Evaluation of safety and pollution hazards of chemicals and preparation of consequential amendments (Agenda item 3)

IMO BLG 17 Summary Report Introduction The 17 h session of the IMO Sub-Committee on Bulk Liquids and Gases (BLG 17) took place from 4 to 8 of February 2013, at the IMO headquarters in London. This briefing summarise the discussion which is relevant to the work of Lloyd s Register. Due attention should be made to the Advice and Application where they are given. Evaluation of safety and pollution hazards of chemicals and preparation of consequential amendments (Agenda item 3) Evaluation of new products new MEPC.2/Circular 5 new products are approved for all countries which will be published in the MEPC.2/Circular 19 in December 2013. There are 20 Tripartite cargoes due to expire in December 2013, unless they are assessed by ESPH group in the Autumn. Evaluation of new cleaning additives BLG 17 concurred with the evaluation of new 24 cargo tank cleaning additives found to meet the requirements of regulation 13.5.2 of MARPOL Annex II for inclusion in the next edition of the MEPC.2/Circular, subject to the endorsement by MEPC 65. Amendments to the Revised Guidelines and specifications for oil discharge monitoring and control systems for oil tankers (resolution MEPC.108(49)) BLG 17 decided to revise the existing guidelines as opposed making new guidelines for the carriage of biofuel blends. It is required by 1 of January 2016 to have an ODME tested for the bio-fuel when carrying them. Therefore the guidelines (MEPC 108(49)) need to be revised. As requested from MEPC 62 references to oil-like substances were removed. This will become a new resolution and will be applicable for all Annex I tankers carrying bio-fuel blends with 75% petroleum oil or more. The original resolution will carry on to be applicable. MEPC 63 had requested addition of spare parts and Manual alternatives. IMO Secretariat advised BLG 17 that, because the bio-fuel guidelines are not mandatory instrument, it was not appropriate to revise the Form B supplement to the IOPP certificate which contains only mandatory requirements as a part of the MARPOL convention. Review products requiring oxygen dependent inhibitors No information was received from industry so it will be reviewed in the ESPH meeting later in the year. Guidance for the re-issuing of chemical tanker certification This was discussed and a draft MSC-MEPC Circular for agreement by both committees, drafted to facilitate a smooth and practical implementation for the re-issuing of the certificates for the changes from 1 June 2014. 1

Review of safety criteria guidelines in chapter 21 of the IBC Code to address inconsistencies in chapters 17 and 18. The submitted paper and information paper were discussed. It is proposed to produce a tracked changes version of the changes for discussion at ESPH meeting together with the impact assessment on cargoes carried. Ballast Water Management issues (Agenda item 4, 5 and 6) BLG 17 discussed various matters relating to Ballast Water Management under separate agenda items. BWM Circular on Ballast Water Sampling BLG 17 prepared a draft Guidance to ballast water sampling and analysis for trial use in accordance with the BWM Convention and Guidelines (G2), taking into account advances in research since the guidance was first drafted. It was further agreed that this document should continue to be updated on a regular basis so that it continues to reflect the state-of-the-art science and technology. Recognising that standard sampling and analysis methods do not currently exist a proposal was developed for the introduction of a trial period, that would commence from the date that the BWM Convention enters into force, during which standardised sampling and analysis methods will be evaluated to ensure that they are practical, easy to apply, effective, and fit for purpose for port State control. It was agreed the trial period would be for two to three years and that during this time port States would refrain from applying criminal sanctions or detaining a ship on the basis of sampling. This would not prevent Port States from taking preventative measures to protect their environment, human health or property. Further development of the science and technology of sampling and analysis is required to develop standard methodologies in time for the start of the trial period (i.e. the entry into force of the Convention). The guideline will be sent to MEPC 65 for approval. FSI has also been requested to issue port State control guidelines in advance of the Convention being ratified as the sampling and analysis methodologies will have to align with these guidelines. Draft BMW circular on other methods of ballast water management for Offshore Support Vessels to comply with the BWM Convention This circular provides guidance how the requirements of the convention will be applied to OSVs. It does not provide any special treatments for OSVs. There may be further discussion toward MEPC 65 on the use of dockside water etc. Additional guidance with regard to application of the provisions contained in Guidelines (G8) This guidance provides additional instructions on transparency of the reporting on approved of ballast water treatment systems, including limiting conditions and tested conditions. Compatibility between BWM system and ballast tank coatings While BLG 17 welcome a proposal on establishing compatibility between BWM system and ballast tank coatings. However, whilst some delegations expressed their support for the proposed recommendations on corrosively of ballast tank coatings, ballast piping systems and anodes, other delegations were of the view that a thorough technical review, such as a need for account the chemical used in the BWM system, unclear technical background, reference to NACE standards, rather than ISO standards etc. The issue will be further discussed at the GESAMP-Ballast Water Working Group. Advice to clients 2

