Technical and Operational For Bulk Carriers 2

INTERCARGO
International Association of Dry Cargo Shipowners
Technical and
Operational Update for
Bulk Carriers
March 2006 Issue One
Photograph front cover courtesy of Bocimar
INTERCARGO
Technical and Operational

Update for Bulk Carriers
INTERCARGO
Acknowledgement
INTERCARGO is grateful to the Members of its Safety, Technical and Environmental Committee (CASTEC) for contribution in the drafting process of this publication. Appreciation also goes to the INTERTANKO Safety, Technical and
Environmental Committee (ISTEC) for the comments and suggestions received.
The valuable information from the following source is unique and relevant to
many common interest issues:
http://www.intertanko.com
All rights reserved. No part of this publication may be reproduced in any material
form (including photocopying or storing it in any medium by electronic means
and whether or not transiently or incidentally to some other use of this publication) without the written permission of the copyright owner. Applications for the
copyright owners written permission to reproduce any part of this publication
should be addressed to the publisher.
INTERCARGO 2006
Whilst every effort has been made to ensure that the information contained in this
publication is correct, neither the authors nor INTERCARGO can accept any responsibility for any errors or omissions or any consequences resulting therefrom.
No reliance should be placed on the information contained in this publication
without independent verification.
www.intercargo.org
INTERCARGO
St Clare House, 30-33 Minories,
London EC3N 1DD
Tel: + 44 (0) 20 7977 7030
Fax: +44 (0) 20 7977 7031
Email: info@intercargo.org
Contents
Page
Air Pollution Prevention - MARPOL Annex VI.
Ballast Water Management
12
Bunkers - MARPOL Annex VI and EU Directive
Cargoes - Dangerous.
30
Cargoes - Direct Reduced Iron..
32
Cargoes - Petcoke..
19
Cold Ironing..
10
Emergency Towing.
33
Entry into Force .
IACS Common Structural Rules...
28
Lifeboats
MARPOL Special Areas.
27
Oily Water Separators
40
Particularly Sensitive Sea Areas..
Pilotage - Denmark
34
Reception Facilities - Baltic
21
Ship Recycling.
37
Index of Abbreviations.
42
INTERCARGO
FOREWORD
It gives me great pleasure to be associated with Intercargos initiative to publish a summary of regulatory developments and other useful guidance designed to promote safety
in the bulk carrier sector.
Many countless hours have been spent in developing Regulations and Conventions, both
nationally and in the main international fora of the IMO and IACS. Best practice examples are increasingly being communicated to industry through international and national shipping associations. Although the result of this regulation and self-regulation
has seen a markedly safer bulk carrier industry, re-emphasising these new developments
will undoubtedly increase the knowledge base of the dry bulk supply chain.
This document, which will be published regularly after the introduction of significant
developments at both IMO and IACS, is equally commended to Technical Departments
and those providing commercial and strategic direction in the industry as a means of understanding the interlinking nature of issues. I commend the foresight in producing a
published record suitable for the bulk carrier sector and look forward to the issuance of
future editions.
March 2006
Tom Allan
Former Chairman of the IMO Maritime Safety Committee
INTERCARGO
Technical and Operational Update for Bulk Carriers
Entry into Force

- Index of New Requirements to be Implemented
The index contains currently available requirements and

regulations relevant to bulk carriers with entry into force
dates from 19 May 2005 to 1 Jan 2009. It will be updated
periodically with new items of requirements and regulations when they are adopted and their entry into force
dates are fixed.
19 May 2005: entry into force

1.1 MARPOL Annex VI: Air Pollution Prevention.
The dry bulk cargo residue will be treated as garbage. The residue and cargo hold wash water
should be treated carefully in accordance with the
relevant national, regional and international requirements and regulations.
Relevant information:
Intercargo Guide on compliance with MARPOL
Annex V. Contact info@intercargo.org for more
information.
1 Jan 2006: entry into force
Circular IMO MEPC/Circ.472 on Guidelines for Port
State Control under MARPOL Annex VI (Resolution
MEPC.129(53)). It is available for download from
http://www.imo.org/home.asp.
Intercargo Guide on C125
ompliance with MARPOL Annex VI - Air pollution
prevention. Contact info@intercargo.org for the full
text of an up to date version.
22 Jul 2005: entry into force
2.1 Resolution MEPC.130(53) - Guidelines for On-Board
Exhaust Gas-SOx Cleaning Systems. Contact
info@intercargo.org for the source of the document.
1 Aug 2005: entry into force

3.1 Revised MARPOL Annex IV on Regulations for the
prevention of pollution by sewage from ships, adopted by
Resolution MEPC.115(51). Contact info@intercargo.org
for the source of the document.
Annex IV may cause difficulties for ships without a
holding tank in certain ports, such as in Korea and the
Black Sea region. IMO may develop relevant port
State control guidelines for the implementation of Annex IV in the future.
3.2 MARPOL Annex V: Amendments to MARPOL Annex V on cargo residues to the Form of the Garbage Record Book contained in the Appendix to MARPOL Annex
V on Regulations for the prevention of pollution by garbage from ships, adopted by Resolution MEPC.116(51).
Contact info@intercargo.org for the source of the document.
4.1 Amendments to SOLAS chapter II-1 concerning

means of access for inspections within spaces in the
cargo area of oil tankers and bulk carriers, adopted by
Resolution MSC.151(78). Contact info@intercargo.org
for the sources of the document.
4.2 Amendments to the Technical Provisions for
Means of Access for Inspections, adopted by Resolution
MSC.158(78). Contact info@intercargo.org for the
source of the document.
IACS Unified Interpretations (UI) SC 191for the
application of amended SOLAS regulation II-1/3-6
(Resolution MSC.151(78)) and revised Technical
Provisions for Means of Access for Inspections
(Resolution MSC.158(78)). Contact
info@intercargo.org for the source of the document.
4.3 Revised NAVTEX Manual. The relevant circular
MSC/Circ.1122 on the Revised NAVTEX Manual is
available for download from http://www.imo.org/
home.asp.
4.4 Early implementation and guidance on safety during abandon ship drills using lifeboats and the Guidelines for simulated launching of free-fall lifeboats.
MSC 79 urged Member Governments to give effect to
the amendment to SOLAS regulation III/19.3.3.3,
adopted by Resolution MSC.152(78), prior to 1 July
2006 (which is the amendments entry into force date)
and approved MSC circular MSC/Circ.1127 on Early
Implementation of Amendment to SOLAS Regulation
March 2006 Issue One 1
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III/19.3.3.3 adopted by Resolution MSC.152 (78).

Contact info@intercargo.org for the source of Resolution
MSC.152(78). The relevant circular MSC/Circ.1127 is
available for download from http://www.imo.org/
home.asp.
1 Jul 2006: entry into force

5.1. Amendments to SOLAS Chapter III, adopted by
Resolution MSC.152(78). Refer to 4.4 above.
Resolution MSC.152(78) adopted amendments to:
- Chapter III Life-Saving Appliances and Arrangements
in:
Regulation 19 - Emergency training and drills
Regulation 20 - Operational readiness, maintenance
and inspections
Regulation 32 - Personal life-saving appliances (An
immersion suit shall be provided for every person
on board the ship).
- CHAPTER IV Radiocommunications in:
Regulation 15 - Maintenance requirements.
5.2 Amendments to SOLAS Chapter XII (Additional
Safety Measures for Bulk Carriers). Contact
info@intercargo.org for the source of the revised Ch XII.
In relation to the entry into force of the revised Ch XII,
the following Resolutions have the same entry into force
date:
Resolution MSC.168(79) - Standards and Criteria for
Side Structures of Bulk Carriers of Single-Side Skin
Construction; and
Resolution MSC.169(79) - Standards for Owners Inspection and Maintenance of Bulk Carrier Hatch Covers.
Contact info@intercargo.org for the source of the
MSC.169(79) and MSC.168(79).
Relevant circulars (effective when issued and available
for download from http://www.imo.org/home.asp):
Circular MSC/Circ.1135 on As-Built Construction
Drawings to Be Maintained On Board the Ship and
Ashore, 15 December 2004;
Circular MSC/Circ.1143 on Guidelines on Early Assessment of Hull Damage and Possible Need for Abandonment of Bulk Carriers; and
Circular MSC/Circ.1145 on Precautionary Advice to

Masters When Undertaking Ballast Water Exchange
Operations.
5.3 The adopted amendments to SOLAS chapters II-1,
by Resolution MSC.170(79). Contact
info@intercargo.org for the source of Resolution
MSC.170(79) and the amendments.
The amendments were made in:
Regulation 2 - Definitions of bulk carrier;
Regulation 18 - Construction and initial tests of watertight doors, sidescuttles, etc., in passenger ships and
cargo ships; and
Regulation 45 - Precautions against shock, fire and
other hazards of electrical origin
5.4 Amendment to SOLAS Chapter III (Life-Saving
Appliances and Arrangements)
The following new paragraph 1.8 is added after the existing paragraph 1.7:
1.8 Notwithstanding the requirements of paragraph
1.1, bulk carriers as defined in regulation IX/1.6 constructed on or after 1 July 2006 shall comply with the
requirements of paragraph 1.2..
5.5 Amendments to Chapter V (Safety of Navigation)
In paragraph 2.5 of Regulation 19 (Carriage requirements
for shipborne navigational systems and equipment), the
existing text of subparagraph .1 is replaced by the following:
.1 a gyro compass, or other means, to determine and
display their heading by shipborne non-magnetic
means, being clearly readable by the helmsman at the
main steering position. These means shall also transmit
heading information for input to the equipment referred
in paragraphs 2.3.2, 2.4 and 2.5.5;
The following new paragraph 2, regulation 20 (Voyage
data recorders) is added after existing paragraph 1:
2 To assist in casualty investigations, cargo ships,
when engaged on international voyages, shall be fitted
with a VDR which may be a simplified voyage data
recorder (S-VDR) as follows:
.1 in the case of cargo ships of 20,000 gross tonnage
and upwards constructed before 1 July 2002, at the
first scheduled dry-docking after 1 July 2006 but not
later than 1 July 2009;
.2 in the case of cargo ships of 3,000 gross tonnage
and upwards but less than 20,000 gross tonnage con-
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structed before 1 July 2002, at the first scheduled drydocking after 1 July 2007 but not later than 1 July 2010;
and
were adopted by Resolution MSC.194(80). Contact

info@intercargo.org for the source of annex 1 to Resolution MSC.194(80). The amendments are in:
.3 Administrations may exempt cargo ships from the

application of the requirements of subparagraphs .1
and .2 when such ships will be taken permanently out of
service within two years after the implementation date
specified in subparagraphs .1 and .2 above.
Regulation 3-2: Corrosion prevention of seawater

ballast tanks in oil tankers and bulk carriers (This
regulation applies to oil tankers and bulk carriers
constructed on or after 1 July 1998);
5.6. Unified interpretation of SOLAS Chapter XII

MSC 80 agreed to the need to provide ship designers with
interpretations of the revised SOLAS chapter XII, before
its entry into force. At its twenty-fourth regular session of
the IMO Assembly (A24), the unified interpretations of the
regulations 6.5.1 & 6.5.3 were adopted. IMO circular
SLS.14/Circ.250 with the unified interpretations is available for download from http://www.imo.org/home.asp.
Note: The IACS Common Structural Rules will be implemented to tankers and bulk carriers contracted for construction on or after 1st April 2006. IACS believe that the
objective of removing competition on scantlings for each
ship type has been achieved. The IACS Council also endorsed a long-term harmonisation plan between the
tanker and bulk carrier rule sets at its meeting in Dec
2005.
Regulation 3-7: The amendment includes Construction drawings maintained on board and ashore;
Regulation 3-8: Towing and mooring equipment; and
Regulation 23-3: Water level detectors on single hold
cargo ships other than bulk carriers.
7.2 Amendments to the Guidelines on the Enhanced
Programme of Inspections during Surveys of Bulk Carriers and Oil Tankers (Resolution A.744(18), as
amended) by Resolution MSC.197(80). Contact
info@intercargo.org for the source of Resolution
MSC.197(80).
7.3 The revised MARPOL Annex II, as adopted by
Resolution MEPC.118(52), is expected to enter into
force on 1 January 2007. Contact info@intercargo.org
for the source of Resolution MEPC.118(52).
22 Nov 2006: amendment of entry into force
1 Jan 2008: amendment of entry into force
6.1 Amendments to MARPOL Annex VI and the NOx

Technical Code by Resolution MEPC.132(53). Contact
info@intercargo.org for the source of the Resolution
MEPC.132(53).
8.1 Under the terms of the ASF Convention

(International Convention on the Control of Harmful
Anti-fouling Systems on Ships ), by 1 January 2008
(effective date), ships shall either:
Amendments to MARPOL Annex VI are the introduction

of the Harmonized System of Survey and Certification
(HSSC) and the introduction of the North Sea as a new
SOx Emission Control Area (SECA), (Regulation 14(3)
(a)).
6.2 Amendments to the revised Survey Guidelines under
the Harmonized System of Survey and Certification
(Resolution A.948(23)) for the purpose of MARPOL Annex VI by Resolution MEPC.128(53).
The Resolution MEPC.128(53) was adopted on 22 July
2005. IMO invited Governments to apply the Guidelines,
as soon as possible. Contact info@intercargo.org for the
source of Resolution MEPC.128(53).
From 1 January 2007: amendment of entry into force

7.1 Amendments to SOLAS chapter II-1 parts A-1 and C.
The amendments to SOLAS chapter II-1 parts A-1 and C
(a) not bear such compounds on their hulls or external

parts or surfaces; or
(b) bear a coating that forms a barrier to such compounds leaching from the underlying noncompliant anti-fouling systems.
1 Jan 2009: amendment of entry into force

9.1 Amendments to SOLAS chapter II-1 parts A, B and
B-1, II-2, VI, IX, XI-1, XI-2.
The amendments to SOLAS chapter II-1 parts A, B and
B-1, II-2, VI, IX, XI-1, XI-2 were adopted by Resolution MSC.194 (80). Contact info@intercargo.org for
the source of Resolution MSC.194(80).
The reasons for the entry into force date:
As the revised SOLAS chapter II-1 introduces a
fundamental change to the way ships are designed and would have a significant effect on
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shipbuilders and ship operators, there is a need for sufficient time before the revised chapter II-1 enters into
force in order that shipbuilders and ship operators
can develop and optimize new designs before such
entry into force; and
10.2 circular MSC/Circ.1142 - MEPC/Circ.425 on

Marking the ships plans, manuals and other documents with the IMO ship identification number. The
circular is available for download from http://
www.imo.org/home.asp.
The time period between the adoption of amendments to SOLAS chapter II-1 and their entry into
force should be sufficient for the DE SubCommittee to deal with consequential amendments to
SOLAS chapter III, in particular to SOLAS regulation
III/21.1.2, so that the draft amendments to SOLAS
chapter II-1 under consideration at this session and
proposed amendments to SOLAS chapter III, when
developed by the DE Sub-Committee and adopted by
MSC, could enter into force simultaneously.
10.3 Resolution MSC.200(80)- Amendments to the

revised recommendation on testing of life-saving appliances. Contact info@intercargo.org for the source
of Resolution MSC.200(80).
9.2 Annex 2 to Resolution MSC.198(80) - Amendments to

the Format and Guidelines for the Maintenance of the Continuous Synopsis Record (CSR). Contact
info@intercargo.org for the source of Resolution MSC.198
(80).
The amendments require the use of Registered Owner
ID Number and Company ID Number.
9.3 Resolution MSC.194(80) - Amendments to SOLAS
Ch XI-1include a new regulation 3-1 Company and Registered Owner ID number. Contact info@intercargo.org for
the source of Resolution MSC.194(80).
9.4 Resolution MSC.195(80) - Amendments to ISM Code:
Company Identification Number to be added in the DOC
and SMC Certificates. Contact info@intercargo.org for the
source of Resolution MSC.195(80).
9.5 Resolution MSC.196(80)- Amendment to ISPS Code:
Company identification number to be added in the Ship
Security Certificates. Contact info@intercargo.org for the
source of Resolution MSC.196(80).
Voluntary requirements
10.1 Resolution MSC.160(78) on Adoption of the
IMO unique company and registered owner identification number scheme requires voluntary implementation
before the requirements are made mandatory from 1 Jan
2009. Contact info@intercargo.org for the source of Resolution MSC.160(78).
MSC 78 adopted the IMO unique company and registered owner identification number scheme for implementation on a voluntary basis. The Resolution recommends
Governments concerned to voluntarily implement the
scheme as far as is practicable, and to inform IMO of
measures taken in this respect.
Governments are recommended to apply the

amendments to the Revised recommendation on
testing of life-saving appliances (Resolution
MSC.81(70)), when testing life-saving appliances.
IMO Circulars (available for download from http://
www.imo.org/home.asp):
MSC/Circ.1140 - MEPC/Circ.424 on Transfer of
ships between States.
Amendments to the FAL/MEPC/MSC circular
FAL/Circ.90 - MEPC Circ.368 - MSC Circ.946
on list of certificates and documents to be carried
on board ships.
MEPC/Circ.472 on Guidelines for Port State Control under MARPOL Annex VI (Resolution
MEPC.129(53)).
MEPC/Circ.469 on Revised consolidated format for
reporting alleged inadequacy of port reception
facilities - an effort to improve the rate of reporting of alleged reception facility inadequacies so
that the problem can be tackled more effectively.
MSC/Circ.1108 on Guidelines for assessing the
longitudinal strength of bulk carriers during loading, unloading and ballast water exchange.
MSC/Circ.1114 on Guidelines for periodic testing of immersion suit and anti-exposure suit
seams and closures.
MSC/Circ.1115 on Prevention of accidents in high
free-fall launching of lifeboats.
MSC/Circ.1117 on Guidance for checking the
structure of bulk carriers.
STCW.7/Circ.14 on Guidance for masters on
keeping a safe anchor watch.
SN/Circ.245 on Amendments to the Guidelines
for the installation of a shipborne automatic
identification system (AIS) (SN/Circ.227).
MSC/Circ.1145 on Precautionary advice to masters
when undertaking ballast water exchange operations.
MSC/Circ.1159 on Guidelines on the provision of
stability-related information for bulk carriers.
MSC/Circ.1119 on Ship/Terminal Interface Improvement for Bulk Carriers.
MSC/Circ.1135 on As-Built Construction Drawings
to Be Maintained On Board the Ship and Ashore,
15 December 2004.
********
4
INTERCARGO
Air Pollution Prevention

