INTERNATIONAL MARITIME ORGANIZATION

E
IMO

MARINE ENVIRONMENT PROTECTION MEPC 56/6/7

COMMITTEE 4 May 2007
56th session Original: ENGLISH
Agenda item 6

INTERPRETATION AND AMENDMENTS OF MARPOL 73/78

AND RELATED INSTRUMENTS

Clarification on the carriage of vegetable oil by Ship Type 2 and Ship Type 3
chemical tankers

Submitted by the Republic of Korea

SUMMARY
Executive summary: This paper proposes clarification on the operational volume restriction
imposed on Ship Type 2 and Ship Type 3 chemical tankers when
carrying vegetable oil
Action to be taken: Paragraph 7
Related documents: Regulation 4.1.3 of MARPOL Annex II and the IBC Code
(chapters 16 and 17)

Background

1 The revised MARPOL Annex II was adopted on 15 October 2004 by resolution

MEPC.118(52) and entered into force on 1 January 2007. Also, with effect from 1 January 2007,
vegetable oils have been moved to chapter 17 of the IBC Code and, accordingly, must be carried
by Ship Type 2 chemical tankers only.

Exemptions

2 Notwithstanding the above, and in accordance with regulation 4.1.3 of the revised
MARPOL Annex II, the Administration may exempt ships from the carriage requirements under
regulation 11 for ships certified to carry individually identified vegetable oils identified by the
relevant footnote in chapter 17 of the IBC Code, provided the ship complies with the following
conditions:

.1 the NLS tanker shall meet all requirements for Ship Type 3 as identified in the
IBC Code except for cargo tank location;

.2 cargo tanks shall be located at the distances inboard in accordance with

regulations 4.1.3.2.1 and 4.1.3.2.2 of MARPOL Annex II. The entire cargo tank
length shall be protected by ballast tanks or spaces other than tanks that carry oil;
and

.3 the relevant certificate shall indicate the exemption granted.

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3 In addition, concerning the maximum allowable quantity of cargo per tank, chapter 16 of
the IBC Code Operational Requirements defines that the quantity of cargo required to be
carried in a Type 2 ship shall not exceed 3,000 m3 in any one tank.

4 In this regard, some shipowners operating Ship Type 2 chemical tankers with individual
tank capacity in excess of 3,000 m3 have voiced their concern that a number of Administrations
do not allow Ship Type 2 chemical tankers to carry vegetable oil in excess of 3,000 m3 per
individual tank, while allowing Ship Type 3 chemical tankers to carry vegetable oils without
such operational volume restriction, despite the fact that Ship Type 2 chemical tankers offer more
structural protection than Ship Type 3 chemical tankers. In such cases, shipowners would need
to change the Certificate of Fitness from a Ship Type 2 to a Ship Type 3 whenever they want to
carry a vegetable oil in quantities over 3,000 m3 in any one tank, which would be considered an
unreasonable procedure given the circumstances.

5 Furthermore, there have been cases where an Administration has granted its permission to
Ship Type 2 chemical tankers under its flag to carry vegetable oils without the operational
volume restriction but, at same time, has been notified that the port authorities, i.e. the loading
port or discharge port authorities, have decided to apply the operational volume requirement not
exceeding 3,000 m3.

Proposal

6 To facilitate the uniform application of the operational requirements for the carriage of
vegetable oils by tankers of different types, the Republic of Korea proposes that the Committee
considers the above matter and provides clear interpretation for Administrations in which type of
chemical tanker with individual tank capacity in excess of 3,000 m3, as discussed in paragraph 4
above, vegetable oils are permitted to be carried without the operational volume restriction. It is
also proposed that such interpretation, if supported by the Committee, should be circulated to all
Parties to provide uniform understanding to Administrations and port authorities alike.

Action requested of the Committee

7 The Committee is invited to consider the above information and decide as appropriate.

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