Lloyd s Register has produced a series of guidance on Understanding Ballast Water Management including status of technology, installation requirements and how to comply with the convention. This is available to download from www.lr.org/bwm Further In October 2010 LR issued the document "Ballast Water Treatment Systems - Guide for ship operators on procurement, installation and operation". The latest document is available on the LR website at the same link as above. Improved and new technologies approved for reduction of atmospheric pollution (Second part of agenda item 6) Information on the available technology was addressed under this agenda item. Please note that there were discussions under agenda item 11 below. Equivalent technologies for reduction of sulphur oxides (SOx) BLG 17 noted information provided. Advice to clients Please note LR has published a report on the outlook for LNG bunker and LNG-fuelled newbuild demand up to 2025. A PDF version is available at http://www.lr.org/images/lr%20bunkering%20study_final%20for%20web_tcm155-243482.pdf Further information is available on the Lloyd s Register s website (www.lr.org/eca) Development of international measures for minimizing the transfer of invasive aquatic species through biofouling of ships (Agenda item 7) Bio-fouling is considered to be a significant factor in the transfer of organisms and its control forms the second initiative by the IMO in its commitment to minimise the translocation of invasive species, the Ballast Water Convention being the other. Draft MEPC Circular on Guidance and performance measures for evaluating the effectiveness of the Guidelines for the control and management of ships' biofouling to minimize the transfer of invasive aquatic species This is guidance to flag Administrations for gathering information on the current application of the biofouling guidelines within the industry. Advice to clients Lloyd s Register has also developed a model bbiofouling Management Plan that the Australian Department for Agriculture, Fisheries and Forestry refer to as meeting their national requirements. The model plan can be downloaded from www.lr.org/biofouling. Development of international code of safety for ships using gases or other low-flashpoint fuels (Agenda item 8) IMO developed interim guidelines for ships with natural gas fuelled engine installations in 2009 (resolution MSC.285 (86))). These guidelines are an interim measure until an International Code for the Safety of Gas Fuelled Ships (IGF Code) is produced, which is intended to be mandatory for ships other than those regulated under the IGC Code. The burning of gas fuel in ships has been carried out on LNG shipss for many years and there are recognised practices in place detailed in the IGC Code to mitigate the risks. The interim guidelines produced do not align 3

with the IGC Code and there are concerns in some quarters that the draft IGF Code being developed may also fail to align with the IGC Code leading to a double standard depending on the type of ships with one set of requirements for Gas ships and another set for all other ships. There were significant progresses on the development of the mandatory code of safety for ships using gases or other low-flashpoint fuels (IGF code). Further work is required toward 2014. The following is the summary of the major issues discussed at this session. Inclusion of fuels other than LNG such as Methyl/Ethyl alcohol Some delegations were of the views that the draft IGF code should address the use of LNG only, at first, while other delegation was of the view that the draft IGF code should also address other fuels, such as Methyl/Ethyl alcohol. BLG, having considered the matter at the working group established, agreed a two step approach, i.e., while providing mechanism for including texts for fuel other than LNG, the actual details will not be provided at an initial stage. Nevertheless, the terminology low flashpoint fuel has been used throughout the text. It was agreed that there would for now only be specific requirements for natural gas. It was also stated that other low flash fuels were not excluded as they could still be used through the risk assessment route. The details of other low flashpoint fuels will be further developed by the correspondence group established. Location of gas fuel tank proposed SOLAS regulation There was considerable discussion over various points and as a result the code was substantially improved and developed. Readers are to note that this will be discussed SLF 55 (from 18 to 22 February). Definition of hazardous areas There was lengthy discussion of the section and it was finally agreed that there would be a revised definition of the hazardous areas and a revised list of areas considered hazardous. One of the main issues was the hazard around Type C tanks. Concerns over the difference in the definitions of the hazardous area surrounding the gas vent included in the IGF and IGC codes were expressed. BLG 17 noted that some ships that use LNG as fuel will carry more LNG than some small LNG carriers. Hazardous areas - Isolation of equipment Equipment in hazardous areas must be suitable for the hazard. The problems with the equipment which is not isolated also stretches to portable equipment as there is little control over portable equipment which the crew use and virtually no control over equipment being used by passengers. Use of Emergency Shut Down (ESD) and single walled piping At BLG 17, there was discussion on possible imposture of restriction on the use of ESD concept, such as engine room size or engine output. However, such idea did not gain support. Compressed natural gas in general BLG 17 agreed that provisions regarding compressed natural gas (CNG) should be part of section A-1 as a part of the requirements for the storage tank, and that all other requirements are relevant for compressed gas also. BLG 17 agreed not to develop specific requirements for the CNG storage tanks as they could be certified and approved by the Administration or its recognized organization. Thus, section 6.6 on compressed natural gas is considered finalized. 4