- Guide on Compliance with MARPOL Annex VI
1. Background
MARPOL Annex VI was adopted in 1997 and entered
into force on 19 May 2005.
In the 8 years since the adoption of Annex VI, there have
been significant technical advances in the control of
harmful emissions from diesel engines, including marine
engines. Since 2000, virtually all new ship engines have
met or exceeded Annex VI requirements for nitrogen
oxides (NOx).
There has been an MEPC project on monitoring the
worldwide average of sulphur content of residual fuel oil
ever since MEPC 45 (2-6 Oct 2000). The information of
the project for 2004 as provided by the Netherlands
(MEPC 53/4) has the conclusion that the three year
(2002-2004) rolling average can be established as 2.67%,
which is identical to the previous three years average.
Subsequent to the entry into force of MARPOL Annex
VI regulating emissions from ships, MEPC 53 agreed to
delegate to the IMO Sub-Committee on Bulk Liquid and
Gases (BLG) the revision of MARPOL Annex VI by
April 2006 with the aim of reducing further the limits.
The preliminary indications at MEPC 53 are that all current emissions limits would be subject to revision and, in
addition, it is proposed that elements like Particulate Matters (PM) be added to the convention. The revision process would also aim to bring greater clarification through
amendments to the current provisions, particularly to the
NOx Technical Code.
2. Areas of possible difficulties and problems
2.1) What Masters are required to do.
Vessels must retain the bunker sample for minimum of 1
year. The BDN (Bunker Delivery Note) must be retained
on board for 3 years. If the vessels flag is a signatory
State of MARPOL Annex VI, the vessel must comply
with Annex VI regardless of where they purchase their
fuel.
Ships Master is to comply with:
I. Regulation 14(1), which states that the sulphur content of any fuel used on board shall not exceed 4.5%
m/m (mass of sulphur per mass of fuel);
II. Regulation 14(4), which requires ships to demon-
strate that while the ship is passing through a SOx

emission control area (SECA) it is either:
(4) (a) using fuel which has a sulphur content not
exceeding 1.5% m/m, or
(4) (b) using an approved exhaust gas cleaning device or any other technological method which ensures that the total emission of sulphur oxide from
the ship does not exceed 6.0 g SOx/kW h;
III. Regulation 14(6) for those ships using separate fuels
to comply with Reg14(4)(a) records must be kept on
the completion of any fuel change-over procedure
when entering and leaving a SECA to verify compliance. The records shall include the date, time and
position of the ship when the fuel change-over is
complete. It shall also record the quantity of the low
sulphur fuel in each tank;
IV. Regulation 18(4), which states that the ship is to retain the BDN, readily available for inspection, on
board the ship for a minimum of 3 years;
V. Regulation 18(6), which states that the Annex VI
sample is to be retained under the ships control until
the fuel is substantially consumed, but in any case
for a period of not less than 12 months from the time
of delivery; and
VI. Resolution MEPC.96(47), which requires that the
ships master should develop and maintain a system
to keep track of the retained samples.
2.2) Bunker delivery notes and fuel samples.
MEPC 53 endorsed that it was clear that a ship, which
has on board only non compliant fuels, would be asked to
obtain compliant bunker fuels before leaving port.
As raised at the last Intercargo Safety, Technical and Environmental Committee (CASTEC) meeting in June 2005 in
Hong Kong and the Follow-up Action No. 12 (FUA 12) ,
members are concerned about what will happen if the ship
could not get the required sample and relevant documentation when receiving PSC inspection at ports of the 20 or so
signatory States of MARPOL Annex VI.
MEPC 53 recognized that Annex VI places requirements
on ship owners in respect of bunker delivery notes and
representative samples of the fuel delivered. If the country
of fuel oil supply is not a Party to the 1997 Protocol, then
the required bunker delivery note or the representative
sample may not be available. It also noted the concern
about problems relating to ships that cannot obtain the
appropriate documentation - the bunker delivery note and
the representative sample(s) of fuel delivered, when bunkering in ports and terminals under the jurisdiction of non-
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Party States to MARPOL Annex VI.

Suppliers are to comply with:
I. Regulation 18(7) (b), which states that the supplier
is to provide a compliant BDN and a representative sample of the fuel oil delieved. This sample is
to be used solely for determination of compliance
with Annex VI by port state authorities;
II. Resolution MEPC.96 (47) Guidelines for the sampling of the fuel oil, which requires that the IMO
sample should be taken at the receiving ships
bunker inlet manifold according to specified procedures; and
III. Regulation 18 (1) (a) & (b), which requires the
fuel to be of a specified quality.
Suppliers need to be registered with the appropriate Authorities and are required to provide a mandatory sample.
This is to be taken by either a:
I. continuous drip sampler,
II. time proportional automatic sampler, or
III. flow proportional automatic sampler.
The sample should be taken at the receiving vessels
manifold in accordance with resolution MEPC.96(47). It
must be a minimum of 400ml.
The sample will be accompanied by a Bunker Deliver
Note (BDN). The supplier is required to retain a copy of
BDNs for 3 years.
2.3) PSC Guidelines under Annex VI.
MEPC 53 noted that a number of bunker providers operating under the jurisdiction of a MARPOL Annex VI
non-Party State are issuing a Bunker Certificate of
Compliance to receiving ships, in order to provide them
with documentation of the fuel oil on board, in case the
ship should be subject to port State control in the port of
call under the jurisdiction of a MARPOL Annex VI
Party. MEPC 53 confirmed that according to the application of regulations 14 and 18 of MARPOL Annex VI, it
is the ship which is responsible for documenting compliance.
Having considered the issue, MEPC 53 agreed that a
Bunker Certificate of Compliance could not replace appropriate documentation issued by a bunker provider
operating under the jurisdiction of a Party to MARPOL
Annex VI. It was also agreed that it was at the discretion
of the port State control Authority of a MARPOL Annex
VI Party whether to accept the Certificate of Compliance
or not and to take appropriate action.
The IMO Secretariat has received many enquiries from
both receivers and suppliers of bunker fuel oil. In response to the enquiries, the Secretariat has informed
them that the issue is considered as a commercial issue
between the supplier and the receiver, and that according

to MARPOL Annex VI, the ship is responsible for documentation of the fuel oil quality on board and used.
MEPC 53 agreed to urge countries, which are not Parties
to MARPOL Annex VI, to institute relevant measures in
order that ships are provided with the necessary bunker
delivery note and representative samples of the fuel oil
delivered.
With regard to ships flying the flags of non signatory
States to MARPOL Annex VI, those ships may have obtained a certification or document of compliance by a
Classification Society, MEPC 53 noted that para 3.3 of
the draft PSC Guidelines for MARPOL Annex VI stipulates that , the PSCO may take such documentation
into account in the evaluation of the ship.
Paragraphs relating to the above Bunker Delivery Note
issue in the PSC Guidelines are:
Chapter 2:
2.1.1.8 any notification to the ships flag Administration issued by the master and the officers in charge of
the bunkering operation crew together with any available commercial documentation relevant to noncompliant bunker delivery.
2.1.4bis In the case where the bunker delivery note or
the representative sample as required by regulation 18
of this Annex presented to the ship are not in compliance with the relevant requirements, the master or the
officers in charge of the bunkering operation should
have documented that through a Notification to the
ships Flag Administration with copies to the port authority under whose jurisdiction the ship did not receive the required documentation pursuant to the bunkering operation and to the bunker deliverer. A copy
should be retained onboard the ship, together with any
available commercial documentation, for the subsequent scrutiny of port State control.
2.3.2.3 the sulphur content of any fuel oil being used
on board exceeds 4.5% m/m.
2.4) Letter of Protest.
In event that either the BDN or the statutory sample, or
both, have been found to be non-compliant, a Letter of
Protest (LOP) should be issued in accordance with the
ships standing instructions. It is recommended that the
ships flag administration is consulted as to whether they
have any procedural requirements for LOP.
If no standing instructions exist then it is recommended
that 4 or more copies of the LOP may be issued. One to
the supplier, one to the port State Authority overseeing
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the registration of the suppliers, another for the ships record and you may consider sending a further LOP to the
ships Flag Administration.
Issuing of the LOP will demonstrate the ships understanding of Annex VI requirements putting the onus on the supplier in the event that a port State Authority challenges any
non-compliance identified.
2.5) Options to comply with Annex VI.
I.
II.
III.
IV.
V.
The ship is not intending to operate in a SECA. All

fuel on board is not to exceed the global sulphur
maximum of 4.5% m/m.
All heavy fuel oil (HFO) carried on board is to be
less than 1.5% sulphur content.
Dual fuel operation <1.5% & <4.5% HFO changeover procedures apply.
Alternative technological method specify.
Strategy for handling national boundary emission
regulations, such as those imposed by the EU and
USA.
3. CO2 index - MEPC Circular 471

In 1997 IMO adopted a resolution on CO2 emissions from
ships, requesting to consider what CO2 reduction strategies
would be feasible for ships. Resolution A.963(23) on IMO
policies and practices related to the reduction of greenhouse gas emissions from ships was adopted, which requests the MEPC to develop a greenhouse gas emission
index for ships, and guidelines for application of that index.
As urged by the Assembly, MEPC 53 approved circular
MEPC/Circ.471 on Interim Guidelines for Voluntary Ship
CO2 Emission Indexing for Use in Trials. The most common equation used, and that which has found its way into
the CO2 Guidelines is expressed as:
Index = Fuel consumed x Carbon content / mass cargo x
distance
The objective of these guidelines is to provide the users
with guidance on achieving the targets set by IMO Assembly Resolution A.963 (23).
mittee (CASTEC) is carrying out a project of data collection and analysis, in order to report their experiences
back to MEPC 58 (October 2008), using the following
form:
NAME AND TYPE OF SHIP:
Fuel consumption (FC) at
Voyage or time period
sea and in port in tonnes
data
V
o
y Fuel
a type
g ( )
e
1
2
Fuel
type
( )
Fuel
type
( )
Cargo
(tonnes or
units)
Distance
(NM)
3
4
CO2 Index reporting sheet
Fuel type includes: Diesel/Gasoil, light fuel oil (LFO),
Heavy fuel oil (HFO).
4. Guidelines for On-Board Exhaust Gas (SOx)
Cleaning Systems
MEPC 53 adopted the Guidelines for On-Board Exhaust Gas (SOx) Cleaning Systems (EGCS-SOx). It
also endorsed the view that small engines such as lifeboat engines and emergency generators would rarely, if
ever, be run on high sulphur fuel and therefore will not
be subject to exhaust gas scrubbing. At present it would
also be inappropriate to standardize connections for
delivering scrubber wash water to shore-based reception facilities due to the variety of dimensions used,
differing needs of different ship types and inadequate
experience to date in using such a system.
MEPC will address the issue of exhaust wash water
discharges with more specific recommendations and
criteria relevant to EGCS-SOx wash water discharges
in the near future as amendments to the Guidelines.
5. References
The guidelines present the concept of an index for the energy efficiency of a ship in operation, limited to an expression of efficiency expressed in way of CO2 emitted per unit
of transport work. The guidelines are intended to monitor
the efficiency of ship operation. They should be used to
establish a common approach for trials on the voluntary
CO2 emission indexing, which will enable shipowners to
evaluate the performance of their fleet with regard to CO2
emissions. As the amount of CO2 emitted from a ship is
directly related to the consumption of bunker fuel oil, the
CO2 indexing will also provide useful information on a
ships performance with regard to fuel efficiency.
1). MEPC/Circ 472 - PSC Guidelines under Annex VI.

2). MEPC/Circ 471 - Interim Guidelines for Voluntary Ship CO2
Emission Index for Use in Trial.
3). Resolution MEPC.128(53) Adopted on 22 July 2005 Amendments to the Revised Survey Guidelines under the Harmonized System of Survey and Certification (Resolution A.948(23)) For The
Purpose of MARPOL Annex VI.
4). Resolution MECP.130(53) Guidelines for On-Board Exhaust GasSox Cleaning Systems.
5). Lloyds Register Marine Fuel Sulphur Record Book for the
control of sulphur oxide emissions
Contact info@intercargo.org for the sources of the above circulars.
The Intercargo Technical, Safety and Environmental Com-
INTERCARGO
Bunkers - MARPOL Annex VI and EU Directive
1.
The differences between IMO MARPOL Annex VI and the EU Sulphur Directive
In July 2005 the European Union (EU) adopted significant amendments to the EU Directive 1999/32, now
amended by the EU Sulphur Directive (2005/33). These
amendments have largely aligned the EU Sulphur Directive with the IMO MARPOL Annex VI requirements.
However there are still a few important differences:
(1) Differing dates for the commencement of the North
Sea/English Channel Sulphur Emissions Control Area
(SECA).
North Sea/English Channel becoming a SECA.
According to IMO, the North Sea/English Channel will
become a SECA (i.e. where fuels with a maximum sulphur content of 1.5% must be used) on 21 November
2007, while the interpretation given by the EU Commission to their own Sulphur Directive is:
"In the North Sea and English Channel SECA, operators
of all ships other than passenger vessels should comply
with the 1.5% sx.ulphur fuel limit from 11 August
2007." (Passenger ships must, however, comply with the
1.5% sulphur fuel limit from 11 August 2006 whilst on
regular services in European waters.)
We have no doubt that EU Member States will implement this requirement within their 12 nautical mile territorial zone, which according to the United Nations Convention on the Law of the Sea (UNCLOS) is under their
jurisdiction. But while the EU can enforce this requirement in its own territorial waters (12 miles), we cannot
clarify whether they could legally monitor enforcement in
international waters. However, bearing in mind that the
difference between the IMO and EU enforcement dates
for ships (other than passenger ships) is only 3 months
and 10 days, we cannot foresee that this discrepancy
would create too much of a problem as long as ship operators take it into account when trading in the North Sea/
English Channel at this time.
(2) Requirements that ships use very low sulphur content fuels while "at berth".
Use of very low sulphur fuels
Before these amendments, the EU Sulphur Directive required that all marine gas oils (MGO) and marine diesel
oils (MDO) used by ships in intra-European voyages

and when in EU ports should have a maximum sulphur
content of 0.2%. The lack of supply of these oils has
created a number of problems and since the original
EU Sulphur Directive did not cover residual fuels,
many ships have been forced to use exclusively intermediate fuel oil (IFO) and heavy fuel oil (HFO) when
in Europe.
The amendments have changed the situation and address all marine fuel oils but with one significant
change: from 11 August 2006, the 0.2% sulphur limit
will apply ONLY to DMA and DMX grade marine gas
oils (MGOs) but no longer to DMB and DMC grade
marine diesel oils (MDOs), which are commonly used
by sea-going ships. As the ISO specification of grade
DMB is close to the specification of grade DMA (the
differences being in order to allow for the bunkering of
DMA through a contaminated bunkering hose), one
could assume that if MGOs are not available, the ship
could use grade DMB for a short period of time and
avoid the problem of non-compliance due to lack of
supply.
It should also be aware that from 1 January 2010,
when ships are at berth they will be required to use
only fuels with a 0.1% sulphur content.
2
EU Sulphur Directive - What do the provisions on marine distillate fuels (MDO & MGO) mean
in practice?
There are different provisions in Article 4 of EU Directive 1999/32 and the new Articles 4a and 4b of
2005/33 which relate to marine gas oils (MGO) and
marine diesel oils (MDO). Confusion can arise here
because the new directive is an amending proposal
which has to be read in conjunction with the original
directive. The following clarifications are proposed:
Until 10 August 2006, the existing 0.2% sulphur

limit continues to apply to all marine distillates used in
EU territory waters, including ships in territorial seas
and on inland waterways, but excluding ships in the
territory waters of Greece, the French DOM-TOM,
Madeira, the Azores and the Canary Islands. The term
used in the directive is marine gas oil but the definition includes all marine distillates under ISO 8217:
DMA, DMB, DMC and DMX grades, i.e. also including marine diesel oils;
INTERCARGO
From 11 August 2006 until 31 December 2007, the

