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ESPH 18 – a report from the IMO Working Group on the Evaluation of Safety and Pollution Hazards

INTERTANKO participated in the 18th Session of the IMO Working Group on the Evaluation of Safety and Pollution Hazards (ESPH 18) this week, represented by INTERTANKO’s Senior Manager, Vetting & Chemical, Ajay Gour.

The meeting was chaired by David MacRae of the UK and was attended by delegations from 18 countries (Argentina, Belgium, Finland, France, Germany, Greece, Japan, Liberia, Marshall Islands, Netherlands, Nigeria, Norway, Singapore, Spain, Sweden, South Africa, United Kingdom, United States) and eight non-governmental organisations (International Association of Classification Societies (IACS), International Chamber of Shipping (ICS), International Association of Independent Tanker Owners (INTERTANKO), Dangerous Goods Advisory Council (DGAC), International Association of Ports and Harbours (IAPH), International Parcel Tankers Assoc (IPTA), European Chemical Industry Council (CEFIC), Oil Companies International Marine Forum (OCIMF)).

Agenda items discussed included:
The evaluation of new products and new cleaning additives
ESPH evaluated and approved seven new products for inclusion in List 1 (All Countries, No Expiry date) of the MEPC.2/Circ. Some of these products were approved with minor corrections to their submissions.

The Group also considered 25 cleaning additives which had been presented for evaluation. All 25 cleaning additives met the criteria outlined in MEPC.1/Circ.590 and these chemicals can be used as of now.

The Group was also informed that the trade names of two existing cleaning chemicals had changed and this change will be reflected in the list when it is published in December.

Review of MEPC.2/Circular – Provisional classification of liquid substances transported in bulk and other related matters
New Mixtures for entry into List 3 of the MEPC.2/Circ were reviewed by ESPH. As this review was of confidential Mixture information, it was conducted only by member states. Non-governmental attendees were asked to leave the meeting during this review. The final results were later shared with all attendees.

Review of MEPC.2/Circ.17 on the Provisional Classification of Liquid Substances Transported in Bulk – list of proposed changes to MEPC.2/Circ.17
ESPH undertook a review of a draft version of MEPC.2/Circ.18 which is scheduled to be published on 17 December 2012.

List 1
MEPC.2/Circ.18 List 1 will include some additional updated information column “i” (Electrical Data) that was missing on the previous review of this data. These products will just have columns i’, i’’, i’’’ shaded in grey to indicate those changes.

Finland submitted paper ESPH 18/4/8 requesting the addition of 3 products to Annex 11 of the MEPC.2/Circ. which is the Bio-Fuel list and to add 3 bio-fuel blends to List 1 of the MEPC.2/Circ.

During discussions of this paper, Finland mentioned these were needed to be able to blend these products with petroleum at less than 25% to carry the blend as Annex I.

ESPH agreed to add the bio-fuels to Annex 11, but did not agree to adding the blends to List 1. If Finland requires the bio-fuel blends to carry as Annex II chemicals then they will have to prepare a tripartite agreement for the blend.

The products being added to MEPC.2/Circ.18 Annex 11 are as follows:

  • tert-Amyl ethyl ether
  • renewable naphtha
  • renewable aviation fuel


Tripartite agreements

It was agreed that the following products currently listed as tripartite agreements in MEPC.2/Circ.17 will be removed from the list as their expiry date has been reached and no submissions have been made for review to make them permanent:

  • CaCl2 ‘Kill Pill’
  • EB-8061
  • EB-8246

Further, the following List 3 products will also be removed from the list due to the submission papers related to these products being withdrawn on the basis of a lack of information:

  • AMINE DCT
  • Epoxy Resin XZ-92742

Consideration of the outcome of the most recent session of GESAMP/EHS
Dr Tim Bowman, Chairman of the Group of Experts on the Scientific Aspects of Marine Environmental Protection’s (GESAMP) Working Group on the Evaluation of the Hazards of Harmful Substances Carries by Ships (GESAMP/EHS) could not attend the meeting of ESPH-18. The Secretariat (Ken McDonald) reviewed the report of GESAMP (
BLG.1-Circ.34) and noted that 9 new products were reviewed at the GESAMP meeting in June 2012 which were added to the EHS list.

It was noted also that there was an ongoing review of 40 products in the EHS list which has resulted in hazard profiles changing for 18 products.

The next GESAMP Meeting has been scheduled for 15-19 April 2013 and the submission deadline is Friday March 8, 2013.

Matters arising from FP 55
As a result of the changes being considered by the Fire Protection Sub-committee (FP) to the Inert Gas Regulations in SOLAS, the group considered consequential amendments to the IBC Code (International Code for the Construction and Equipment of Ships carrying Dangerous Chemicals in Bulk).

In doing so the group agreed that, in addition to logical amendments to SOLAS paragraph references in the IBC Code, the following additions will be made:

  • In section 1.3 Definitions, definitions were added for gas-freeing and purging.
  • A new section 8.5 Cargo Tank Purging will be added to the IBC Code and the current section 8.5 with then become section 8.6. This section will require new ships requiring inert gas for low flash chemicals to purge those tanks of hydrocarbons or other flammable vapours to below 2% by volume after tank washing and before gas-freeing.
  • A new section 15.13.5 will be added and the current section 15.13.5 will be modified and numbered 15.13.5.1. This section applies to new ships carrying low flash cargoes inhibited with oxygen dependent inhibitors and it says that these cargoes shall not be inerted before loading and during the voyage, but shall be inerted during the discharge.
  • The group will recommend some minor wording changes for the FP Committee to consider for their recommended new paragraph for SOLAS, 16.3.3.2. If FP goes with the recommendation then no further additions to Chapter 9 of the IBC Code will be needed.


Review of products requiring oxygen-dependent inhibitors and proposals to amend MSC/Circ.879-MEPC/Circ.348
In reviewing the need to update and amend the advice contained in these circulars, the group agreed that these circulars will be updated at some point in the future.

Consideration of further guidance for the re-issuing of chemical tanker certification
The International Association of Classification Societies (IACS) submitted paper
ESPH 18/8 to make possible proposals for handling re-issuance of Certificates of Fitness for chemical tankers when the revised Chapters 17,18,19 take effect on July 1, 2014.

ESPH discussed the proposals by IACS in considerable detail however could not reach agreement on how the re-issuance of certification should be handled.

Finalisation of amendments to the Revised Guidelines and specifications for oil discharge monitoring and control systems for oil tankers (resolution MEPC.108(49))
In finalising the amendments to the Revised Guidelines and Specifications for Oil Discharge Monitoring and Control systems for Oil Tankers (Resolution MEPC.108(49)), ESPH reviewed the changes to the existing Resolution agreeing that the amendments will be recommended to BLG and MEPC so that the Resolution MEPC.108(49) can be replaced with the new Resolution with the wording and text corrections as agreed.

These amendments are needed to remove the references to Category C and D “oil-like substances” and add references to bio-fuel blends.

The Group noted that ODME manufacturers will need to certify that their equipment will work with the various individual bio-fuel blends.

Review of safety criteria guidelines in chapter 21 of the IBC Code to address inconsistencies in chapters 17 and 18
ESPH reviewed a number of suggested modifications to Chapter 21 and the effects that they would have on the carriage requirements of a number of products in chapter 17 of the IBC Code. The Group agreed to some of the modifications suggested to the criteria in Chapter 21 and agreed that a further review of other criteria in Chapter 21 was necessary at a future meeting.

The Group recognised that significant upgrades or changes to carriage requirements of certain products could have a serious impact on available tonnage which should be avoided. However it stressed that no carriage requirements will change until at least 2018.

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