1 Regulatory Primer for 2nd & Chief Engineers Covering Current and New Regulations Cargo Ship Related Questions Que. What is the IMSBC Code and what does it cover? Ans. The International Maritime Solid Bulk Cargoes Code (IMSBC Code) is mandatory under SOLAS Chapter VI. In 2011, it replaced the Code of Safe Practice for Solid Bulk Cargoes (BC Code), which was first adopted as a recommendatory code in 1965 and has been updated at regular intervals since then. The aim of the IMSBC Code is to facilitate the safe stowage and shipment of solid bulk cargoes, by providing information on the dangers associated with the shipment of certain types of cargo and instructions on the appropriate procedures to be adopted. The IMSBC Code Supplement includes revised updates for: • The Code of Practice for the Safe Loading and Unloading of Bulk Carriers (BLU Code) • the manual on loading and unloading of solid bulk cargoes for terminal representatives (BLU Manual) • uniform method of measurement of the density of bulk cargoes • lists of solid bulk cargoes for which a fixed gas fire- extinguishing system may be exempted or for which a fixed gas fire-extinguishing system is ineffective • recommendations for entering enclosed spaces aboard ships • recommendations on the safe use of pesticides in ships applicable to the fumigation of cargo holds • guidelines for the submission of information and completion of the format for the properties of cargoes not listed in the IMSBC Code and their conditions of carriage Regulatory Primer for 2nd & Chief EngineersRegulatory Primer for 2nd & Chief Engineers 2 • guidelines for developing and approving procedures for sampling, testing and controlling the moisture content for solid bulk cargoes which may liquefy • contact names and addresses of the offices of designated national competent authorities responsible for the safe carriage of grain and solid bulk cargoes. Que. What are the recent amendments to the IMSBC Code? Ans. Amendment 02-13 entered into force on 1st January 2015. IMO Resolution MSC.354(92) contains amendments to Sections 4 and 8 of the IMSBC Code. These aim to increase the responsibility of the competent authority of the load port for approving and ensuring implementation of procedures for sampling, testing and controlling moisture content at a safe level until the cargo is on board the ship. The amendments also highlight that even “if samples remain dry following a can test, the moisture content of the material may still exceed the Transportable Moisture Limit (TML)”. Therefore, proper testing by the load port authorities is vital. The Resolution contains other amendments, which also entered into force on 1st January 2015, affecting in-transit fumigation and hazardous cargoes. Amendment 03-15 entered into force on 1st January 2017. IMO Resolution MSC.393(95) specifies the amendments, which relate to the following sections: application and implementation of the Code, safety of personnel and ship, assessment of acceptability of consignments for safe shipment, cargoes that may liquefy, materials possessing chemical hazards and prevention of pollution by cargo residues from ships. The various appendices, which cover cargoes, were also amended. Amendment 04-17 entered into force on 1st January 2019. This includes matters relating to substances harmful to the marine environment (HME) and amendments to paragraphs 4.5.1 and 4.5.2 of the IMSBC Code, highlighting the responsibility of the shipper Regulatory Primer for 2nd & Chief EngineersRegulatory Primer for 2nd & Chief Engineers 3 for ensuring that a test to determine the TML of a solid bulk cargo is conducted. Amendment 05-19 was adopted in June 2019 and will enter into force on 1st January 2021. The 2019 amendments include updates to various schedules (such as a new individual schedule for BAUXITE FINES as a Group A cargo), as well as editorial amendments. The amendments are incorporated into a consolidated IMSBC Code. Amendments may be applied in whole, or in part, on a voluntary basis from 1st January 2020. Que. What are the IMSBC Code cargo groups and how are they applied? Ans. The IMSBC Code categorises cargoes into three groups: • Group A – cargoes that may liquefy if shipped at a moisture content exceeding their Transportable Moisture Limit (TML) • Group B – cargoes that possess a chemical hazard that could give rise to a dangerous situation • Group C – cargoes that are neither liable to liquefy (Group A) nor possess chemical hazards (Group B), but can still be hazardous. Que. What sources of guidance are available for personnel carrying out tanker operations? Ans. The ship’s safety management system (SMS) should be the first point of reference before carrying out any operation. Additional sources of guidance include, but are not limited to: • Industry guidance from bodies such as CDI, ICS, INTERTANKO, OCIMF and SIGTTO, including publications such as: ‘International Safety Guide for Oil Tankers and Terminals’ (ISGOTT) ‘Liquefied Gas Handling Principles on Ships and in Terminals’ (LGHP4) ‘Ship to Ship Transfer Guide for Petroleum, Chemicals and Liquefied Gases’ Regulatory Primer for 2nd & Chief EngineersRegulatory Primer for 2nd & Chief