0.2% sulphur limit now applies only to marine gas oils
used in EU territory waters with a viscosity or density
falling within the ranges of viscosity or density defined
for DMX and DMA grades under ISO 8217. The exemption for Greece and the outermost regions continues to
apply. For DMB and DMC grade marine diesel oils the
0.2% sulphur limit in EU territory waters is dropped, and
a less stringent limit of 1.5% sulphur is introduced with
respect to fuels placed on the market in EU Member
States territory. This is to allow the use of marine diesel
oils to comply with the SOx Emission Control Areas, in
case supplies of 1.5% S heavy fuel oil are insufficient;
From 1 January 2008 until 31 December 2009, a

0.1% sulphur limit applies to marine gas oils used in EU
territory with a viscosity or density falling within the
ranges of viscosity or density defined for DMX and
DMA grades under ISO 8217. The exemption for Greece
and the outermost regions continues to apply; and
From 1 January 2010, the provisions originating

from Directive 1999/32 and relating to the use of marine
gas oils in EU territory waters (described above) are
now deleted. Instead a 0.1% sulphur limit is introduced
for marine gas oils placed on the market in EU Member
States territory, and a 0.1% sulphur limit starts to apply
to all types of marine fuel used by ships at berth in EU
ports and by inland waterway vessels. This applies to
any use of the fuel e.g. in auxiliary engines, main engines and boilers. There are the following exemptions:
for ships which spend less than 2 hours at berth according to published timetables, for hybrid sea-river vessels
while they are at sea, and for ships which switch off all
engines and use shore-side electricity. The outermost
regions continue to be exempt from this provision, but
Greece does not, apart from a 2-year derogation for 16
named Greek vessels until 2012.
**********
Lifeboats
- Measures to prevent accidents
IMO produced the following documents with measures to prevent life-boat accidents:
MSC/Circ 1049 Accidents with Lifeboats

MSC/Circ 1093 Guidelines for Periodic Servicing
and Maintenance of Lifeboats, Launching Appliances and On-Load Release Gear
MSC/Circ.1136 Guidance on Safety During
Abandon Ship Drills using Lifeboats
MSC/Circ.1137 Guidelines for Simulated
Launching of Free-Fall Lifeboats
Resolution MSC.152(78) Adoption of Amendments to the International Convention for the
Safety of Life at Sea, 1974, As Amended
****************
Particularly Sensitive Sea Areas
The following Particularly Sensitive Sea Areas
(PSSA) have been designated:
the Great Barrier Reef, Australia (designated a
PSSA in 1990);
the Sabana-Camagey Archipelago in Cuba
(1997);
Malpelo Island, Colombia (2002);
the sea around the Florida Keys, United States
(2002);
the Wadden Sea, Denmark, Germany, Netherlands (2002);
Paracas National Reserve, Peru (2003);
Western European Waters (2004);
Extension of the existing Great Barrier Reef
PSSA to include the Torres Strait (proposed by
Australia and Papua New Guinea) (2005);
Canary Islands, Spain (2005);
the Galapagos Archipelago, Ecuador (2005);
and
the Baltic Sea area, Denmark, Estonia,
Finland, Germany, Latvia, Lithuania, Poland and
Sweden (2005).
INTERCARGO
Cold Ironing
1. Introduction
There are reports on the feasibility studies in the US
about cold ironing to meet environmental concerns. Coldironing refers to shutting down auxiliary engines on ships
while in port and connecting to electrical power supplied
at the dock, thus eliminating virtually all emissions from
a ship while it is in port. (Cold-ironing is also referred to
as shore power and alternative maritime power). The
term cold-ironing comes from the act of
dry-docking a vessel, which involves shutting down all
on-board combustion, resulting in the vessel going
cold. Without cold-ironing, auxiliary engines run
continuously while a ship is docked, or hotelled, at a
berth to power lighting, ventilation, pumps, communication, and other onboard equipment. Ships can hotel for
several hours or several days.
There are no effective standards for electrical connection
to shoreside power, and wide variations in the electrical
infrastructures of both ships and ports. Ships which can
connect in the US cannot easily do so in Europe (and vice
versa). Controls are likely to apply primarily to regular
visitors. Some examples are:
Cruise Ships in Alaska: Cruise lines now use
shoreside power when alongside. Princess Cruise
Lines, based in Santa Clarita, California, has spent
over $4.5 million to enable its big cruise ships to
accept local power in Juneau, the capital of Alaska.
New terminal in Los Angeles: The port was sued
by a local community who was not adequately consulted before a new terminal went ahead. A settlement required ships at the terminal to use shoreside
power.
BP in Los Angeles: With the port paying for the
shoreside installation, BP has also invested to allow
its tankers, bringing oil from Alaska, to use shoreside power while unloading. It makes clear this is
voluntary, and it has no legal obligation to do so.
The costs, complications and additional shoreside emissions appear to make it unattractive as a general solution
without significant change in both ship and shore electrical technologies. (Source: The USA & Shipping Emissions)
In order for a ship to cold iron, it must be equipped to
do so and the terminal at which it is docked must be
equipped to provide power to the ship.
According to Princess Cruise Lines, the cost of purchased power of some 100,000 kWh per day somewhat exceeds the cost of diesel fuel that would be consumed if the ship's generators were operated in port.
However, if new legislation further reduces the emission level in ports, ships may be offered an option to
use shore power instead of using different types of fuel
and related installations to balance the added cost with
a contribution to protecting the environment. Modifying a ship to accept cold ironing costs more than
$500,000 per vessel. Currently, the cruise line is implementing cold ironing at its docks in Seattle. A major Chinese line has also begun implementing cold
ironing for its freighters that dock in Long Beach,
California, which is known for its concerns about air
pollution (source http://www.copper.org/resources/
cutopics/Ct98/ports_pollution.html).
This approach is especially concerning for the tanker
industry. There are obvious safety issues when connecting to the mains ashore. Other issues cover the
availability of large amounts of power needed for
tankers. Attention should also be paid to the type of
energy plant that will be required to deliver this electricity (quite possibly coal based in U.S.), and the location of the power plant in relation to densely inhabitated areas. Therefore an immediate question is what is
the real gain from the introduction of cold ironing by
burning more coal.
2. New development
At the last meeting of the Inter-Industry Shipping and
Ports Contact Group (IISPCG) on 15 Nov 2005, IAPH
(International Association of Ports and Harbours) reported the progress of cold ironing in the US. Los Angeles and Long Beach ports are considering introducing AMP (alternative marine power) but only for the
hotelling operation, i.e. only providing shore electricity to ships for crew living on board, not for operational needs. It was also reported at the meeting that
the International Standardisation Organisation (ISO) is
in the process of developing standards but using different vocabulary from those used by shipping.
3. Comments from Members

Based on current information and initial comments
from CASTEC members, we have the following summary:
10
It is extremely important NOT to underestimate
INTERCARGO
what it takes to shut a ship down these days and

accordingly arrangements should, at all costs, allow
for parallel running of the shore supply and ships
power plant. The relevance of this increases with the
decrease in expected stay alongside. Matching of
power supplies will be an issue.
It is difficult to make the changeover between

ship and shore power supplies without power interruptions, however short. This imposes extra costs
and safety precautions to a great deal of the sensitive
electronic equipment upon which modern ships depend
Heating is a service normally provided by the boiler.
Electric heating is not really practical (the average or
typical 30kW~40kW heaters for domestic services
found are often inadequate) and the power required
for the machinery heating services would be impractically large.
What will be a much more significant problem is if
the requirement is also to shut down the
boiler. Owners would then be faced with all the
problems of keeping the main engine and the fuel at
the correct temperature and supplying hot water and
heat for the accommodation for which on most ships
the boiler is required. If the boiler cannot be used
then significant expense will be involved.
The power demands are large in comparison with
other port uses. The approach of cold ironing is capable of handling the ships normal power requirements excluding that required for the deck cranes,
which would require to be fitted with individual
power supply points.
Cold ironing is only one of the tools to locally reduce air

pollution from ships in ports and can be effective in some
special cases, depending on local circumstances and sensitivity of the local environment. It is often difficult to
adapt the ship to shore connection. The cables are
bulky, safety critical, and need special handling, especially for ships of different lengths and sizes and shifting
in berth.
Intercargo would like to see uniform measures and requirements to tackle the emission problem. If the IMO
development is directed to low sulphur fuel on board and
shipping has purchased expensive fuel with the installation of additional storage tanks and handling systems,
another regime following a different approach would
undermine the implementation of the IMO requirements.
It is noted that the issue is not a high priority for bulk
carriers compared to cruise ships, tankers and container
ships. However, it is realised that participation in the joint
industry initiative may be necessary:
To monitor closely the progress in the US on cold

ironing;
To provide feedback and comments of the bulk carrier sector to the process;
To influence the standard being developed by ISO;
To bring the issue to IMO when necessary to reduce
the negative impact on shipping;
To influence the early practice and protect and balance ships interests (high cost and long term consequences); and
To exchange views with other industry partners.
Intercargo would encourage safety assessments for bulk

carriers and feasibility studies for bulk carrier terminals
with moving loading/unloading facilities.
4. Industry position
The environmental benefit achieved depends on a number
of factors, such as the time the vessel is berthed at
the quay, the fuel used, the performance of the engines
and so on. The relative benefit of electricity supply from
the shore depends on how the electricity is produced. If
the shore power is generated by coal other than wind
power, analysis may come out with a different view.
**********
The total cost for onboard generation of electricity will

depend on the design of the ships power supply system
and the fuel used (the fuel prices vary largely over time
and by fuel quality). The total cost will also depend on
costs for investments and maintenance (the investment
costs will vary with the type of engine (two/four
stroke, engine brand, size etc), age and running hours per
year).
INTERCARGO
Ballast Water Management
1. Background
The Ballast Water Management Convention (BWM Convention) was adopted in 2004 and is expected to enter
into force in 2009 (a summary of BWM Convention is at
annex I to this document). Relevant technologies of ballast water management have been developing since 2004.
IMO will use the evaluation methodology to conduct a
technology review covering aspects of safety, environmental acceptability, practicability, cost-effectiveness and
biological effectiveness.
By noting that the International Conference on Ballast
Water Management for Ships (February 2004) had
adopted the International Convention for the Control and
Management of Ships Ballast Water and Sediments
(BWM Convention), MEPC 51 in April 2004 considered
the requirements under the BWM Convention and approved a work programme for the development of guidelines for the uniform implementation of the BWM Convention.
MEPC 52 in October 2004 finalized the Guidelines for
approval of ballast water management systems ( also
referred to as G8) and approved the Procedure for approval of active substances (G9), with a view to adoption at MEPC 53 in July 2005. MEPC 52 also agreed on a
set of recommendations for the conduct of a review of the
ballast water management technologies, as required by
regulation D-5 of the BWM Convention, and invited
IMO Member States and Non-Governmental Organisations (NGOs, Intercargo being one of NGOs) to submit
relevant information to MEPC 53 to facilitate the review.
MEPC 53 made significant progress on the development
of guidelines called for under the BWM Convention and
adopted 5 sets of Guidelines.
2. Up-to-date Progress
There are 14 sets of Guidelines to be developed by
MEPC in order to implement the BWM Convention. At
MEPC 53 the following 5 sets of Guidelines have been
adopted by MEPC Resolutions. Contact
info@intercargo.org for information of the resolutions
and the Guidelines.
1)
Guidelines for Ballast Water Management

Equivalent Compliance (G3), adopted by Resolution MEPC.123(53);
Guidelines for Ballast Water Management and
the Development of Ballast Water Management
Plans (G4), adopted by Resolution MEPC.127
2)
12
(53);
3) Guidelines for Ballast Water Exchange (G6),
adopted by Resolution MEPC.124(53);
4)
Guidelines for the Approval of Ballast Water
Management Systems (G8), adopted by Resolution MEPC.125(53); and
5)
Procedure for the Approval of Ballast Water
Management Systems that make use of Active Substances (G9), adopted by Resolution
MEPC.126(53).
Substantial work was undertaken on the remaining 9
sets of guidelines, all of which will be completed by
the end of 2006. Contact info@intercargo.org for the
information of the Programme for Development of the
Guidelines for Uniform Implementation of the BWM
Convention.
3. Technology available
Categories of technology include filtration, ultraviolet
radiation (UV), oxidation, ultrasonic, non-oxidizing
chemical biocides, heat, and deoxygenation processes,
as well as combinations (usually with an initial filtration step) in multi-stage systems. . Some systems presented used more than one technology.
On reviewing some 14 different types of systems
(detailed in annex II to this document) MEPC 53
agreed that for the time being there was no need to
review the implementation dates as set out in the Convention. However, not enough information has been
provided to firmly conclude on cost effectiveness. It
should also be noted that no systems had been fully
tested on board before MEPC 53.
MEPC 53 agreed that it would undertake a second
review at its 55th meeting in October 2006 (MEPC 55)
to assess the progress made on the technologies reviewed at its 53rd session. There is a growing concern
that sufficient capability will not be available in time
to produce and install the systems on all the vessels
mandated to use them.
4. When type approved systems will be available
The program for a (G8) type approval (not using active
substances) could potentially range from 8 months for
land-based and shipboard testing in parallel and to up
to 2 years if difficulties are encountered.
1) A G8 process might be achievable within the following dates:
INTERCARGO
Systems that do not use Active Substances: Landbased test facilities available: February 2006;
Earliest type approval using parallel ship and landbased testing: October 2006. However, it is questionable whether any operator would consider the
installation of a test system without the confidence
given by an extensive land-based test; or
Type approval assuming difficulties encountered:

February 2008
2) A combined G8 & G9 approval for a system that used

active substances would have to follow the (G9) process
and assuming that data for an Active Substance was
available at the earliest opportunity, then a combined
(G8)/(G9) process might be achievable within the following dates:
Systems that use Active Substances: Consideration

by the Technical Group December 2005; Basic approval at MEPC 54 March 2006;
Earliest (G8) completion using parallel land and

ship testing: January 2007. Earliest final approval at
MEPC 56: July 2007; or
(G8) completion assuming difficulties encountered:

May 2008. Final approval assuming difficulties
encountered, at MEPC 58: October 2008.
by heating may need to be cooled to less than 10 deg C

above ambient to minimize any environmental impact.
5). Systems with filters on up-take and/or discharge
should ensure that any residual waste discharged by
back-flushing may only be discharged at the point of
origin. The capabilities of filters may impose a limit on
achievable flow rate.
6). The size range of the systems onboard varies between systems and between flow rates for the same system.
7). Systems that include an in-tank treatment stage may
introduce a minimum voyage time and may not be practicable for voyages of short duration. The minimum
voyage time may be of the order of 24 to 48 hours.
8). There was not enough information at MEPC 53 to
come to any firm conclusions about likely costs.
6. Annexes
Annex I Summary of the Ballast Water Management
Convention; and
Annex II Summary of the technologies presented at
MEPC 53.
***********
5. Advice to Members
1). No equipment should be permanently installed before it is type approved, during which full consideration
should be given to the issues of safety, environmental
risks and practicality.
2). The calibration or consistency of manufacture is also
an important area of concern. There are uncertainties
with regards to maintenance, robustness, design-life and
calibration of the system. Owners should consider extending guarantees and/or warranties for maintenance
cover since the system may have not been life-cycle
tested.
3). Storage facilities should be given appropriate design
consideration for systems that use Active Substances,
since it is possible for ships to store and carry large
quantities of potentially hazardous and toxic chemicals
for use in ballast treatment systems. Investigation should
be made to check whether some technologies may have
other waste products from the Active Substances used on
board. Residual chemicals may be produced when using
non-active substance treatment systems.
4). The ballast water that has been subject to treatment
INTERCARGO
Annex I
Summary of the Ballast Water Management Convention
The new Ballast Water Convention has been adopted and
will enter into force when 30 States representing 35% of
the worlds gross tonnage become signatories.
All ships including submersibles, floating craft/platforms,
FSUs and FPSOs) are to manage their ballast water in accordance with an approved Ballast Water Management
Plan and record such management in a Ballast Water Record Book in accordance with the provisions of the Convention based on the following implementation schedule:
D1 = Ballast Water Exchange (95% volumetric

exchange) or pumping through three times the volume of each tank;
D2 = Ballast Water Treatment systems approved by
the Administration which treat ballast water to an
efficacy of:
not more than 10 viable organisms per m3 >50
micrometers in minimum dimension; and
not more than 10 viable organisms per millilitre
< 50 micrometers in minimum dimension and
>10 micrometers in minimum dimension.
Indicator Microbe concentrations shall not exceed:

a) toxicogenic vibrio cholerae: 1 colony forming unit (cfu)
per 100 millilitres or 1 cfu per gram of zooplankton samples;
b) Escherichia coli: 250 cfu per 100 millilitres; and
c) Intestinal Enterococci: 100 cfu per 100 millilitres
Ballast CapacConstruction Date

ity (m3)
14
<2009
Ballast Water Exchange is to take place as follows:

