical tankers will be provided with a new Certificate of Fitness including a new List of Products based on the revised requirements. The new certificate will take effect and supersede the existing certificate on the entry-into-force date.
We urge owners of chemical tankers to be proactive and map in due time the impact for their fleets in case any modifications are needed, taking into consideration charter parties and cargoes of interest.
As the revised carriage requirements are more or less decided and only minor adjustments may be anticipated, DNV GL is already capable today, upon request, of assisting our customers in predicting the impact for any vessel classed with DNV GL where we have issued the Certificate of Fitness. This will be done by preparing a GAP report showing which cargoes may be lost or gained, and in which tanks.