Section 4.2 - Risk assessment There was recognition that a goal based code requires judgements/assessments to be made on the results of the risk analysis. Therefore, the title of this section was changed from 4.2 Risk analysis to 4.2 Risk assessment. The sub-clauses were also modified to ensure: consideration of physical layout; and documentation of risks and their mitigation to the satisfaction of the Administration. The requirement to detail risks and their mitigation within the ship s operating manual was deleted. There was recognition that a goal based code requires a risk assessment. The title was changed to 4.2 Risk assessment. This recognises the need for judgements on the risk analysis results. Section 5 - Requirements for arrangement of entrances and other opening - 5.11 Requirements for arrangement of entrances and other openings / 5.12 Requirements for airlocks / 5.13 Air locks with ventilation monitoring Some confusions among members were observed, this was largely because air locks are not typically found on ships other than gas/oil/chemicals ships. However, the IGF Code needs to cover all ship types and different requirements may be needed (e.g. for passenger ships). A number of text amendments were made to reflect general requirements for airlocks. A concern was expressed by an NGO that due to the 600:1 expansion of LNG from liquid to gas, a leak would result in overpressure of the hazardous space and may negate any negative pressure ventilation in the design, thus resulting in adjacent spaces being raised to a higher hazardous zoning. Section 6.4 Liquefied gas fuel containment Independent tanks have a low likelihood (i.e. probability) of failure. However, a low likelihood of failure does not necessarily equate to a low risk to persons on board. This is because risk is a combination of likelihood and consequence. In simple terms, for safety risk, consequence is dependent upon the location and number of persons onboard (for example 10 persons on a small ship compared to thousands on a cruise ship). In recognition of this, the following clause was agreed: 6.4.1 The risk assessment in Section 4.2 shall include evaluation of the vessel's liquefied gas fuel containment system, and may lead to additional safety measures for integration into the overall vessel design. Hence, if the risk is shown not to be low then additional safety measures may be required. The additional measures are not prescribed but they would need to be implemented to the satisfaction of the Administration. The above will be included in Part 2 of the IGF Code and is not shown in Part 1. Section 6.5 - Portable tanks It was agreed that, there will not be any additional requirement in addition to fixed type C tanks. For a portable tank, if it is possible to provide a Tank Connection Space as per a fixed Type C Tank then the requirement would not apply. Requirements were included to ensure that after connection to the ships fuel piping system each portable tank can be independently isolated. In addition, isolation will not impair the availability of other tanks, and each tank will maintain an independent vapour space. Section 11.4.3 - Fire protection requirement A permanently installed dry chemical powder will be required. The clarification that, when it is considered sufficient with an A-0 standard, it is not required to have a cofferdam between the spaces under consideration, was agreed. 5