1. at least 200 nm from the nearest land and in more
than 200 m water depth;
2. at least 50 nm from the nearest land and in more
than 200 m water depth; or
3. in the event throughout the intended route the sea
area does not afford the above characteristics, in a sea
area designated by the port State.
All ships > 400gt (except floating platforms, FSUs and
FPSOs) are to be surveyed (initial, annual, intermediate,
and renewal) and certificated (not exceeding 5 years).
States may establish additional ballast water management measures for ships to meet, based on Guidelines
which remain to be developed.
The MEPC shall undertake a review of the Ballast Water
Standards no later than 2006 and is to include an assessment of the technologies available that achieve the standard.
2015
<2009
>2009
> 5000
<2012
> 5000
>2012
2016
D1 or D2
>2009
> 1500
< 5000
Major Conversion: change of ballast capacity of 15%;

change of ship type; projected life is extended by 10
years; or ballast system modification except for replacement-in-kind or modifications needed to carry out ballast
water exchange.
First, Intermediate or Renewal Survey , which ever occurs first after

anniversary date of delivery in the year indicated below
2009 - 2014
<1500
Construction Date: keel laying date; 50 tons or 1% of

structural material whichever is less; or major conversion.
2017
D2
D2
D1 or D2
D2
D2
D1 or D2
D2
D2
Does not use active substances
An active substance (Chlorine

dioxide) is used, to
be generated on
board the ship
from its subcomponents.
The active substance is generated
onboard
Heat water to 3840 degrees Celsius

for a period of
time in order to be
effective. Limited
by length of voyage and ballast
capacity.
This system uses

filtration on uptake
with a secondary
chemical treatment
of ballast water
with Chlorine dioxide.
a) mechanical
separation
(filtration) and
b) generation of an
active substance
No.1 (Heat
Method in document MEPC
53/2/15)
No.2 (Filtration
and Chlorine
Dioxide Treatment Method in
document MEPC
53/2/15)
No. 3
(Mechanical
Separation and
Disinfection in
document MEPC
53/2/11)
Available for all

ship types and all
ship sizes due to
the modular system design
Constrained by a
ballasting rate of
2,500 cubic meters
per hour due to
filtration
Between 50 and
5000 cubic meters
per hour. Space
requirements
should not be significant.
Anticipated size
range
Will be commercially available in

the near future
(end of 2006).
Not undergone
shipboard trials
Tested on a dry
bulk carrier,
141,475 dwt travelling between
Japan and Australia.
State of development
Designed in a
modular fashion
no upper limit in
the flow rate
Chlorine dioxide
is widely used in
municipal water
treatment.
The system provides a level of

simplicity, which
for practical purposes is desirable
in a shipboard
system.
Positive results for

eliminating viable
organisms.
has not been undertaken in relation to the D-2
standard or the G8
guidelines
The testing undertaken has provided
positive results;
however testing
has not been undertaken in relation to the D-2
standard or the G8
guidelines.
Pilot tests have
been carried out
under worst case
conditions in river.
Standard D-2 can
be met for organisms >50 m and
organisms <50 and
>=10 m.
Other relevant
information
Extent of testing
Operation does not

require consumables. However,
cleaning chemicals and spare
parts replacements
are needed.
Cost information
Note: Technologies 8, 10 and 13 are not included as they are duplicates of other technologies already submitted.
Active substances
used
Description
Technology
Annex II Summary of the technologies presented at MEPC53
INTERCARGO
16
Tested on land
with a flow rate of
200 and 500 cubic
meters per hour.
Size 4.8 and 14.8
square meters.
The system makes

use of an active
substance
PERACLEAN
Ocean, which is a
readily biodegradable and chlorinefree.
The system uses an
active substance.
Produces no special risks for the
environment. No
special risk for
health or onboard
safety.
A first step mechanical separation

(hydro cyclone
and 50m filtration) and a second
step treatment with
an oxidizing agent.
First step filtration

(mesh size 50 m)
and a second step
disinfection based
on electrochemicalactivation
No. 5 (Physical Separation and Disinfection in document

MEPC 53/2/11)
No. 6 (Filtration and

Disinfection in document MEPC 53/2/11)
5 square meter size

for a flow rate of
300 cubic meters
per hour.
For ships with a

ballast water flow
rate up to 250 cubic meters per
hour. It requires
approx. 5 square
meters.
The active substance needs to be

dosed directly into
the ballast water
A first step filtration, second step

UV-radiation and
third step disinfection
No. 4 (Filtration and

UV in document
MEPC 53/2/11)
Anticipated size
range
Active substances
used
Description
Technology
INTERCARGO
Results in relation
to D-2 from onboard testing are
not available at
present.
Installed on a
container vessel
(1.100 TEU)
since May 2005.
No influence to
the normal ballast water operation. It starts and
stops automatically with the
common ballast
operation.
Installation cost
cannot be assessed at the
present. Costs
for operation are
anticipated at
0.30 US$ per
treated m of
ballast water.
Estimated operation costs for
1000 m of
treated ballast
water are between 4 to 10
.
Consumables are
required on a
very limited
scale. Costs for
maintenance and
consumables are
below 10k US$
annually.
Due to the
modular design
system, components can be
placed in different locations
within the ship.
Larger flow rates
can be treated by
using multiple
systems in parallel.
No constraint
resulting from
the voyage
length. The
treated water
should be retained for a
minimum of 24
hours.
The system can
be designed for a
ballast water
flow rate up to
5000 m/h and
should be world
wide commercially available
in summer 2006.
Pilot tests have

been carried out
and did not meet
the D-2 Standard
completely. The
insufficient filtration rate for larger
organisms needs
the use of active
substances to meet
the D-2 standard
Reached or even
exceeded the D-2
standard
Cost information
Other relevant
information
Extent of testing
Fully developed
and ready for
shipboard testing
in accordance
with G8.
Not using Active

Substances.
Uses nitrogen injected into a

steam-plume established in the
flow in the ballast
pipe line following
filtration through a
50 micrometer
mechanical automatically back
flushing filter.
Electrochemical
disinfection uses
various active substances produced
from electrolysis
of sea water.
No. 9 (Filtration,
Dual Pulsed Shock
Wave/
Supersaturation and
Oxygen Deprivation
in document MEPC
53/2/16)
Active substances
are not added to
the system but
produced during
electrolysis of sea
water,
attacking
simultaneously an
organism or organisms for disinfection so that a synergy effect can be
expected.
The system does

not utilize active
substances. No
safety hazard for
the ship or the
crew running and
operating the system.
The method of
treating ballast
water with a lowpressure loss separator and UV.
No.7 (Filtration and

UV Radiation in
document MEPC
53/2/16)
No.11
(Electrochemical Disinfection in document
MEPC 53/2/31)
Active substances
used
Description
Technology
INTERCARGO
Electrochemical
reactor module,
dimension (mm)
840 W x 740 D x
2700 H. Rectifier
dimension (mm)
1400 W x 1300 D
x 2350 H.
A 300 cubic meter

system is approximately 1.5 square
meters in size. Expected lifetime of
3000 running
hours
Anticipated size
range
Land-based pilot
test with ballast
water flow rate
of 60 cubic meter is being conducted.
Installed on
board a total of 7
ships; 5 retrofits
and 2 new
builds. The first
installation since
May 2000. There
are no environmental concerns.
Undergone laboratory tests, landbased test and is

currently evaluated
in a shipboard
situation.
The current version has not been

tested under the
current D-2 standards and G8 testing guidelines.
Extent of testing
There are no
waste streams
that have to be
disposed of and
require special
concern during
the system operation.
Comprises a
compressor and
membranes for
nitrogen production, only the
filter, injection
and cavitation
components
need to be installed.
Other relevant
information
The capital cost

including installation is expected
to be in the range
of 160K - 170K
US$ for new
vessel with 1500
m3/hr ballast
pump and 180K
- 200K US$ for
an existing vessel.
Cost information
18
All equipment and

tanks housed in a
standard 20 foot
long shipping container. Target flow
rate capability is
1,000 -10,000 cubic meters per
hour.
Uses Active substance ClO2. Its

storage and handling are not a concern because it is
generated on
board. Design dose
is 5 mg/L ClO2
with 24-hour incubation.
No.14 (Chlorine Dioxide in document

MEPC 53/2/14
A area of 3 square
meters for equipment is required to
treat 500 cubic
meters per hour.
No substances are
added and no residuals are created.
Automatically
black-flushing
filter for removal
of large particles
and the AOT unit
producing hydroxyl radicals in
breaking down
micro-organisms
and bacteria.
Based on a chlorine dioxide
(ClO2) generator
which produces a
treatment solution
from sulphuric
acid and sodium
chlorate/hydrogen
peroxide.
No.12 (Filtration and

Advanced Oxidation
in document MEPC
53/2/6)
Anticipated size
range
Active substances
used
Description
Technology
INTERCARGO
Currently undergoing full-sized

shipboard tests
on a 11,000 cubic meter ballast
water capacity
container ship
with a ballast
flow rate of
2,500 cubic meters per hour.
A full-scale prototype has since

September 2003
been installed on
board a transoceanic car carrier.
Vendor reports that

the design dose
achieves treatment
meeting IMO D-2
standard
concentrations.
Shipboard tests to
validate at full
scale are underway.
Compliance with
the D-2 standard
should be
achieved. Fullscale land-based
tests according to
G8 are yet to be
tested.
Extent of testing
Power consumption depends on

the amount of
ballast water to
be treated, e.g.
500 cubic meters
per hour requires
15 kW.
Other relevant
information
Capital for
equipment and
installation:
$300K to $450K;
technical support
including materials: 50K - 100K
US$ per year.
Operational costs
including power
consumption and
consumables
about 0.015US$/
m3 treated ballast
water.
Cost information
INTERCARGO
Cargoes - Petcoke
- Guide on disposal of petcoke residue and cargo hold wash water
1. Background
with these requirements by completion of log books,

oil record books, incinerator logs and records of port
discharges.
Due to the entry into force of the amendments to MARPOL Annex V on 1 Aug 2005, cargo residues become
garbage under the amended Annex V.
2. Operational experience
After carrying green delayed petcoke, subsequent cleaning will remove both the residues and the residual footprint (the paint pigment) left behind. The cargo residue
has polluting properties which leave a sheen on the surface, therefore it needs a port reception facility to collect
it. The water cleaning operations may use chemicals/
detergents to remove the "footprint". The resultant wash
water then needs special attention. The wash water may
be contaminated by oil, or hydrocarbons and may trigger
application of regulation 3(2), or 5(2) of Annex V which
states that "when the garbage is mixed with other discharges having different disposal or discharge requirements the more stringent requirements shall apply".
If a bulk carrier is within special areas (as defined within
MARPOL Annex V) or within port limits (this definition
to be determined by the port authority regarding how far
out to sea this goes), the wash water cannot be discharged
overboard. Even if the ship is out of the special areas, but
the chemicals/detergents of the wash water do not break
down the oily deposit and prevent the 'sheen' from occurring and/or the chemicals/detergents are not the ones as
approved by IMO, the wash water is still not allowed to
be discharged overboard. Ships turn to adequate port reception facilities for assistance, which are required by
MARPOL as statutory obligation of ports. Without
proper port reception facilities to receive the cargo residues, a ship may not be able to physically present itself
with clean holds to back load at a port or terminal within
one of the Special Areas. Intercargo is aware that it is not
easy for a ship to clean for loading after a discharge in
either North West Europe or the Mediterranean.
The PSC inspectors may quickly become aware of the
issue.
MARPOL Annex I contains limits on the amount of oil
which ships can legitimately discharge into the sea.
Where discharge from bilge tanks is permitted it is a requirement that an Oil Discharge Monitoring and Control
System together with Oil Filtering equipment (Oily Water Separator) be fitted so as to ensure that the oil content
of any discharge does not exceed the maximum permitted
under Annex I (15ppm). Any residue or sludge should
then either be incinerated or discharged into port reception facilities. Owners are required to ensure compliance
2.1 Experts contacted

The following members and organisations were contacted for advice:
Intercargo membership:
Anglo-Eastern Ship Management (Hong Kong) Ltd.
COSCO UK
Bocimar, Belgium
IMC Singapore
Kristen Marine S.A. Greece
Oceanbulk Maritime S.A. Greece
Pacific Basin UK
Thomas Miller Ltd
Unisea Shipping Ltd
Wallem Shipmanagement Ltd, Hong Kong
Others:
Experts from Intertanko
Thenamaris Ships Management Inc. Greece
Strmme ASA, Norway
2.2 Advice received
MEPC circular MEPC.2/Circ.8 issued in Dec 2002
indicates the restriction on the types of detergents used
in washing under Para. 3.4 Cleaning additives as:
1.8.2 When small amounts of detergents are added to
water in order to facilitate tank washing, no detergents
containing pollution category A components should be
used except those components that are readily biodegradable and present in a total concentration of
less than 10%. No restrictions additional to those
already applicable to the tank due to the previous
cargo should apply (amendments to the Standards for
Procedures and Arrangements for the Discharge of
Noxious Liquid Substances, implemented as of 1 July
1996).
The IMO BLG Sub-Committee evaluated a list of
cleaning additives and found it to meet the requirements of paragraph 1.8.2. Annex 12 of the MEPC.2/
Circ.8 details the consolidated list.
Cargo residues: Having a similar property is fuel
sludge, petcoke should be collected by a shore facility.
Owners best proposal is to get the cargo receiver and
INTERCARGO
is not approved under the above class and its use

should be avoided. The disposal has to go through
standard discharge and monitoring equipment if
available.
receiving terminal involved as early as possible for their

preparation and arrangement to deal with the cargo residues.
Cargo hold washing: It is normal that after discharging
of petcoke there are always some dark foot prints left
behind on the bulkheads of cargo holds. These are normally cleaned with bridgeable cleaning agents which
remove these stains and any oily content or sheen which
is then emulsified into a harmless solution and is discharged as normal and wont invoke Marpol Annex I.
6). For dry petcoke

EDGE or Enviromate 2000 is usually recommended.
Edge or Enviromate 2000 would be the product of
choice if a spray on application is going to be used.
EDGE is recommended when stubborn stains are a
problem.
Procedure to wash cargo holds after discharge:

US Practice:
1) Sweep tank (Very Important to Thoroughly Sweep
Out);
2) High pressure water wash if possible with warm
water (50 to 60 deg C);
3) Manual spray at 100 to 150 liters of cleaner per 1000
cubic meters of tank space or tank cleaning machine;
4) Let soak 45 to 60 minutes maximum; and
5) High pressure water wash.
Chemicals for different types of petcoke
1) Only products listed under IMO MEPC.2/CIRC.8
can be used and disposed of at sea for cargo tank
cleaning when cargo residue slops are permitted to be
disposed at sea. It is suggested to check with the
manufactures for a Certificate of Compliance of the
products to meet the requirements of MEPC.2/Circ.8.
2) The cleaning products EDGE, Enviromate 2000 and
DREW TC at Sea have been evaluated by IMO bulk
liquid and gases (BLG) working group on the evaluation of safety and pollution hazard of chemical
(ESPH) and found to meet the requirement of Paragraph 1.8.2 of Procedures and arrangement standards
and is listed on IMO MEPC.2/CIRC.8.
3) OSD/LT is an oil spill dispersant used to breakdown
sheen and TYPE 1 approved by the UK environmental and food council.
4) Cleaning chemical Aqutuff from Unitor was evaluated through IMOs BCH Working Group on the
Evaluation of Safety and Pollution Hazards of
Chemicals and found to meet their requirements of
paragraph 1.8.2 of the P&A Standards.
5). For oily petcoke
Solvent cleaning is required. Drew TC Sea or TC #4
can be applied or used through a tank cleaning machine, combigun or maxigun.
If De-odoring is required then use Drew EDGE.
The product TC#4 is not listed under this category and
20
A vessel may not discharge wash water of any kind from

her bilge tank(s) directly into the sea. Any wash products
that may form a sheen (shiny translucent film) in the water or contain chemicals, oil, hydrocarbons or any other
product unfriendly to the aquatic life environment, cannot
be disposed overboard in US waters.
The procedures call for the secure transfer of the wash
water or of any other liquid type to be disposed into special holding tanks (frac tanks). Once the wash water has
been transferred into the holding tanks a tank transportation company would thereafter transport the tank content
to an approved (EPA agency) facility for final disposal.
All the disposals are governed by federal, state and local
environmental control regulation.
3. References (contact info@intercargo.org for the
information of them):
1.
2.
3.
4.
5.
6.
7.
8.
9.
Summary of the amendments to MARPOL Annex V.

