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INTERCARGOInternational Association of Dry Cargo Shipowners

Joint Technical SeminarAnnex V for Dry Bulk22nd November, 2006

byRoger Holt

Secretary General

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Annex V and the problems associated with water washing

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Agenda:

- Introduction to Intercargo- The Round Table of International Shipping Associations- India and Dry Bulk- The Regulator and Rule Maker- MARPOL Annex V- Port Reception Facilities- Water Washing

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Introduction to INTERCARGO

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- The International Association of Dry Cargo Shipowners

- Representation of Bulk Carrier Owner/Operator interests

- Direct entry organisation

- Specialising in Bulk Carrier issues

- Promotion of Safety, Quality, Efficiency and Profitability

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- 120 Full and Associate Members

- 900 bulk carriers over 10,000 dwt

- Inclusive of Operators as full members

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The Round Table of international shipping associations

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• BIMCO, International Chamber of Shipping, Intertanko and Intercargo

• Established 1998• Probably covers about 90% of the world’s

tonnage• Designed to improve efficiency, identify major

issues, be more effective with the regulator, prevent surprises, enhance cooperation

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Round Table summary:

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INTERCARGOTypical issues:

• Tripartite Dialogue – 5th annual meeting in Seoul in September• Dialogue with the Asia Shipowners Forum • Dialogue on Piracy – Malacca Straits• Industry Code on Recycling• Industry Guidelines on Flag State Performance

However, recognition that each Association is answerable to its own management

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India and Dry Bulk

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INDIA & DRY BULK

Ownership & Control

• 20 Dry Bulk companies trading internationally (10,000dwt+ vessels)

• 92 Dry Bulk vessels controlled within India plus another 16 elsewhere

• 12th largest ownership concentration globally

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DRY BULK OPPORTUNITIES

• Average age of Indian fleet – 18.65 years (international average – 14.76 years

• World GDP growing at c. 5% p.a : India c. 6%• Management and manning advantages • Clusters – Class; Shipyards; Training Colleges

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The Regulator and Rule Maker

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• IMO• National Administrations • Regional Administrations• State Legislation• Classification Societies • Flag States • Port States

There is conflict between a number of these authorities e.g. EU SSP

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The Regulation of Shipping

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IMO Conventions and Protocols• Safety prime importance – SOLAS, maritime traffic, load lines,

carriage of dangerous goods, etc• Pollution – MARPOL 73/78• Liability conventions• International Mobile Satellite Organization (1970) • Global Maritime Distress and Safety System (1999)• Standards of Training, Certification and Watchkeeping

(1978)

In total, around 40 Conventions and Protocols have been adopted.

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Sample of regulatory topics

• IACS/Common Structural Rules

• IMO/Goal Based Standards

• MARPOL/Annex V

• MARPOL/Annex VI

• EU/Competition Law

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MARPOL Annex V

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- Annex V in force December 1988

- Regulation for the prevention of pollution by Garbage

- Garbage includes all kinds of food, domestic and operational waste …….

- Amendment to Garbage Record Book in force on 1st August 2005 includes:

* Cargo residues

* Position of the ship

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Procedures to be followed:

- Garbage categories in the GRB must include cargo residues- Cargo residue disposal must be recorded giving start and stop lat/long positions- Disposal prohibited < 12nm to nearest land - In a Special Area, cargo residues cannot be disposed into the sea- MARPOL requirements are the minimum; port states may be more stringent

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Special Areas

Adopted Entry into force In effect

• Mediterranean Sea 02 Nov 1973 31 Dec 1988 -• Baltic Sea 02 Nov 1973 31 Dec 1988 01 Oct 1989• Black Sea 02 Nov 1973 31 Dec 1988 -• Red Sea 02 Nov 1973 31 Dec 1988 -• ‘Gulfs Area’ 02 Nov 1973 31 Dec 1988 -• North Sea 17 Oct 1989 18 Feb 1991 18 Feb 1991• Antarctic Area 16 Nov 1990 17 Mar11992 17 Mar 1992• Caribbean Sea 04 July 1991 04 April 1993 -

+ Gulf of Mexico

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Special Areas (cont.)

The Special Areas where the requirements have not taken effect may be due to the following reasons:

- Lack of adequate reception facilities;

- Lack of ratification of the Convention by Coastal States

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Operational Wastes are defined ascargo-associated waste and maintenance wasteand cargo residue.

Cargo Residues are defined as the remnants ofany cargo material on board which cannot beplaced in cargo holds plus spillage during loading(spillage) or which remain in cargo holds plus spillage after unloading

A few definitions:

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• Cargo residues are expected to be in small quantities• Cargo material contained in the cargo hold bilge water is not treated as cargo residue• Such bilge water must be discharged from a loaded hold through the ship’s fixed piping bilge drainage system

Plus:

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Port Reception Facilities

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Regulation 7 of Annex V states:

• Each party to the Convention undertakes to ensure the provision of reception facilities at ports and terminals for the reception of garbage :-

1) Without causing undue delay to ships

2) According to the needs of the ships using them

• Each party to the Convention shall notify the IMO of all cases where the facilities provided are alleged to be inadequate

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INTERCARGOPort Reception Facilities Database (PRFD)

• FSI13 instructed the IMO Secretariat to develop the PRFD as a module of GISIS (Global Integrated Shipping Information System)• Reports on alleged inadequacy of reception facilities to be made publicly available on the IMO PRFD• Follow-up response by the port States to be posted within 3 months after receipt of notification of inadequacy• PRFD went live 1st March 2006• Member States enter own port reception facilities • Public access on a view-only basis• Website: http//gisis.imo.org

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Port Reception Facility Data (cont.)

Three main tools available to the user in GISIS:-- Location of reception facility in a port- Search for available reception facilities in a port- Locate information on alleged inadequacies

Plus, there is an industry PRF Forum which:-

- Aims to ensure the provision and use of PRF internationally as per MARPOL;- Focus on technical and operational matters (avoid political);- Meets twice a year; produces an Action List

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Cargo Hold Water Wash

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Cleaning after Green Delayed Petcoke

• Sweep and remove all solids• High pressure water wash all holds with warm water (50-60deg C)• Footprint/staining will be left behind on hold coating• Use detergents as prescribed by MEPC Circular MEPC.2/Circ.8• Pump out to port reception facility

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- Provided the prescribed detergent has been used, the oily content or sheen will be emulsifed into a harmless solution.

- Retain the water wash solution on board in a suitable tank.

- Pump out the harmless solution into the ocean not less than 50nm from land as prescribed in Annex I.

- Here we have a joining of bulk carrier and tanker interests.

What happens if the port or terminal will not or cannot accept the Water Wash?

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Warning!

If you do not supply the correct detergent for cleaning as laid down by MEPC Circular MEPC.2/Circ.8 your Master will have severeproblems:

- Port reception facilities will almost certainly refuse to take the solution;

- It cannot be pumped out at sea – ANYWHERE.

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• The amendments to the Garbage Record Book may cause PSC problems• Not all Special Areas have a strict ban on disposal of cargo residue at sea• Bilge water in loaded hold condition does not contain cargo residue – by definition• Refer to PRFD on GISIS and report inadequate facilities• Take care with disposal of hold water wash

In Conclusion:

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Finally ….

Do not create problems for your Master andhave him branded as a criminal!

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INTERNATIONAL ASSOCIATION OF DRY CARGO SHIPOWNERS

Thank you

www.intercargo.orgwww.shippingfacts.comhttp//gisis.imo.orgwww.themaritimefoundation.com