Section 11.6 Requirements for water spray The spaces/areas where water spraying is required were clarified. 11.7.1 Requirements for dry chemical powder fire-extinguishing system The capacity of dry chemical power was clarified. (Minimum of 3.5 kg/s for minimum of 45s). Section 13 Ventilation Ventilation arrangements for potentially hazardous areas are quite specific. The ventilation chapter was discussed and many of the issues resolved following discussion. Among other matters it was decided to retain the requirements for non-sparking fans. Section 15.4 - Requirements for gas tank monitoring The potential for rollover was discussed and temperature and density monitoring proposed. Although considered to be unlikely, the potential for rollover was acknowledged. To avoid listing prescriptive solutions, it was agreed that detection and prevention of rollover should be considered, and text was included in Section 15.4 to reflect this. Operational issues, such as bunkering BLG 17 reviewed information provided by Denmark on the LNG bunkering facility. Methods for making the IGF code mandatory and application of the requirements given in SOLAS It was recognised that changes to SOLAS are required to ensure the IGF Code is mandatory. Therefore, proposals were made for additions to SOLAS Chapter II-1 (i.e. introduction of Part G, Regulation 56 and 57) and Chapter II-2 (Regulation 4.2.1.4). It is established practice to issue an IGC Code Certificate. A requirement for a similar IGF Code Certificate was discussed, and noted in the draft IGF code. However, no conclusion was made as to whether an IGF Code Certificate was necessary. Advice to clients Lloyd s Register s Rules for the Classification of Natural Gas Fuelled Ships were published at July 2012 and updated at January 2013. The Rules explain the current Lloyd s Register s opinion on the use of natural gas (and low flash point fuel with similar properties, provided any differences are taken into account as a part of the design and their hazards mitigated) as fuel for ships other than LNG carriers. Clients are advised to use the above rules instead of Lloyd s Register s Provisional Rules for the Classification of Methane Gas Fuelled Ships (2007) and RESOLUTION MSC.285(86). Lloyd s Register is continuously developing these Rules to reflect the up to date discussion result on the draft IGF code and clients are welcome to comment and participate in this Rule development. Lloyd s Register Rules for the classification of Natural Gas Fuelled Ships exclude statutory requirements related to the use of natural gas as fuel. It should also be noted that Lloyd s Register has developed a formal process to cover the risk assessment requirements of the above rules, resolution and the latest draft of the IGF Code. In addition, a quantitative risk assessment model has been developed that can be used to optimise LNG fuelling designs and arrangements Development of revised IGC Code (Agenda item 9) BLG 17 finalized the draft revised IGC code for approval at MSC 92 and subsequent adoption at MSC 93. Expected entry into force will be 1 January 2016. 6

In general, BLG 17 agreed that this is a revision to existing code which will be applicable to new ships, while some chapter will be applicable existing ships as well. Primarily discussion points at BLG 17 were as follows: Self-contained breathing apparatus It was agreed to require at least 15 minutes operational duration in accordance with existing the existing ICG code and the IBC code, rather than 10 minutes required by the FSS Code. There is an ISO standard in this regard - ISO23269-part 3 and 4, adopted in 2011. Emergency shutdown arrangement In general, the emergency shutdown arrangements during cargo transfer have been significantly improved. Limit State Design Concept BLG 17 could not address this issue properly owing to the lack of concrete proposal. Recalling agreement at BLG 16, BLG 17 invited members to submit proposals directly to MSC 92 scheduled in June 2013. Gas detection systems and inert gas systems Wording for gas detection system from the primary and secondary insulation spaces of membrane ships was improved, to make it clear that the text does not require two independent inert gas systems. Reference to MARPOL Convention BLG 17 decided that reference to the code from the MARPOL convention is not necessary. Consideration of the impact on the Arctic of emissions of Black Carbon from international shipping (Agenda item 10) BLG 17 reviewed the outcome of the correspondence group established by BLG. BLG 17 failed to agree on the definition of black carbon. There are two schools of opinions The matter was tasked to the intersessional correspondence group with an aim of developing one single technical definition. Policy definition will be taken as General understanding of the subject. Review of relevant non-mandatory instruments as a consequence of the amended MARPOL Annex VI and the NOx Technical Code (Agenda item 11) BLG 17 considered the guidelines prepared by the correspondence group established by BLG 16 and completed the following work for approval by MEPC 65. Draft guidelines for replacement engines not required to meet the Tier III limit Replacement engines not complying with Tier III will only be accepted where a Tier III engine of a similar rating is not commercially available or due to size cannot be fitted on board or the level of heat release will have an adverse impact on the ship. Although the guideline provide case not required to meet Tier III limits, in practice it will be extremely difficult to justify not sourcing a Tier III engine and it is to be emphasised that cost and inconvenience are not accepted as reasons. It should be noted that, while the guidelines provides process to be followed, it lacks details thus Administrations may come up with different conclusions. 7