Introduction of Petcoke.
Garbage management plans - MEPC/Circ.317.
Provisional categorization of liquid substances, IMO MEPC.2/
Circ.8, Dec 2002.
Research project - Precautions when fixed for Green Delayed Petcoke, Strmme AS, Nesveien 15, PO Box 31 N-1305 Haslum, Norway.
Cleaning Manual for bulk carriers, Strmme AS.
Solutions to petcoke problems, Strmme AS.
Solving hold cleaning problems in vessels transporting petcoke,
Strmme AS.
Pollution Prevention Equipment Required By Marpol 73/78.
INTERCARGO
Reception Facilities - Baltic

- Introduction of its no-special-fee System
1.
INTRODUCTION of the Baltic Strategy
Main Components of the Baltic Strategy
Port reception facilities: Over 210 port reception

facilities in the Baltic Area
Notification: 24 hours in advance
Mandatory delivery: obligation to deliver to a
port reception facility before leaving
No-special-fee: Ports charge the reception
costs as part of their harbour fee, irrespective of delivery of any waste or not and irrespective of
amounts
Promotion of sound waste management on
board and on shore
Information and awareness raising
Control and enforcement: aerial surveillance
supported by satellite observations
The Baltic Sea area has been designated as a special area
under Annexes I, II and V. Prohibitions and restrictions
on any discharge into the sea of oil or oily mixtures, noxious liquid substances and garbage have been introduced
by the Baltic Sea States.
The Baltic Sea area comprises the Baltic Sea proper, plus
the Gulf of Bothnia, the Gulf of Finland, and the entrance
to the Baltic Sea bounded by the parallel of the Skaw in
the Skagerrak at 5744.43'N, with a total area of about
370,000 km.
The Helsinki Commission has approved the Strategy for
Port Reception Facilities for Ship-generated Wastes and
Associated Issues, also known as the Baltic Strategy,
which comprises a set of measures and regulations with
the main goals to ensure ships' compliance with global
and regional discharge regulations and to eliminate illegal
discharges into the sea of all wastes from all ships.
In addition, regulations concerning the discharge of sewage into the sea and the prohibition of incineration of
ship-generated wastes in the territorial seas of the Baltic
Sea States have been adopted by the Contracting Parties
to the HELSINKI CONVENTION (refer to the attached
Introduction to the Convention). There is also a general
ban on dumping and incineration of other wastes, not
incidental to or derived from the normal operation of
ships, in the entire Baltic Sea area.

Source: http://www.helcom.fi (GRID Arendal)
The HELCOM Recommendation 26/1on Application

of the no-special-fee system to ship-generated wastes
in the Baltic Sea area was adopted on 2 March. It
recommends that the Governments of the Contracting
Parties to the Helsinki Convention apply the attached
Guidelines for the establishment of a harmonised "nospecial-fee" system for the operation of reception
facilities in their ports as of 1 January 2000 for shipgenerated wastes covered by Annex I (oily wastes
from machinery spaces) of MARPOL 73/78 and as of
1 January 2006 for wastes covered by Annex IV
(sewage) and Annex V (garbage) of MARPOL 73/78.
No-special-fee for the reception of ship-generated
waste means that the ports charge the reception and
treatment costs to all ships calling as part of their harbour fee, irrespective of whether a certain ship delivers
any waste or not and irrespective of amounts discharged. In addition, they have a mandatory commitment for ships to deliver all their wastes to port reception facilities before leaving port.
The "no-special-fee" system has the dual purpose of
encouraging ships to deliver waste ashore thus avoiding undesirable waste streams between ports and encouraging a sound sharing of the waste burden. This
INTERCARGO
means that fees covering the cost of the reception, handling and final disposal of ship-generated wastes are included in the harbour fee and otherwise charged to the
ship, irrespective of whether any wastes are actually delivered.
Over 210 port reception facilities are provided in ports
located around the Baltic Sea.
Additionally, the Baltic Sea States have agreed that by 1
January 2001 ships bound for or leaving a port of a Baltic
Sea State and carrying dangerous or polluting goods,
must report on the substances to the competent authority
of that Baltic Sea State. Some Baltic Sea States have already made this reporting requirement obligatory under
their national law.
CHAIN of responsibility
The responsibility for avoiding discharges of oil or other
harmful substances rests not only with the master and his
crew but also with the charterer, the ship-owner and the
ports.
The charterer should include in the Charter Party a clause
stating his policy on pollution prevention compliance.
The ship-owner should ensure sound management in
safety and pollution prevention, as required by the International Safety Management Code for certain categories
of ships.
Ports should be prepared to accept tank cleaning slops, or
cargo that has been mixed with retained residues.
Notes: 10 Contracting Parties (9 Baltic Sea coastal States and the
European Community)
HELCOM: the Helsinki Commission, Governing body of the
Convention . HELCOM MARITIME: the Maritime Group of the Helsinki Commission
Attachments:
1. Introduction to the Helsinki Convention.
2. Application of the No-Special-Fee System to ShipGenerated Wastes in the Baltic Sea Area.
********
Attachment 1
Introduction to the Helsinki Convention
(source: http://www.helcom.fi/)
Growing awareness that national measures alone are not
sufficient to protect this highly sensitive marine environment led the Baltic Sea States to adopt the HELSINKI
22
CONVENTION, which was signed in 1974 and came

into force in 1980. The 1974 Convention was the first
international agreement worldwide to take into account
all aspects of marine environment protection. The Convention aims to prevent pollution from ships (including
dumping), pollution from land-based sources, and pollution resulting from the exploration and exploitation of
the seabed and its subsoil. The Convention also regulates
the co-operation to respond to marine pollution by oil
and other harmful substances.
A new Convention was signed in 1992 in order to extend, strengthen and modernize the legal regime for the
protection of the marine environment of the Baltic Sea
area. The 1992 HELSINKI CONVENTION entered into
force on 17 January 2000. The Convention text and
HELCOM Recommendations can be found in the internet, see www.helcom.fi.
The discharge regulations are as follows:
Oil
Any discharge of oil or oily mixtures into the Baltic Sea
area is prohibited. Oil means petroleum in any form including crude oil, fuel oil, sludge, oil refuse and refined
products. The prohibition applies not only to discharges
from the cargo tanks of oil tankers but equally to discharges from the machinery spaces of any ship. Only if
the oil content in the effluent does not exceed 15 parts
per million can a discharge be permitted. The oil filtering
equipment must be provided with arrangements that ensure that any discharge of oil or oily mixtures is automatically stopped when the oil content in the effluent
exceeds 15 parts per million. Since 1 January 2002 ships
of less than 400 tons gross tonnage, flying the flag of a
Baltic Sea State, should also comply with the adopted
guidelines concerning holding tanks/oily water separating or filtering equipment.
Finland has prohibited the use of bilge water separators
in her inland waterways and in the territorial waters,
within an area of 4 nautical miles from the nearest land.
Noxious liquid substances carried in bulk
Within the Baltic Sea area there is a prohibition on discharges from tanks that have contained Category A or B
substances, specified by IMOs International Bulk
Chemical Code, which categorizes noxious liquid substances carried in bulk as A, B, C or D according to their
magnitude of harm to the marine environment if discharged.
Tanks having contained Category A or B substances
must be pre-washed and the resultant tank washings
must be delivered to a reception facility. This is either to
ensure a certain concentration of the substance in the
INTERCARGO
effluent or a certain concentration of the substance in the

wake astern of the ship. The same applies to tanks that
have contained high-viscosity or solidifying Category C
substances. The eventual discharge into the sea must comply with provisions on the speed of the ship, discharge
below the waterline, distance from the nearest land and
depth of water.
For discharges from tanks that have contained other Category C substances there are provisions on the concentration of the substance in the wake astern of the ship, maximum quantity of cargo to be discharged, speed of the ship,
distance from the nearest land, discharge below the waterline and depth of water.
Likewise provisions on concentration of the mixtures to
be discharged, speed of the ship and distance from the
nearest land apply to discharges from tanks that have contained Category D substances.
The discharge into the sea of noxious liquid substances,
which have not been categorized, provisionally assessed
or evaluated, or of ballast water, tank washings, or other
residues or mixtures containing such substances, is prohibited.
Sewage
For ships flying the flag of a Baltic Sea State it is prohibited to discharge sewage within 12 nautical miles of the
nearest land. This prohibition also applies to all other
ships in the territorial seas of the Baltic Sea States. However, sewage that has been comminuted and disinfected
using an approved system may be discharged at distances
greater than 3 nautical miles from the nearest land. In any
case, when discharging from a sewage holding tank, the
discharge must be at a moderate rate and the ship must be
proceeding en route at a minimum speed of 4 knots. Only
if an approved sewage treatment plant is used onboard can
discharge take place at any distance from the nearest land.
For ships, flying the flag of a Baltic Sea State, certified to
carry more than 50 persons and engaged in international
voyages in the Baltic Sea area, regulations on Surveys and
Sewage Pollution Prevention Certificates also apply.
Garbage
Discharge of garbage in the Baltic Sea area is prohibited.
However, food wastes may be discharged, but in any case
not less than 12 nautical miles from the nearest land.
Fuel oil quality
In the Baltic Sea area ship-owners are encouraged to use
marine fuel oils with as low sulphur content as possible,
but not exceeding 1.5% m/m (mass/mass) by weight. Alternatively, exhaust gas treatment systems, proven to
cause no harm to the marine environment, may be used.

The Baltic Sea States have also agreed to take actions to
reduce and finally prohibit the use of ozone-depleting
substances on board ships flying the flag of a Baltic Sea
State.
When Annex VI of MARPOL 73/78 on Regulations for
the Prevention of Air Pollution from Ships enters into
force on 20 May 2005 the Baltic Sea area will obtain the
status of a SOx emission control area requiring that on
and after 20 May 2006 all ships navigating in the area use
fuel oil with a sulphur content not exceeding 1.5% m/m
or an exhaust gas cleaning system or any other technical
method reducing the total emissions of sulphur oxides
from ships. In accordance with Annex VI deliberate
emissions of ozone-depleting substances will be prohibited.
Prohibition of incineration
Incineration means the deliberate combustion of wastes
or other matter at sea for the purpose of their thermal
destruction, excluding activities incidental to the normal
operation of ships or other man-made structures.
Incineration, except for incineration of ship-generated
wastes, is prohibited throughout the Baltic Sea area.
However, incineration of wastes deriving from the normal operation of the ship is also prohibited in the territorial seas of the Baltic Sea States.
Prohibition of dumping
Dumping means any deliberate disposal at sea of wastes
or other matter from ships, or any deliberate disposal
from ships at sea. The prohibition of dumping does not
apply to the disposal of dredged materials at sea, provided specific provisions are complied with.
Dumping is prohibited throughout the Baltic Sea area.
Mandatory delivery of wastes at port reception facilities
All ships, with some exceptions, are under an obligation
to deliver to a port reception facility, before leaving the
port, their ship-generated wastes and cargo residues that
cannot be legally discharged under the global International Convention for the Prevention of Pollution from
Ships, 1973, as modified by the Protocol of 1978 relating
thereto (MARPOL 73/78), or under the HELSINKI
CONVENTION.
Availability of port reception facilities
To enable ships to deliver their ship-generated wastes and
cargo residues, over 210 port reception facilities are pro-
INTERCARGO
vided in ports located around the Baltic Sea area.

Notification of the intended use of port reception facilities
To ensure the use and efficiency of the port reception
facilities, an information sheet must be forwarded to the
next port of call 24 hours in advance of the intended use
of a port reception facility. The sheet must include the
following information: the capacity of the waste storage
tanks/bins on board; the amounts of wastes delivered at
the last port of call and the estimated amounts of wastes
to be delivered at the next port of call. The notification
can also be accomplished electronically via the Baltic
Ports Waste Information System.
The no-special-fee system
According to the no-special-fee system, a fee covering
the cost of reception, handling and final disposal of shipgenerated wastes is levied on the ship irrespective of
whether or not ship-generated wastes are actually delivered. The fee is included in the harbour fee or otherwise
charged to the ship.
Detection and prosecution of offenders of antipollution regulations
The Baltic Sea States place high priority on the elimination of violations of anti-pollution regulations, and on the
conviction of any offenders. Various actions have been
taken to this end.
Co-operation in investigation
The Baltic Sea States are co-operating to investigate
violations of anti-pollution regulations.
This is particularly important when a ship violates the
discharge regulations in the waters of one State, without calling at a port in that State, and proceeds to a port
in another State. Thus, a Baltic Sea State can request
another State to conduct a Port State Control inspection
upon the ship's arrival at the next port of call, to obtain
the necessary information and evidence of the suspected violation.
To enhance this co-operation, the Baltic Sea States
have elaborated a Baltic Legal Manual specifying the
requirements for obtaining a conviction in each Baltic
Sea State and Guidelines on ensuring successful convictions of offenders of anti-pollution regulations at
sea.
Fines
The Baltic Sea States have agreed to harmonize administrative fines by deciding on a minimum level, which
is intended to be preventive - discouraging the master
or other person in charge of a ship from violating the
anti-pollution regulations. The minimum level will
prevent fines varying greatly between the Baltic Sea
States, and will also avoid a situation in which it is
cheaper to discharge illegally than to use port reception
facilities.
Cargo, Oil and Garbage Record Books

MARPOL 73/78 and the HELSINKI CONVENTION lay
down a duty to keep Cargo, Oil and Garbage Record
Books, and specify the operations requiring entries in the
appropriate Record Books. Accurate and timely entries in
Cargo, Oil and Garbage Record Books are of utmost importance to ensure compliance with the special discharge
regulations. A copy of the relevant Record Book may be
used in judicial proceedings as evidence of facts stated in
the entry.
********
Attachment 2
Application of the No-Special-Fee System to ShipGenerated Wastes in the Baltic Sea Area
(source: http://www.helcom.fi/)
Aerial surveillance
THE COMMISSION,
In order to prevent and detect any violation of discharge

regulations, the Baltic Sea States regularly conduct aerial
surveillance supported by satellite observations of their
response regions and jointly survey specific parts of the
Baltic Sea area.
During the joint surveys a chosen traffic route is surveyed
for a minimum of 24 hours by a number of aircraft from
the Baltic Sea States. A joint command post manages the
surveillance in close co-operation with patrol vessels,
ready to take proper measures when offenders are detected.
RECALLING Article 8 of the Convention on the Protection of the Marine Environment of the Baltic Sea
Area, 1992 (the Convention) which calls for development and application of uniform requirements for the
provision of reception facilities,
24
RECALLING ALSO Article 9 of the Convention

stipulating a need for special measures in relation to
pleasure craft, which includes the establishment of adequate reception facilities for wastes from pleasure craft,
INTERCARGO
age and Garbage to Port Reception Facilities

CONSCIOUS that the "no-special-fee" system constitutes a system with the dual purpose of encouraging
ships to deliver waste ashore and to avoid undesirable
waste streams between ports, thereby encouraging a
sound sharing of the waste burden,
CONSCIOUS ALSO that the no-special-fee system
constitutes one of the prerequisites for a substantial decrease in the number of operational and illegal discharges and thus for the prevention of pollution of the
marine environment from ships,
1 Definition of the "no-special-fee" system

1.1 In this context the "no-special-fee" system is defined
as a charging system where the cost of reception, handling and disposal of ship-generated wastes, originating
from the normal operation of the ship, is included in the
harbour fee or otherwise charged to the ship irrespective
of whether wastes are delivered or not.
1.2 The "no-special-fee" system is not restricted to any
specific type of ship-generated waste.
NOTING that the port authorities are responsible for

providing reception facilities for wastes covered by Annex I (oil), Annex II (noxious liquid substances), Annex
IV (sewage) and Annex V (garbage) of the International
Convention for the Prevention of Pollution from Ships,
1973, as modified by the Protocol of 1978 relating
thereto (MARPOL 73/78),
2 Obligation to pay
2.1 Every sea-going ship's obligation to pay for reception, handling and disposal of oil residues, sewage and
garbage is deemed to arise with the arrival of a ship in
any port of the participating countries, irrespective of
whether or not that particular ship will actually make use
of the reception facilities, which are available there.
NOTING ALSO that the consignor in the loading port

is responsible for reception arrangements for cargo related wastes covered by Annex I (oil residues from cargo
tanks) of MARPOL 73/78,
2.2 The above fee covers the waste collecting, handling

and processing including infrastructure and shall be distributed among ships and collected as part of or in addition to the port dues.
NOTING FURTHER that the consignee in the unloading port is responsible for reception arrangements for
wastes covered by Annex II (residues of noxious liquid
substances) of MARPOL 73/78,
3 Exemptions
3.1 A ship may be exempted by the competent authority
from the obligation to pay, when engaged in scheduled
traffic with regular and frequent port calls and it is ensured that the disposal requirements will be met on the
ships own account.
RECOMMENDS that the Governments of the Contracting Parties apply the attached Guidelines for the establishment of a harmonised "no-special-fee" system for the
operation of reception facilities in their ports as of 1
January 2000 for ship-generated wastes covered by Annex I (oily wastes from machinery spaces) of MARPOL
73/78 and as of 1 January 2006 for wastes covered by
Annex IV (sewage) and Annex V (garbage) of MARPOL 73/78,
3.2 For the purpose of these Guidelines "scheduled traffic with regular and frequent port calls" means the traffic
meeting the following criteria:
3.2.1 scheduled: the ship must have a published or
planned list of times of departures and arrivals,
between nominated ports or terminals;
TAKING NOTE of the adoption within the European

Union of Directive 2000/59/EC on port reception facilities for ship-generated waste and cargo residues,
3.2.2 regular: for being exempted, the ship must make

repeated journeys between those nominated ports
or terminals; or
REQUESTS the Governments of the Contracting Parties

to support or seek active co-operation with the North Sea
States for the purpose of establishing a similar "nospecial-fee" system also in the North Sea Region,
3.2.3 frequent: the ship must visit the port for which the
exemption applies at least once a week.
REQUESTS ALSO the Governments of the Contracting