Engineers 4 • Codes such as the IMDG Code, IBC Code and IGC Code • Guidance Manual for Tanker Structures • The MARPOL and SOLAS Conventions • Material Safety Data Sheets (MSDS) • Onboard plans and manuals • Code of Safe Working Practices for Merchant Seafarers (COSWP). Que. Are tankers permitted to blend liquid cargoes at sea? Ans. The physical blending of bulk liquid cargoes at sea is prohibited. Regulation 5-2 of SOLAS Chapter VI, on the prohibition of the blending of bulk liquid cargoes and production processes during sea voyages, has been in force since 1st January 2014. There are separate requirements for the transport and handling of limited amounts of hazardous and noxious liquid substances in bulk on offshore support vessels (see Resolution A.673(16), as amended). Ref: SOLAS Consolidated Edition, MSC.325(90) Que. What are the current UK regulations and guidance on ship to ship (STS) operations? Ans. The UK Ship to Ship Transfer Regulations 2010/2012 are set out in MSN 1829. The key points are: • Ship to ship transfers, including most bunkering operations, outside of port authority areas are prohibited within the UK territorial sea with the exception of an identified area near Southwold on the east coast, for operations • for transfers within the area, detailed technical requirements apply to STS operations including a need to provide 72 hours’ notice • outside of the UK territorial sea, but within the UK Pollution Control Zone, ship to ship transfers are permitted but must be Regulatory Primer for 2nd & Chief EngineersRegulatory Primer for 2nd & Chief Engineers 5 notified to the MCA no less than 48 hours before the transfer on a ‘for information’ basis • UK-flagged oil tankers involved in STS operations internationally are required to carry a plan prescribing how to conduct STS operations in line with MARPOL Annex I. Additionally, the ‘Ship to Ship Transfer Guide for Petroleum, Chemicals and Liquefied Gases’ is a joint industry-wide publication that contains specific guidance for STS operations. It includes information on effective planning, executing the operation, risk assessment, ship compatibility and the management of workloads to minimise fatigue. Ref: MSN 1829, Ship to Ship Transfer Guide Que. What are the requirements for inert gas on tankers and why? Ans. Inert gas is a mixture of gases that together contain insufficient oxygen to support combustion. It is an essential safety system to prevent ignition of flammable vapours in cargo tanks carrying hydrocarbons. Inert gas, principally composed of nitrogen, is usually produced by inert gas generators or flue exhaust gas systems on board, although it can be obtained in limited circumstances from ashore. The requirements for tankers to be fitted with inert gas systems have been phased in, by size since 1974, by SOLAS. The most recent amendment to SOLAS and the Fire Safety Systems Code on inert gas was in 2014. This stated that from 1st January 2016 all new tankers of 8,000 DWT and above must use inert gas. However, vessels of less than 20,000 DWT are permitted to use inert gas supplied from ashore. In practice, most tankers are fitted with inert gas systems, so they can operate safely and effectively in tanker terminals. Regulatory Primer for 2nd & Chief EngineersRegulatory Primer for 2nd & Chief Engineers 6 Que. How is the atmosphere in cargo spaces monitored on tankers? Ans. SOLAS Regulation II-2/4 requires that all oil tankers are fitted with equipment that can measure both oxygen concentrations and flammable vapour concentrations on board. This is in addition to requirements for the carriage of at least one portable instrument capable of measuring flammable vapour concentrations. It is essential that these values are monitored during inerting, purging and gas-freeing operations. Monitoring the values during purging (when inert gas is added to prevent ignition of flammable vapours) is necessary to prevent the atmosphere in the tank entering the flammable range during the gas-freeing process (when oxygen is introduced). Additionally, tankers greater than 20,000 DWT, constructed on or after 1st January 2012, that do not have a constant inerting system for ballast and void spaces adjacent to cargo tanks are required by SOLAS to be provided with a fixed hydrocarbon gas detection system, fitted with audible and visual alarms in the CCR and ECR and on the bridge. Other portable measuring units should be available on board to monitor the particular characteristics of the cargo, particularly where it requires the application of additional safety procedures, for example hazardous chemical cargoes or cargoes such as benzene. Que. On a tanker, what information would you expect to find that deals with the management of emissions of cargo vapours or VOCs (volatile organic compounds) into the atmosphere? Ans. There should be an approved VOC Management Plan on board that demonstrates the procedure for eliminating VOC emissions. The plan should be compiled in accordance with IMO guidelines (MEPC.185(59) and MEPC.1/Circ.680) and should provide details on managing emissions during loading, passage and discharge. It should include information on the Vapour Emission Control