Draft guidelines to outline the information to be submitted as part of the required notification from an Administration to the Organization in respect of the approval of an Approved Method The concept of the Approved Method, which is required to be fitted to certain engines installed on ships constructed 1.1.1990 31.12.1999, was introduced under the revised MARPOL Annex VI. It would appear that the process and application of the Approved Method is not currently widely understood. This situation is not aided by the notifications issued by IMO to date which, although the later ones (MEPC.1/Circ.738.Add.1, Circ. 764, Circ. 765 & Circ.770) are clearer than earlier ones as a result of the comments made at MEPC 62, could be still further improved. BLG 17 could not agree with the text prepared by the correspondence group. There will be further work intersessionally. Draft guidelines pertaining to equivalents set forth in regulation 4 of MARPOL Annex VI and not covered by other guidelines MARPOL Annex VI provides wide range of mechanism for equivalent arrangements in regulation 4. While some guidelines are developed, e.g., 2009 Guidelines for Exhaust Gas Cleaning Systems, (MEPC.184 (59)), there are still gaps where no guidelines are developed. A specific focus was on the scheme so called sulphur averaging which has been initiated by Bahamas (MEPC.1/Circ. 789) and Malta (MEPC.1/Circ. 799. BLG 17 reviewed the draft guidelines as well as submissions relating to the sulphur averaging scheme. However, it noted that there are so many undecided factors thus not suitable for discussion in a drafting group. BLG 17 agreed to bring the matter to the attention for MEPC 65 for decision on principles, such as use by the group of ships, role of flag and port States, whether the guideline should be specific or be generic. Draft amendments to the NOx technical Code 2008 concerning use of dual fuel engines In the NOx Technical Code 2008, currently the equations and fuel test factors and co-efficients used are based on liquid fuels and it is recognised that some guidance is needed for those dual fuel engines which are to be certificated on the basis of their gas fuel emission. These amendments clarify testing and approval of such engines, including calculation values that dual fuel engines are to be tested at their maximum liquid/gas fuel ratio (i.e., the worst NOx emission case) is retained and that these changes are in no way a means of offering a single certification on gas for engines whose normal in service NOx emission values will be higher due to operating with a greater liquid/gas fuel ratio than that used in the testing process. These additions are fully consistent with ISO 8178-1 on which Chapter 5 of the Code is based. Therefore there are no changes to either the fundamentals or details of the application of the Code in respect of Parent Engine selection, engine testing or either the Simplified Measurement Method or Direct Measurement and Monitoring options as Onboard NOx Verification Procedures. The amendments also include addition of other alternative fuels such as methanol, propane and butane and this should provide clarity and uniformity to those who are tasked with testing and approving such engines. Review Exhaust Gas Cleaning System wash-water discharge criteria for exhaust gas cleaning systems BLG 17 could not agree on the amendment to the existing guideline - MEPC.184(59). The issue will be further discussed toward at the next session. The following information is invited to the next session: impact on the marine environment of discharging highly acidic washwater; and current availability of Exhaust Gas Cleaning Systems to meet the requirements as set out in the 2009 Guidelines and those that cannot. 8

NOx monitoring scheme MEPC tasked consideration on this scheme (fitting monitoring equipment onboard when ship operations ECA) to record compliance with Tier III NOx requirements. BLG 16 did not agree with the idea. There was neither submission nor comment at BLG 17. It was decided not to work on this item any further. Development of a code for the transport and handling of limited amounts of hazardous and noxious liquid substances in bulk in offshore support vessels (Agenda item 12) MEPC 60 tasked BLG to update the existing Guidelines for the Transport and Handling of Limited Amounts of Hazardous and Noxious Liquid Substances in Bulk in Offshore Support Vessels (A.673(16)) and to develop a replacement Code. The rationale for this is to take into account advances in technology, the increased size of Offshore Support Vessels (OSVs) and the increased quantities of flammable, hazardous and noxious liquid substances carried by these vessels. In addition, the existing guidelines are open to interpretation which has lead to a variance in their application. BLG 17 reviewed document submitted. It was agreed that a further work is required through the correspondence group established. BLG 17 briefly addressed the issue of back loading (chapter 16 of the draft code loading of various fluid used for drilling activities from rigs to OSVs to transport to shore). While some delegation was of the view that this task could be sent to the ESPH Working Group, one delegation expressed concerns over this arrangement owing to the resource commitment. The issue will be addressed at the next session. Readers are to note that some of the stability relating issues (Chapter 2 of the draft code) will be addressed at SLF 55 scheduled from 18 to 22 February 2013. Consideration of IACS unified interpretations (Agenda item 14) BLG 17 agreed with the interpretation presented by IACS (IACS UI MPC 98 - "Time of the Replacement or Addition" for the Applicable NOX Tier Standard For the Supplement to the IAPP Certificate 9

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