Parties to report on the implementation of this Recommendation and attached Guidelines in accordance with
Article 16(1) of the Convention.
Guidelines for the Establishment of a Harmonised
"No-Special-Fee"
System for the Delivery of Ship-Generated Oily
Wastes Originating
From Machinery Spaces and for the Delivery of Sew-
3.3. When a ship applies for an exemption, the competent authority of the Port State should require evidence
of the ships scheduled traffic as well as evidence of
waste management practice (contract, receipts, copy of
garbage record book, oil record book etc.). The ship has
to organise its waste management according to a contract
and deliver its waste regularly under this arrangement in
a certain port/ports. If it chooses to deliver elsewhere, a
port can charge the ship according to the real costs
(direct fee).
3.4. The Contracting Parties should also advise on exMarch 2006 Issue One 25
INTERCARGO
emptions issued to other Port States along the scheduled

route. The Contracting Parties will inform the HELCOM
Secretariat of their competent authority responsible for
granting exemptions from the mandatory delivery and
notification requirements.
4 Basis of calculation of the no-special-fee
4.1 The waste management fee imposed on a ship should
be independent of the volume of the wastes delivered to
the port reception facilities. To obtain the maximum fairness in specifying the ships contribution to the nospecial-fee system the gross tonnage, as indicated in the
vessel's Data Sheet, could be taken as the basis of calculation by the port. The basis of the quantity calculation of
oil, garbage and sewage may depend on the type and size
of the ship as well as the number of crew and passengers.
4.2 A high quality standard of the applied waste management procedures and waste processing equipment on
board can also be taken into account in scaling the waste
management fee, having in mind the general aim of minimisation of waste production, and the benefit of waste
separation.
4.3 The waste management fee shall be fair, transparent
and non-discriminatory to all ships, i.e. the size of the
waste management fee shall be visible to every ship even
if it is included in the harbour fee.
4.4 The waste management fees received from ships shall
be used for no other purposes than:
- investments in reception facilities, stationary
and mobile;
- operation of reception facilities;
- repair and maintenance costs of such facilities;
and
- costs of handling, treatment and final disposal
of the received wastes.
5 Avoidance of competitive distortion
5.1 To avoid competitive distortions between ports located in different sea areas, all possible efforts shall be
made to achieve as soon as possible a harmonised waste
management fee system for the ports in the Baltic Sea
and in the North Sea Regions.
5.2 The Contracting Parties involved shall make the necessary efforts in order to implement a harmonised fee
system simultaneously in the ports of the Baltic Sea as
well as in the North Sea Regions.
5.3 Provisions should be made to preclude any subsidising of the waste management fee through public funds for
the operation of reception facilities.
5.4 The Governments of the Contracting Parties shall
exchange periodic reports on the implementation of these
Guidelines in their ports, including reports on the financ-
26
ing and operation of reception facilities, and evaluate

such reports at the meetings of the Maritime Group of the
Helsinki Commission.
********
INTERCARGO
MARPOL Special Areas
Special areas under MARPOL 73/78 are as follows:

1) Annex I: Regulations for the prevention of pollution by oil
der amendments to Annex VI adopted by the MEPC in

July 2005, with expected entry into force in November
2006.
*********
Regulation 10 identifies the following special areas with

strict controls on discharge of oily wastes:
Mediterranean Sea area

Baltic Sea area
Black Sea area
Red Sea area
Gulfs area
Gulf of Aden area
Antarctic area
North West European Waters
Oman Sea area of the Arabian Seas (from 1 January
2007)
2) Annex II: Regulations for the prevention of pollution by Noxious Liquid substances
Regulation 1 identifies the following special areas with
strict controls on tank washing and residue discharge
procedures:
3)
Baltic Sea area

Black Sea area
Antarctic area
Annex V: Regulations for the prevention of
pollution by Garbage
Regulation 5 identifies the following special areas, in

which there are strict controls on disposal of garbage:
Mediterranean Sea area

Baltic Sea area
Black Sea area
Red Sea area
Gulfs area
North Sea
Antarctic area (south of latitude 60 degrees south)
Wider Caribbean region including the Gulf of Mexico and the Caribbean Sea
4) Annex VI: Prevention of air pollution by ships
This annex enters into force on 19 May 2005 and establishes the Baltic Sea area as a "SOx Emission Control
Areas" (SECA) with more stringent controls on sulphur
emissions from ships.
The North Sea was adopted as a SECA in July 2005, un-
INTERCARGO
IACS Common Structural Rules
General industry position

INTERCARGO, together with the other three Round
Table International Shipping Associations (BIMCO, ICS
and INTERTANKO), lends its full support to IACS and
its commendable work on developing Common Structural
Rules (CSR) for Bulk Carriers. We believe that the broad
application of the Rules by all IACS members is fundamental to the future of Class and is in the best interests of
maintaining the highest standards of ship safety and quality. INTERCARGO has shown and will continue to show
its commitment to work together with IACS in the harmonisation and future reviews process.
As to the history, the 2nd draft of Common Structural
Rules for Bulk Carriers was published on the JBP Website on 8th April, 2005. Large number of comments from
the Industry have already reached IACS and led to the
revision of the 2nd draft CSR. It shows that the IACS
harmonisation process has difficulties. It is the request of
the shipping industry that the IACS members should endeavour to maximise those elements of harmonisation
which can be achieved before the implementation of the
CSR.
Both IACS and the industry have covered much ground,
however the industry still has areas of concern and has
requested IACS to consider them during the harmonisation process and future revisions in the review process.
Uncertainties at present with the impact on the CSR
The IMO is also busy with the development of Goalbased New Construction Standards (GBS), which are
indirectly linked to the CSR development. Such a link
will have a significant impact on the future review of the
CSR. This leaves CSR with a level of uncertainty for its
user.
Maritime safety and environmental issues are increasingly attracting the attention of the public, who together
with their governments, are demanding increasingly robust ships. These pressures alone are enough to push the
development of CSR to the fullest extent of its safety
margins.
Shipping is driven by commercial interest. Shipowners
who put more attention on the long term benefit, will
respond positively to the increase of safety margins, but
there are also groups of shipowners positioning themselves with the intention of relatively short term invest-
28
ment in newbuildings and who are not interested in a

ships life longer than 20 years. These are entirely legitimate concerns and interests, which will need to be
accommodated within the CSR development process.
There are still areas of ship design and building issues
waiting for new technology to come up with new solutions or clarification. The advance of new technology
will leave the CSR under continuous pressure for review and evaluation.
Information flow between key stakeholders of the CSR
can either promote or restrict the understanding and
appreciation of the CSR. Lack of transparency or
shortage of information flow will delay the process of
CSR development and the review process.
Shipyards and marine products manufacturers have to
respond to the CSR positively. New designs under the
CSR will therefore impact on their standards. The cost
of absorption will be passed down to the end user,
shipowners, with commercial uncertainty.
The principle of CSR is to reduce the competition
level between IACS Members but internal conflicts
have been evidenced in the review and harmonisation
of the CSR between tanker and bulk carrier and the
ramification study, although recent perceived unanimity within IACS Members has been greatly welcomed
by the wider shipping industry. There is always a
question as to what extent the CSR incorporates the
industry comments and feedback.
Overall impact on shipping
CSR, covering both single and double side skin bulk
carriers, will come into force for ships contracted for
construction on or after the 1st of April 2006, as decided by IACS Council in December 2005. From April
1, 2006, ships contracted will be subject to the new
rules.
According to the IACS assessment, bulk carriers, built
to the new common rules, could be expected to require
5%-6% more steel on average than ships either built
or under construction that did not already comply with
the Unified Requirements issued by IACS for ships
contracted after July 1, 2003. This equals to a 3% rise
in scantlings over a ship built to UR S25.
Apart from the opportunity cost of ship new buildings
between the first draft CSR available in 2004 and final
INTERCARGO
implementation in 2006, same uncertainties remain and

may leave a long term impact on new ships during their
25 years of commercial life.
implement the CSR from 1 Apr 2006, the following suggestion is offered to those owners who are planning newbuildings:
On the positive side, the CSR is expected to raise the

overall safety bar for new ships. It is also expected to
reduce market forces on ship design and building and
avoid compromise on the safety level of ships. The same
set of rules across the whole design and construction sector is expected to provide the same design in term of
main scantling and strength elements, which will reduce
the opportunity to optimize design and new building standards.
1. The CSR for bulk carriers are completely new to all

yards. There will be more certainty in terms of cost, design, planning approval, and delivery date if the newbuilding contract follows existing rules prior to the introduction of CSR on 1 Apr 2006, because normal yards
have years of experience using them. This will make for a
cheaper newbuild vessel price. However, those with the
perception to use the CSR may have a more robust,
forward-proofed ship offering the long-term benefits
such as a sound second hand resale security and compliant with future IMO strengthening requirements; and
On the commercial side, heavier ships will incur higher

cost of building and a burden on the original owner but
will give more certainty to the second hand owners.
On the negative side, all new ships with IACS member
societies class will follow the new CSR and bear the
possible cost of all uncertainties. A tiny proportion of
ships of non IACS Member societies may compete with
the CSR ships with the advantage of an initial low investment on newbuildings, although it is not widely anticipated that owners will overturn the many years of experience with IACS Members in favour of untried non technically competent non IACS members. The CSR may
result in a higher cost for new orders. Those owners who
have newbuildings shortly after 1 July 2006 may have to
bear the cost of change or re-arrangement of production
lines with ship yards.
2. Owners will need to check the up-to-date development

in the areas of uncertainty, for an overall appreciation and
understanding of the situation. Only then will they be in a
position to take the decisions necessary for a satisfactory
outcome.
********
New rules will also improve the design and drawing approval process. Extra resources from shipowners may
need to be allocated to digest the new rules, especially to
those who have new building contracts with yards around
1 July 2006.
Conclusion
Industry welcomes the development of the CSR with the
expectation that there will be improvement on the safety
level of ships. However, the influences from different
interest groups internally and externally may push the
CSR development into a compromise situation. In addition, there are a number of areas of uncertainty from different parts of the whole safety chain, which will load
significant and different long term cost impacts on individual shipowners. CSR ships may have material differences regarding loading capacity, maintenance and operation, and ship/terminal regimes. They will need to be
tested against the real sea and cargo conditions, which
goes some of the way to explaining why the development
process has been as time-consuming as it has been to the
INTERCARGO working group and others who have contributed so extensively to the debate.
With the perception that IACS will move forward and
INTERCARGO
Cargoes - Dangerous
- Requirements on Ships Carrying Dangerous Cargoes
The following IMO Conventions, Resolutions, Codes,

Circulars, Manuals as well as EU Directives are relevant
for a ship carrying dangerous cargoes. The ships should
comply with their provisions according to which type of
dangerous cargoes are on board. It is also prudent for
those ships to make sure whether there are additional
requirements from their flag States and the visiting port
States:
(1)
(2)
BC Code: the Code of Safe Practice for Solid Bulk

Cargoes, adopted by the IMO by resolution A.434
(XI), as subsequently amended;
BCH Code: the Code for the Construction and
Equipment of Ships Carrying Dangerous Chemicals in Bulk, adopted by the IMO by resolution
A.212 (VII), as subsequently amended;
Board Ships, adopted by the IMO by resolution

MSC.88(71), as subsequently amended;
(11)
Cargo Securing Manual: a manual for the securing of cargo, as required by SOLAS, prepared
pursuant to IMO guidelines, MSC/Circ.745, as
subsequently amended;
(12)
MARPOL 73/78: the International Convention

for the Prevention of Pollution from Ships, 1973,
as modified by the Protocol of 1978, as subsequently amended;
(13)
MFAG: the Medical First Aid Guide for Use in

Accidents Involving Dangerous Goods, MSC/
Circ. 857, as subsequently amended;
(14)
Resolution A.673 (16): the IMO Guidelines for

the transport and handling of limited amounts of
hazardous and noxious liquid substances in bulk
in offshore support vessels. The resolution applies to all combustible substances, irrespective
of whether or not they are listed in Appendix 1 of
the resolution;
SOLAS (Chapter VII): the International Convention for the Safety of Life at Sea 1974, as subsequently amended; and
(3)
Directive 2002/59/EC: the EU Directive 2002/59/

EC establishing a Community vessel traffic and
monitoring and information system and repealing
Directive 93/75/EEC, as subsequently amended;
(4)
MSC Circular EmS: Emergency Response Procedures for Ships Carrying Dangerous Goods, MSC/
Circ.1025, as subsequently amended;
(15)
(5)
GC Code: the Code for the Construction and

Equipment of Ships Carrying Liquefied Gases in
Bulk, adopted by the IMO by resolution A.328
(IX), as subsequently amended;
(16) STCW: the International Convention for Standards, Training, Certificates and Watchkeeping
1978, as subsequently amended.
(6)
Gas Code for existing gas carriers: the Code for

Existing Ships Carrying Liquefied Gases in Bulk,
adopted by the IMO by resolution A.329 (IX), as
subsequently amended;
(7)
IBC Code: the International Code for the Construction and Equipment of Ships Carrying Dangerous Chemicals in Bulk, adopted by the IMO by
resolution MSC.4(48), as subsequently amended;
(8)
IGC Code: the International Code for the Construction and Equipment of Ships Carrying Liquefied Gases in Bulk, adopted by the IMO by resolution MSC.5(48), as subsequently amended;
(9)
IMDG Code: the International Maritime Dangerous Goods Code, adopted by the IMO by resolution A.716(17), as subsequently amended;
(10)
INF Code: the International Code for the Safe Carriage of Packaged Irradiated Nuclear Fuel, Plutonium and High-Level Radioactive Wastes on
30
Normally there are entry-into-force dates clearly indicating its implementation. In absence of an entry into
force date, the adoption date should be complied with.
Ships carrying cargoes covered by the above provisions
should, to the extent they are covered by the body of
legislation, keep the following documentation on board:
SOLAS, Chapter VII;
SOLAS, Regulation II-2/19 / Regulation II-2/54;
MARPOL, Annex III;
BC Code;
IMDG Code;
EmS;
MFAG; and
Directive 2002/59/EC.
Packages containing dangerous goods offered for sea
transport should be marked and packaged in compliance
with applicable regulations, and accompanied by the
necessary transport documents. Goods which do not
comply with this should be refused for transport. Goods
in damaged packaging should always be refused.
INTERCARGO
All ships carrying dangerous goods should have a special list, manifest or detailed stowage plan which sets out
the dangerous goods on board and the location thereof.
The relevant training to the ships crew should be made
according to the requirements of the IMDG Code and
STCW, and must be documented, as referred to in the
IMDG Code, Volume 1, Chapter 1.3 and STCW 1995,
Chapter II, Section A-II/2 including Tables, and Section
B-V/c of the STCW Convention. Safety measures for
dangerous packaged goods should also be in place.
********
INTERCARGO
Cargoes - Direct Reduced Iron

The cargo DRI or direct reduced iron is one of the raw
materials used in the production of steel by certain
method. When moist, hydrogen is released. It also creates heat, which can be so extreme that the DRI glows
white hot. It has been known to melt through steel plate.
The hydrogen it produces in an enclosed space like the
cargo holds could be ignited and causes an explosion.
Before its loading, following cautions should be taken:
Prior to shipment the DRI has to be aged for at

least 72 hours or treated with an air-passivation
technique, or some other equivalent method that
reduces the reactivity of the material to at least the
same level as the aged product would have (72
hours);
It should not be loaded when it is either hot or
damp;
Its condition should be monitored during loading.
Cargo with a temperature in excess of 65 C
should never be loaded;
During loading the DRI must be protected from

exposure to rain or other respiration;
As far as is reasonably practical, DRI should not

be dropped from a height into the hold;
DRI, which has been exposed to wetting on an

open-conveyor or elsewhere, should be rejected;
During loading or discharging no smoking, burning, cutting, chipping or other source of ignition
should be allowed in the vicinity of the holds; and
Movable cargo lights, if used, must be not less

than 3m from the coaming in a position where
they are not likely to be broken during operations,
and not over the square of the hatch.
Relevant information with requirements and reports of

incidents:
IMO BC Code (the Code of Safe Practice for

Solid Bulk Cargoes), as adopted by Resolution
MSC.193(79);
IMO Circular DSC/Circ.8 on Incident reports involving dangerous cargoes;
32
IMO Circular DSC.1/Circ.36 on Accidents involving transport of direct reduced iron (DRI) fines;
IMO Circular MSC/Circ.1149 on Accidents Involving Bulk Cargoes Not Specifically Listed In
the Code of Safe Practice for Solid Bulk Cargoes
(BC Code);
IMO MSC79 meeting paper on report of the explosion and subsequent sinking of M.V. Ythan
carrying DRI (MSC79 12-1);
DSC.1/Circ.26 on Incident involving transport of

zinc ingots;
DSC.1/Circ.27 on Explosion in a Cargo Hold

Loaded With Recycled Aluminium; and
MSC/Circ.1146 on Lists of Solid Bulk Cargoes for

Which a Fixed Gas Fire-Extinguishing System
May Be Exempted or for which a Fixed Gas FireExtinguishing System Is Ineffective.
Contact info@intercargo.org for details of the above information.
********
INTERCARGO
Emergency Towing
- Progress report of New Requirements
Background
The DE Sub-Committee, at its forty-eighth session in Feb
2005, established an intersessional correspondence group
(CG) on Mandatory emergency towing systems in ships
other than tankers greater than 20,000 dwt (DE 48/25
paragraph 14.4) coordinated by Germany.
The CG was instructed to prepare a revised proposal for
draft SOLAS amendments to SOLAS chapter II-1, Regulation 3-4 and related guidelines as per Annex 1 and 2 of
DE 48/14 for the assessment of deck equipment to be
used in emergency towing, taking into account comments
and proposals made in plenary, and to submit a report to
DE 49 in Feb 2006.
Intercargo is one member of the CG, together with Germany, Australia, Cyprus, Italy, Japan, the Netherlands,
the United Kingdom, the United States, ICS, IMCA, Intertanko and ISU.
Work of the DE 48 CG
The Correspondence Group did not make any progress
but, Germany still insists on developing new regulations.
The only concern so far is their suggestion that the emergency towing can be arranged without assistance by crew
members.
From the limited input received, it can be summarised
that there is a need:
for a common understanding of certain terms used in
the context of the guidelines (towing, emergency,
redundant propulsion systems ), and
that there be a re-emphasis on developing and meeting
functional requirements for procedures and arrangements for emergency towing.
Outcome of DE 49
Intercargo agrees to the development of emergency procedures but not mandatory requirements for equipment
and supports the application to new ships only. Intercargo
accepts the comments:
At DE 49 in Feb 2006, it has been agreed that there will
not be requirements for equipment installation but only
procedure requirements for new and exiting ships.
The following draft amendments to regulation 3-4 of SOLAS Chapter II-1 were agreed at DE 49:
2. Emergency towing procedures on ships

2.1 Ships shall be provided with an emergency
towing procedure. Such a procedure shall be
carried aboard the ship for use in emergency
situations and shall be based on existing arrangements and equipment available on board
the ship.
2.2 The procedure shall include:
.1 drawings of fore and aft deck showing possible emergency towing arrangements;
.2 inventory of equipment on board that can
be used for emergency towing;
.3 means and methods of communication; and
.4 sample procedures to facilitate the preparation for and conducting of emergency
towing operations.
2.3 This regulation applies to ships, regardless of
the date of construction, as follows:
.1 all new ships constructed after [1 July
2008];
.2 cargo ships constructed before [1 July
2008] and above 20,000 dwt and all passenger ships not later than [1 July 2008];
and
.3 cargo ships constructed before [1 July
2008] and below 20,000 dwt not later
than [1 July 2010].
An intersessional correspondence group will be established to finalise the guidelines for owners/operators on
the development of emergency towing procedures, and
submit a report to DE50. The Co-ordinator is Dipl.-Ing
Stephan P. Assheuer, ash@gl-group.com.
Clarification at DE 49
1) Certificates and document required to be carried on
board ships.
This should be considered as a verification that such procedures are available on board, rather than an approval or
verification of the content. Such availability on board
could sufficiently be granted by inclusion of the emergency towing procedures in FAL.2/Circ.87 - MEPC/
Circ.426 - MSC/Circ.1151.
2). The emergency towing procedures should be added to
the list of documents to be carried on board ships and that
circular FAL.2/Circ.87 - MEPC/Circ.426 - MSC/
Circ.1151 should be amended accordingly.
********
INTERCARGO
Pilotage - Denmark
1. Background
The Danish Maritime Authority (DMA) wrote to Intercargo on 10 Oct 2005 urging all ships (other than tankers)
with a draught of 11m or more or with Irradiated Nuclear
Fuel (INF) cargoes to take on a pilot when they enter or
leave the Baltic Sea, as recommended by the IMO under
Resolution MSC.138(76). The DMA backs up this assertion with a report that from 1 January 2002 to 30 June
2005, 22 ships grounded on the Great Belt none of
which had a pilot onboard. Intercargo recognises all IMO
Recommendations.
Careful review was taken of the recommendations contained within the letter and the Groundings and collision
reports in the Great Belt 1997-2005. Intercargo reacted
to the letter through a clear statement in the INTERCARGO Bulletin No. 202, October 2005 with a recommendation from the DMA that the IMO recommendations should be followed and that members should include the INTERTANKO Clause in their Charter Parties,
as follows:
Where the vessel is to pass through the entrances to the
Baltic Sea the vessel shall comply with the recommendations set out in the IMO Resolution MSC.138(76) adopted
on 5 December 2002 as amended from time to time including the use of pilots for the passage. Charterers shall
reimburse owners for any pilotage expenses incurred by
compliance with these recommendations on any ballast
passage to a port of loading or on the laden passage
unless such expenses have already been taken into account in the freight payable [in accordance with the
terms and conditions of Worldscale].
2. Intercargo Position
Intercargo responded to DMAs letter with a position that
the IMO recommendations should be followed but, as
intended by IMO, there is a distinction between Recommendations and Mandatory Resolutions. However, in this
particular instance, Intercargo is fully prepared to go further and urge its members to comply with
the recommendation contained in Resolution MSC.138
(76) regarding pilotage in the Danish Straits and include
the INTERTANKO Clause in their Charter Parties.
The DMA was also informed that Intercargo is in the
process of establishing an Ad Hoc Correspondence
Group to review the issue of Pilotage as it relates to dry
bulk carriers. Intercargo welcomes and promotes the
creation of a 'User Group' where industry and pilot interests can be debated openly, issues can be discussed and
problems solved.
34
However, in urging our members to comply with this

resolution and, as we propose in other pilotage situations, we advocate the mutual sharing of responsibility
by the respective parties. It is therefore our contention
that the pilotage service provider, when contracting to
provide such services, should accept liability for loss or
damage caused by the vessel under pilotage, where such
loss and/or damage is attributable to the deliberate and/or
negligent actions of the pilot and/or the service provider,
and that the national authority responsible for licensing
and regulating the pilots and pilotage service providers
ensures that the pilotage service provider maintains adequate insurance protection to discharge this liability.
We believe that this approach highlights that our primary
concern is about damage caused by the ship, and addresses both the duties of the pilotage service provider,
with regards to such matters as training, ensuring pilots
are competent both physically and professionally, provision of appropriate equipment and backup etc.
By drawing this distinction between the pilotage service
provider and the national regulatory authority, Intercargo
believes this highlights that the pilot is not the employee
of the regulatory authority but the service provider by
doing so, and if the regulatory authority chooses to also
be a service provider, it should be subject to the same
responsibilities as all service providers in regard to its
activities.
3. Issues of further consideration
3.1) Reaction of the adjacent States
It is noted that the issue is highly sensitive due to the
recent boom in Russian oil exports that move through
the straits. Baltic Sea States have declined to agree to
make pilotage compulsory, with Russia in particular
arguing that the international law of the sea should be
respected.
3.2) Commercial aspects
One relevant issue as raised some time ago by a member
was the unwillingness of a time charterer to pay for nonmandatory pilotage expenses in the English Channel
where a Master of a deep draughted bulk carrier chose to
take a pilot but was not required to do so. The Charterer
argued that Masters of such ships which they had previously chartered had sufficient experience not to require a
pilot. Therefore, they took the view that they should not
have to pay. We agree that the bottom line should be
safety and nothing else. However we have to be aware
that our members are moving in a commercial world and
usually do not like to see mandatory conditions applied
to their operation.
INTERCARGO
3.3) Liability and human element of the service provider

Liability:- With regard to the pilotage provider, when
providing such services, there is an issue of liability for
causing loss or damage to the vessel under pilotage,
where such loss and/or damage may be attributable to the
deliberate and/or negligent actions of the pilot and/or the
service provider (and also the national authority responsible for licensing and regulating pilots?). Do the pilotage
service providers maintain adequate insurance protection
to discharge this liability?
By drawing a distinction between the pilotage service
provider and the national regulatory authority that the
pilot is not the employee of the regulatory authority but
the service provider then if the regulatory authority
chooses to also be a service provider, then it should be
subject to the same responsibilities as all service providers in regard to its activities.
Human element:- Concerns about the quality, qualifications of pilotage and the efficiency of the whole system in
the area, including the number of appropriately qualified
pilots, training, professional competency both physically
and professionally, provision of appropriate equipment
and backup, etc. need to be addressed.
Procedures:- to manage their areas of responsibility,
including measures to deal with pilot fatigue.
3.4) Common practice of members
What is the common practice of the membership when
their vessels pass through the Danish Straits?
3.5) The regulatory regime of DMA
Review of the system:- Are there any independent reviews of the pilotage regulatory system and regular reviews of the pilotage operations?
Information on support and fair treatment of every
vessel with or without a pilot onboard is needed.
Code of practice to cover:
* Clarification of the responsibility of provider organisations and individual pilots;
* Effective and comprehensive fatigue management
arrangements;
* Effective and safe boarding arrangements;
* Emergency management arrangements;
* Maintenance of effective training programs; and
* Introduction of a "check" pilot system.
3.6) Price
Is the $7,500 a reasonable charge for the pilotage service?
Is the price referred to review by a Surveillance Authority
in the EU system?
4. Safety measures in the Baltic Sea area:

The Baltic Sea States have agreed on certain safety measures in the Baltic Sea area, like ship routing, ship reporting, traffic separation schemes, pilotage, safety of winter
navigation etc.
Route T
A transit route (Route T) through the Kattegat, the Great
Belt and the Western Baltic has been established for deep
draught ships.
SHIPPOS
IMO recommends that large ships navigating Route T
participate in the radio reporting service SHIPPOS. The
system, which is free of charge, provides beneficial information to ships.
Ship reporting systems
IMO has adopted a mandatory ship reporting system in
the Great Belt Traffic Area. Ships with a gross tonnage
equal to or exceeding 50 GT, and all ships with an air
draught of 15 metres or more, are required to submit a
ship report to the VTS Centre. Participation is free of
charge.
Mandatory ship reporting systems have also been established nationally by the Baltic Sea States in approaches to
oil terminals.
Automatic Identification System (AIS)
The Baltic Sea area within A1 sea area will be covered by
land-based monitoring systems for ships, based on AIS
signals (by 1 July 2005).
The AIS information will improve the safety of navigation via real time information as well as statistical information on shipping in the Baltic Sea. The AIS information will also be used to identify offenders of antipollution regulations.
Pilotage
Pilotage services are established locally by the coastal
states.
IMO recommends that, when navigating the Sound, local
pilotage services should be used by:
- loaded oil tankers with a draught of 7 metres or more;
- loaded chemical tankers and gas carriers irrespective of
size; and
INTERCARGO
- ships carrying a shipment of irradiated nuclear fuel,

plutonium and high-level radioactive wastes
(INFcargoes).
IMO also recommends that, when navigating Route T,
established pilotage services should be used by:
- large ships with a draught of 11 metres or more; and
- ships carrying a shipment of irradiated nuclear fuel,
plutonium and high-level radioactive wastes
(INFcargoes).
Traffic separation schemes
Traffic separation schemes are established and adopted
by IMO in the following parts of the Baltic Sea area:
Area
Number of
schemes
In Sams Belt/Great Belt
In the Sound
Off Kiel lighthouse
South of Gedser
South of land Island
South of Gotland Island
Entrance to the Gulf of Finland
In the Gulf of Finland
Deep sea pilotage

Certified Baltic deep sea pilots are available in all Baltic
Sea States.
Safety of winter navigation
Adequate ice strengthening is required for ships sailing in
ice.
Information about ice conditions in the Baltic Sea area
can be obtained from the national ice services. Contact
information of the national ice services and basic information about ice conditions in the Baltic Sea area can be
obtained from the common website of the national ice
services of the Baltic Sea States www.bsis-ice.de.
**********
36
INTERCARGO
Ship Recycling
.3
1. Background
MEPC 52 (11-15 October 2004) approved an MEPC circular on the Guidelines for the development of a ship recycling plan.
MEPC 53 (18 to 22 July 2005) approved an MEPC circular MEPC/Circ.419 on the Implementation of the IMO
Guidelines on ship recycling, providing specific recommendations and guidance to Administrations in recycling
States, shipowners and recycling facilities. Another circular MEPC/Circ.466 on Gas- free- for- hot-work certification in connection with recycling operations was also
approved. The circulars are available for download from
http://www.imo.org/home.asp.
The 24th IMO Assembly (A24) (21 November to 2 December 2005) adopted a resolution to develop the abovementioned instrument and agreed to complete the new
legally binding instrument on ship recycling in time for
consideration and adoption by a diplomatic conference in
the 2008-2009 biennium. The instrument would cover the
design, construction and operation of ships as well as
preparation for the delivery of a ship prior to recycling.
A24 adopted amendments to resolution A.962(23). Contact info@intercargo.org for the sources of the amendments. It was also agreed that the development of a new
legally binding instrument on ship recycling should not
shift the attention of stakeholders away from implementation of the current IMO Guidelines on ship recycling
adopted by Resolution A.962(23). Contact
info@intercargo.org for the source of A.962(23).
2. Draft structure for the new instrument on ship recycling
MEPC 53 developed a preliminary draft structure for the
new instrument on ship recycling and had an initial consideration on a number of issues related to the development of the appropriate mandatory requirements on ship
recycling, including items as outlined in the table at the
end of the article.
3. Green passport
The outcome of MEPC 53 indicated that the Green Passport should contain, at least, the following information on
the ship details:
.1
.2
the name of the State whose flag the ship is entitled

to fly;
the date on which the ship was registered with that
State;
.4
.5
.6
.7
.8
.9
.10
.11
the date on which the ship ceased to be registered with that State;
the ship identification number (IMO number);
hull number on new-building delivery;
the name and type of the ship;
the port at which the ship is registered;
the name of the shipowner and its address;
the name of all classification society(ies) with
which the ship is classed;
the ship main particulars (Length overall (LOA), Breadth (Moulded), Depth
(Moulded), Lightweight); and
shipbuilder name and address.
4. Hazardous Materials Inventory

Inventory of the materials known to be potentially
hazardours, containing the location and the approximate quantity/volume of each identified material on
board the ship, split into the following parts:
Part 1 - Potentially hazardous materials in the ship
structure and equipment;
Part 2 - Operationally generated wastes; and
Part 3 - Stores.
Any changes relating to Part 1 of the inventory
should be recorded so as to provide updated and current information together with a history of the
changes.
Inventories of operationally generated wastes (Part 2
of the inventory) and potentially hazardous
items carried as stores (Part 3 of the inventory)
should be prepared by the shipowner prior to or during the final voyage to the recycling facility and
handed to the recycling facility on delivery of the
ship, as part of the Green Passport.
It is a less confusing issue regarding requirement for
a Green Passport on a newbuilding, on a voluntary
basis, than for the purchase of second hand ship when
its issue of a Green Passport could be confusing no
matter how long an owner intends to keep the ship.
On existing ships, there is still nor firm conclusion as
to when the mandatory requirement will be in place
or to what extent retrospective application will apply.
A cautious approach for existing ship owners is to
prepare for application as soon as possible.
5. Gas Free Certification
At MEPC 53, it was decided that ship owners, ship
recycling facilities and member states will be urged
to consider the matter of gas-freeing vessels in preparation for recycling by circular MEPC/Circ.466 on
INTERCARGO
the Implementation of the IMO Guidelines on Ship Recycling - Gas-free-for-hot-work certification,

6. Responsibility delineation between yard and last
operating owner
Although it encourages ship owners to deliver vessels
with a gas-free-for-hot-work certificate, it recognises
that it is the main responsibility of the ship recycling facility to ensure that those tanks which have been certified
are maintained in the gas-free state. Shipowners are urged
to enter into contract only with those recycling facilities
with the ability to maintain and monitor ships in gasfree-for-hot-work condition during the whole process of
ship recycling.
7. Licensed/Approved recycling Facilities
In the framework of the legal instrument, ship recycling
facilities will also be regulated to ensure safe and environmentally sound recycling. Under the proposed regime,
recycling yards and facilities are required to be licensed/
approved to conduct the recycling business.
8. Intercargo position
Intercargo has the following position on the IMO Convention: Continue to support the development of an IMO
Convention on Ship Recycling, and to underline that the
IMO is the key UN agency on this issue.
Intercargo will:
invite members to provide feedback on the implementation of various aspects of the IMO Guidelines so that this may be presented during the IMO
mandatory process;
ensure an active participation in both the Working
Group and Correspondence Group during MEPC
meetings; and
provide members with continuous feedback on the
development of the Convention
9. References (contact info@intercargo.org for the

sources of information)
1). Resolution A.962(23) IMO Guidelines on ship recycling, adopted on 5 December 2003
2). Amendments to the IMO Guidelines on Ship Recycling (Resolution A.962(23))
3). MEPC/Circ.466 on Implementation of the IMO
Guidelines on Ship Recycling (Assembly resolution
A.962(23))
4). MEPC/Circ.419 on Guidelines for the Development
of the Ship Recycling Plan
38
********
INTERCARGO
Items of the preliminary draft structure for the new instrument on ship recycling
Mandatory Requirement
Guidelines Reference
Recycling Facilities
Recycling State to require operational waste reception facilities at recycling facilities
9.4.2.3
Ship Recyclers to be "licensed"
9.4.4.1
Shipowners required to use approved/licensed recycling facilities
8.1.6
Shipowners to arrange for removal of materials the recycling facility cannot handle
8.1.5
Reporting
Ship Recycling Plan
Recycling facility to prepare a ship recycling plan in consultation with the shipowner
8.3.2.2
Ship Recycling Contract

Shipowners/Recycling facilities to include elements of the Guidelines such as the Ship Recycling Plan, etc. in
recycling contracts
8.3.2.5, 9.2.2,
9.4.3.3, 9.8.2
Potentially Hazardous Materials

States to prohibit/restrict/minimize the use of potentially hazardous materials in new ships
6.1.1, 6.1.4, 6.1.2
Shipbuilders to provide the first shipowner with Part 1 of the inventory
5.5
States to prohibit/restrict/minimize the use of potentially hazardous materials in existing ships
7.2.1
Shipowners to provide an updated inventory of potentially hazardous materials on board on arrival at the recycling facility
5.6
Shipowners to mark assumed and identified potentially hazardous materials included in the inventory and any
potentially hazardous spaces in accordance with the Ship Recycling Plan
8.3.1.1, 8.3.1.2.2,
8.3.3.2.8, 8.3.4.1.24
Shipbuilders to seek advice on limiting the use of identified potentially hazardous materials in ships
6.1.6
Green Passport
Shipbuilders to provide new ships with a Green Passport
5.5, 5.5.1, 5.8
Shipowners to maintain Ship Details and Part 1 of Inventory sections of the Green Passport
5.1, 5.3
Shipowners to prepare Parts 2 and 3 of the Green Passport prior to the final voyage to the recycling facility
5.6
Shipowner to develop Green Passport, Part 1 for existing ships as far as is reasonable and practicable
5.5.2
Shipowners to deliver Green Passport to recycling facility
5.1
Gas Free for Hot Work Certificate

Shipowners to arrange with recycling yard for a "gas-free-for-hot-work" certificate covering enclosed cargo and
other spaces and empty fuel spaces at handover or in accordance with the Ship Recycling Plan
8.3.4.1, 9.4.3.2,
8.1.3.3
Ship Details
Shipowners to hand over the Continuous Synopsis Record to the recycling facility
5.2.1 (Pending
development of the
Green Passport)
INTERCARGO
Oily Water Separators

- New Requirements of the US Coast Guard
New Development
On November 3, 2005, the U.S. Coast Guard published a
Notice of Proposed Rulemaking (NPRM) proposing to
change pollution prevention equipment (PPE) performance
standards to make them consistent with the new International Maritime Organization (IMO) guidelines and specifications issued under Annex I of the International Convention on the Prevention of Pollution from Ships
(MARPOL). In short, the NPRM would:
(1)
(2)
require newly constructed oil tankers to install

cargo monitors meeting new PPE standards; and
require newly constructed vessels and existing
oceangoing vessels (only when an existing vessel is
replacing the exiting PPE) to install oily water separating equipment and bilge alarms to meet new PPE
standards. Comments are due February 1, 2006.
Background
Many in the maritime community have expressed concerns
that existing pollution prevention equipment, especially
technology related to oily water separator systems, does
not work properly. Of particular concern is the processing
of oily bilge waste and the methods by which the oil content of the effluent is measured.
In response to those concerns, the IMO issued Resolution
MEPC.107(49) "Revised Guidelines and Specifications for
Pollution Prevention Equipment for Machinery Space
Bilges of Ships." Subsequently, the Coast Guard issued
MOC Policy Letter No. 04-13, which provides guidance on
implementation of Resolution MEPC.107(49). Please see
http://www.blankrome.com/publications/maritime/
update0405_06.asp dated April 2005 for a discussion of
the IMO guidelines and Coast Guard policy. The Coast
Guard noted that the policy will remain in effect until regulations are promulgated. In addition, IMO issued Resolution MEPC No.108(49), Revised Guidelines and Specifications for Oil Discharge Monitoring and Control Systems
for Oil Tankers, which upgrades cargo monitor PPE standards. The IMO standards become effective internationally
as an amendment to MARPOL on April 1, 2007.
The Proposed Rule
The NPRM would not change the type or class of vessel
that requires a cargo monitor, oily water separator, or bilge
alarm, but would require that such equipment meets the
new IMO PPE standards. The new IMO standards are applicable to vessels newly built on or after January 1, 2005.
Although not clearly stated in the NPRM, under Resolu-
40
tion MEPC No.108(49), cargo monitors originally installed on vessels built before January 1, 2005, may meet
either the new or previous standards when replaced. Oily
water separating equipment and bilge alarms, however,
installed on existing vessels to replace existing equipment must meet the new standards. In addition, the
NPRM would remove existing requirements for bilge
monitors.
The NPRM would require the use of pollution prevention equipment that is more technologically advanced
than that found on most oceangoing vessels now operating. With respect to cargo monitors, the new regulations
would include updated standards for monitors used with
category C and D oil-like noxious liquid substances.
Under the new regulations, oily water separators would
be required to effectively process emulsified oils, surfactants, and contaminants. In addition, the proposed rule
would impose stricter standards for bilge alarms, including requirements that every bilge alarm:
Pass new tests using emulsified oil and contaminants;
Has a ppm display that would display each change
in oil content of the mixture being measured within 5
seconds after the change occurs instead of 20 seconds;
Limit access to the bilge alarm beyond checking
instrument drift, and require the breaking of a seal to
repeat the instrument reading and re-zero the instrument;
Activate the alarm whenever clean water is used for
cleaning or zeroing purposes;
Record date, time, alarm status, and operating status
of the 15 ppm bilge separator;
Store data for at least 18 months; and
Have the ability to display or print a protocol.
Furthermore, in the event that the 15 ppm bilge alarm is
replaced, means must be provided to ensure that the data
recorded remains available on board for 18 months.
Impact of Proposed Rule
Owners and operators should consider the lack of specificity associated with the replacement of PPE in the
NPRM with respect to the applicability to existing vessels. For example, the NPRM provides only that existing
oceangoing vessels subject to the new regulations would
be required to install oily water separating equipment
and bilge alarms that meet the new standards whenever
the owners or operators "replace" the equipment. The
NPRM, however, does not clarify the extent to which
components must be replaced in order to trigger the new
requirements. For example, applicability is unclear when
only parts of an oil-water separator are replaced. This
INTERCARGO
poses several questions: Can owners/operators continually

replace components piecemeal, even when a complete replacement is needed, in order to prevent the expense of a
whole new system? If not, which components can be replaced without requiring a complete replacement?
Owners and operators should take into account the fact that
these new standards apply to PPE equipment placed on
new and existing vessels after January 1, 2005, and will
become enforceable either when made effective by the
Coast Guard, or January 1, 2007, when the MARPOL
amendment becomes effective, whichever comes first. Accordingly, owners and operators should ensure that PPE
equipment installed after January 1, 2005, meets the standards as discussed above in order to avoid possible enforcement action. In addition, the NPRM provides inadequate guidance with regard to the replacement of cargo
monitors on existing vessels. These issues should be carefully considered and commented upon in response to the
NPRM.
Conclusions and Recommendations
Owners, operators, manufacturers, and other interested
parties should review the NPRM carefully to determine the
impact on their operations, comment on the proposed rule
and continue to monitor the development in the US.
********
INTERCARGO
INDEX OF ABBREVIATIONS
A
A24
AIS
AMP
Anti-fouling Convention
ASF Convention
the twenty-fourth regular session of the IMO Assembly

Automatic Identification System
alternative marine power, also referred to as cold ironing
The International Convention on the Control of Harmful Anti- fouling Systems on Ships, 2001
The International Convention on the Control of Harmful Anti-fouling Systems on Ships
B
BC Code
BCH Code
BDN
BLG Sub-Committee
BLU Code
BLU Manual
BWM Convention
the Code of Safe Practice for Solid Bulk Cargoes

the Code for the Construction and Equipment of Ships Carrying Dangerous Chemicals in Bulk
Bunker Delivery Note
The IMO Sub-Committee on Bulk Liquid and Gases
the Code of Safe Practice for the Safe Loading and Unloading of Bulk Carriers
the Manual on Loading and Unloading of Solid Bulk Cargoes for Terminal Representatives
The International Convention for the Control and Management of Ships' Ballast Water and Sediments, 2004
C
CASTEC
cfu
Circ
COLREG
CSR:
The Intercargo Safety, Technical and Environmental Committee

colony forming unit
circular
The Convention on the International Regulations for Preventing Collisions at Sea, 1972
IACS common structural rules
D
D1 or D-1
D2 or D-2.
DE Sub-Committee
Directive 2002/59/EC
DMA
DOC:
DRI
DSC Sub-Committee
Ballast Water Exchange (95% volumetric exchange) or pumping through three time the volume of each tank
Ballast Water Treatment systems approved by the Administration which treat ballast water to an efficacy of:
not more than 10 viable organisms per m3 >50 micrometers in minimum dimension; and not more than 10
viable organisms per millilitre < 50 micrometers in minimum dimension and >10 micrometers in minimum
dimension
The IMO Sub-Committee on Ship Design and Equipment
Establishing a Community vessel traffic and monitoring and information system
Danish Maritime Authority
Document of Compliance
direct reduced iron. When moist, it releases hydrogen as well as creates heat.
The IMO Sub-Committee on Dangerous Goods, Solid Cargoes and Containers
E
EGCS-SOx
EU Directive (2005/33)
EU Directive 2000/59/EC
EU Sulphur Directive
On-Board Exhaust Gas (SOx) Cleaning Systems

The amendments to the EU Directive 1999/32
Port reception facilities for ship-generated waste and cargo residues, 27 November 200
EU Directive (2005/33)
F
FSI Sub-Committee
FUA 12
The IMO Sub-Committee on Flag State Implementation

Follow-up Action No. 12
H
HFO
heavy fuel oil
I
IACS
IAPH
ICS
IFO
IISPCG
IMDG
IMO
INMARSAT
Intercargo
INTERTANKO
42
International Association of Classification Societies

International Association of Ports and Harbours
International Chamber of Shipping
intermediate fuel oil
Inter-Industry Shipping and Ports Contact Group
The Code the International Maritime Dangerous Goods Code
International Maritime Organisation
The Convention on the International Maritime Satellite Organization, 1976
the International Association of Independent Tanker Owners
INTERCARGO
ISM Code
ISO
ISPS Code
the International Management Code for the Safe Operation of Ships and for Pollution Prevention
International Standardisation Organisation
the International Code for the Security of Ships and of Port Facilities
L
LFO
LL
LOP
light fuel oil

The International Convention on Load Lines, 1966
Letter of Protest
M
m/m
MARPOL 73/78
1978
MARPOL Annex I
MARPOL Annex IV
MARPOL Annex V
MARPOL Annex VI
MDO
MEPC
MEPC 49
MEPC 50
MEPC 51
MEPC 52
MEPC 53
MEPC 54
MGO
MSC
MSC 78
MSC 79
MSC 79/4/1
MSC 80
MSC 81
mass of sulphur per mass of fuel in weight

the International Convention for the Prevention of Pollution from Ships, 1973, as modified by the Protocol of
Regulations for the Prevention of Pollution by Oil
Regulations for the Prevention of Pollution by Sewage from Ships
Regulations for the Prevention of Pollution by Garbage from Ships
Regulations for the Prevention of Air Pollution from Ships
marine diesel oil
IMO Marine Environment Protection Committee
the 49th session of IMO MEPC on 14 to 18 July 2003
the 50th session of IMO MEPC on 1 and 4 December 2003
the 51st session of IMO MEPC on 29 March to 2 April 2004
the 52nd session of IMO MEPC on from 11 to 15 October 2004
the 53rd session of IMO MEPC on 18 to 22 July 2005
the 54th session of IMO MEPC on 20 -24 Mar 2006
marine gas oils
IMO Maritime Safety Committee
the 78th session of IMO MSC on 12 to 21 May 2004
the 79th session of IMO MSC on 1 to 10 December 2004
the submitted paper No.1 under agenda item 4 to MSC 79
the 80th session of IMO MSC on 11 to 20 May 2005
the 81st session of IMO MSC on 10 19 May 2006
N
NAVTEX
NGO
NOx
NOx Technical Code
transmission of maritime safety information, including navigational and weather information and forecast
Non-Governmental Organisation
nitrogen oxides
the Technical Code on Control of Emission of Nitrogen Oxides from Marine Diesel Engines
P
ppm
one part of oil per million parts of water by volume
S
SAR
SECA
SMC:
SN/Circ.227
SO2
SOLAS
SOLAS Ch XII
SOx
STCW
The International Convention on Maritime Search and Rescue, 1979

SOx Emission Control Area
Safety Management Certificate (ISM Code)
Circular N0.227 issued by IMO Sub-Committee on Safety of Navigation
sulphur dioxide
the International Convention of the Safety of Life at Sea
Chapter XII of SOLAS Additional safety measures for bulk carriers
sulphur oxides
The International Convention for Standards, Training, Certificates and Watchkeeping for Seafarers, 1978
U
UNCLOS
UR S25:
UV
The United Nations Convention on the Law of the Sea

No.25 of the IACS Unified Requirements concerning Strength of Ships
ultraviolet radiation
INTERCARGO
INTERCARGO
Intercargos vision is for a safe, efficient and environmentally friendly dry cargo maritime
industry where its members ships serve world trade - operating competitively, safely and
profitably.
Intercargo, the International Association of Dry Cargo Shipowners, represents the interests
of 62 Full and 59 Associates members who between them own and operate about 800 dry
cargo ships. Promoting the interests of our member companies in regulatory fora such as
IMO and IACS, Intercargo works closely with the other members of the Round Table of international maritime associations (BIMCO, ICS Intercargo and Intertanko) to promote a safe,
high quality, efficient and profitable industry.
On 1st June 1998, the Intercargo Executive Committee decided to set up a bulk carrier Technical, Safety and Environmental Committee (CASTEC) comprising of selected technical/
operational managers from Intercargo member companies. Leo Cappoen was elected as
CASTEC Chairman in June 2005.
CASTEC is one of Intercargos key Committees. It was established to promote and protect
the interests of the INTERCARGO membership in relation to International, National and
Local Legislation and Regulation as it affects Ship Design, Safe Bulk Carrier Operations and
the Protection of the Environment. It will also foster co-operation with IMO, IACS, Round
Table international shipping associations (BIMCO, ICS, Intercargo and Intertanko) and other
recognised bodies involved with bulk carrier safety and the protection of the environment.
To ensure members views are represented effectively CASTEC meets twice a year, one being the forum for Asian based members the other for those in the Western hemisphere. The
statutory and classification matters debated by IACS and at IMO provide the main areas of
discussion for CASTEC members at these meetings. CASTEC also oversees technical publications such as the annual Bulk Carrier Casualty Report, a new guide on Port State Control
and analysis of ship-terminals interface experiences.
For further information on joining Intercargo, please contact info@intercargo.org.
INTERCARGO
INTERCARGO
Ninth Floor,
St Clare House,30/33 Minories,
London EC3N 1DD
Tel: 020 7977 7030 (Switchboard)
Fax: 020 7977 7031
Email: info@intercargo.org
Web Site: www.intercargo.org

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INTERCARGO

International Association of Dry Cargo Shipowners

Photograph front cover courtesy of Bocimar

Technical and Operational

March 2006 Issue One

Ballast Water Management

Bunkers - MARPOL Annex VI and EU Directive

Cargoes - Direct Reduced Iron..

Entry into Force .

IACS Common Structural Rules...

MARPOL Special Areas.

Oily Water Separators

Particularly Sensitive Sea Areas..

Reception Facilities - Baltic

Technical and Operational Update for Bulk Carriers

Entry into Force

The index contains currently available requirements and

19 May 2005: entry into force

1 Aug 2005: entry into force

4.1 Amendments to SOLAS chapter II-1 concerning

March 2006 Issue One 1

III/19.3.3.3 adopted by Resolution MSC.152 (78).

1 Jul 2006: entry into force

March 2006 Issue One

Technical and Operational Update for Bulk Carriers

Circular MSC/Circ.1145 on Precautionary Advice to

Technical and Operational Update for Bulk Carriers

were adopted by Resolution MSC.194(80). Contact

.3 Administrations may exempt cargo ships from the

Regulation 3-2: Corrosion prevention of seawater

5.6. Unified interpretation of SOLAS Chapter XII

22 Nov 2006: amendment of entry into force

1 Jan 2008: amendment of entry into force

6.1 Amendments to MARPOL Annex VI and the NOx

8.1 Under the terms of the ASF Convention

Amendments to MARPOL Annex VI are the introduction

From 1 January 2007: amendment of entry into force

(a) not bear such compounds on their hulls or external

1 Jan 2009: amendment of entry into force

Technical and Operational Update for Bulk Carriers

10.2 circular MSC/Circ.1142 - MEPC/Circ.425 on

10.3 Resolution MSC.200(80)- Amendments to the

9.2 Annex 2 to Resolution MSC.198(80) - Amendments to

Governments are recommended to apply the

March 2006 Issue One

Technical and Operational Update for Bulk Carriers

Air Pollution Prevention

strate that while the ship is passing through a SOx

March 2006 Issue One 5

Party States to MARPOL Annex VI.

March 2006 Issue One

Technical and Operational Update for Bulk Carriers

between the supplier and the receiver, and that according

The ship is not intending to operate in a SECA. All

3. CO2 index - MEPC Circular 471

Technical and Operational Update for Bulk Carriers

1). MEPC/Circ 472 - PSC Guidelines under Annex VI.

The Intercargo Technical, Safety and Environmental Com-

March 2006 Issue One 7

Technical and Operational Update for Bulk Carriers

Bunkers - MARPOL Annex VI and EU Directive

March 2006 Issue One

oils (MDO) used by ships in intra-European voyages