SINGLE HULL OIL TANKERS

Single-hull oil tanker phase-out

What happened on 5 April 2005?

On 5 April 2005, amendments to Annex I of MARPOL 73/78, adopted by IMO's Marine Environment Protection Committee (MEPC) by resolution MEPC.111(50) in December 2003, entered into force for all Parties to the MARPOL Convention.

How many flag States does this affect?

MARPOL (Annexes I and II) has been ratified by 130 countries representing 97.07 per cent of world merchant shipping tonnage. See status of Conventions

What are the amendments exactly?

The amendments revised the existing regulation 13G on Prevention of accidental oil pollution - Measures for existing oil tankers of Annex I of MARPOL 73/78 and added a new regulation 13H on Prevention of oil pollution from oil tankers carrying heavy grade oil as cargo. Consequential amendments to the Condition Assessment Scheme (CAS) for oil tankers were also adopted.

What does the revised regulation 13G say?

The revised regulation brings forward the phase-out schedule that was first established in 1992, and revised in 2001 for existing single-hull tankers. It says that tankers which are single hull should be phased out or converted to a "double hull" by the dates set out in the revised regulation.

What is the phase-out timetable?

The phase-out schedule is now as follows:

Category of oil tanker	Date or year
Category 1 - oil tankers of 20,000 tons deadweight and above carrying crude oil, fuel oil, heavy diesel oil or lubricating oil as cargo, and of 30,000 tons deadweight and above carrying other oils, which do not comply with the requirements for protectively located segregated ballast tanks (commonly known as Pre-MARPOL tankers)	5 April 2005 for ships delivered on 5 April 1982 or earlier Anniversary date in 2005 for ships delivered after 5 April 1982
Category 2 - oil tankers of 20,000 tons deadweight and above carrying crude oil, fuel oil, heavy diesel oil or lubricating oil as cargo, and of 30,000 tons deadweight and above carrying other oils, which do comply with the protectively located segregated ballast tank requirements (MARPOL tankers) and Category 3 - oil tankers of 5,000 tons deadweight and above but less than the tonnage specified for Category 1 and 2 tankers	5 April 2005 for ships delivered on 5 April 1977 or earlier Anniversary date in 2005 for ships delivered after 5 April 1977 but before 1 January 1978 Anniversary date in 2006 for ships delivered in 1978 and 1979 Anniversary date in 2007 for ships delivered in 1980 and 1981 Anniversary date in 2008 for ships delivered in 1982 Anniversary date in 2009 for ships delivered in 1983 Anniversary date in 2010 for ships delivered in 1984 or later

What about the Condition Assessment Scheme (CAS)?

The CAS for oil tankers was adopted in 2001 alongside the revised phase-out schedule and is applicable to certain oil tankers under regulations 13G and 13H.

Although the CAS does not specify structural standards in excess of the provisions of other IMO conventions, codes and recommendations, its requirements stipulate more stringent and transparent verification of the reported structural condition of the ship and require that documentary and survey procedures have been properly carried out and completed.

The requirements of the CAS include enhanced and transparent verification of the reported structural condition of the ship and verification that the documentary and survey procedures have been properly carried out and completed. The Scheme requires that compliance with the CAS is assessed during the Enhanced Survey Programme of Inspections concurrent with intermediate or renewal surveys currently required by resolution A.744(18), as amended.

Under the revised regulation 13G, the Condition Assessment Scheme (CAS) is applicable to all single-hull tankers aged 15 years, or older.

Can any single hull tankers operate beyond the dates set?

The revised regulation 13G allows the Administration (flag State) to permit continued operation of category 2 or 3 tankers beyond its phase-out date in accordance with the schedule subject to satisfactory results from the CAS, but the continued operation must not go beyond the anniversary of the date of delivery of the ship in 2015 or the date on which the ship reaches 25 years of age after the date of its delivery, whichever is earlier.

In the case of certain Category 2 or 3 oil tankers fitted with only double bottoms or double sides not used for the carriage of oil and extending to the entire cargo tank length or tankers fitted with double hull spaces not meeting the minimum distance protection requirements, which are not used for the carriage of oil and extend to the entire cargo tank length, the Administration may allow continued operation beyond its phase-out date in accordance with the schedule, provided that the ship was in service on 1 July 2001, the Administration is satisfied by verification of the official records that the ship complied with the conditions specified and that those conditions remain unchanged. Again, such continued operation must not go beyond the date on which the ship reaches 25 years of age after the date of its delivery.

A Party to MARPOL 73/78 can deny entry of single hull tankers which have been allowed to continue operation under the exemptions mentioned above, into the ports or offshore terminals under its jurisdiction.

Which Administrations have communicated information on their implementation of the regulations?

Parties to MARPOL applying the provisions allowing for extended operation of category 2 or 3 tankers and Parties which will deny entry to those tankers must communicate this information to IMO. Please see circulars under the section Implementation of regulations 13G/13H

What about tankers which have been converted, how do you determine the date of delivery?

IMO's MEPC, at its 52nd session in October 2004, adopted a unified interpretation to regulation 13G(4) of MARPOL Annex I on Major Conversion, which clarified the situation.

It states that "For the purpose of determining the application date for the requirements of regulation 13G(4) of MARPOL Annex I, where an oil tanker has undergone a major conversion, as defined in regulation 1 of MARPOL Annex I, that has resulted in the replacement of the fore-body, including the entire cargo carrying section, the major conversion completion date of the oil tanker shall be deemed to be the date of delivery of the ship referred to in regulation 13G(4) of MARPOL Annex I, provided that:

• the oil tanker conversion was completed before 6 July 1996;
• the conversion included the replacement of the entire cargo section and fore-body and the tanker complies with all the relevant provisions of MARPOL Annex I applicable at the date of completion of the major conversion; and
• the original delivery date of the oil tanker will apply when considering the 15 years of age threshold relating to the first CAS survey to be completed in accordance with regulation 13G(6) of MARPOL Annex I.

What about heavy grades of oil (regulation 13H)

MARPOL regulation 13H on the prevention of oil pollution from oil tankers when carrying heavy grade oil (HGO) bans the carriage of HGO in single-hull tankers of 5,000 tons deadweight (DWT) and above after the date of entry into force of the regulation (5 April 2005), and in single-hull oil tankers of 600 DWT and above but less than 5,000 tons DWT, not later than the anniversary of their delivery date in 2008.

Under regulation 13H, HGO means any of the following:

• crude oils having a density at 15ºC higher than 900 kg/m3;
• fuel oils having either a density at 15ºC higher than 900 kg/ m3 or a kinematic viscosity at 50ºC higher than 180 mm2/s;
• bitumen, tar and their emulsions.

In the case of certain Category 2 or 3 tankers carrying HGO as cargo, fitted only with double bottoms or double sides, not used for the carriage of oil and extending to the entire cargo tank length, or tankers fitted with double hull spaces not meeting the minimum distance protection requirements which are not used for the carriage of oil and extend to the entire cargo tank length, the Administration, under certain conditions, may allow continued operation of such ships beyond 5 April 2005 until the date on which the ship reaches 25 years of age after the date of its delivery.

Regulation 13H also allows for continued operation of oil tankers of 5,000 DWT and above, carrying crude oil with a density at 15ºC higher than 900 kg/ m3 but lower than 945 kg/ m3, if satisfactory results of the Condition Assessment Scheme warrant that, in the opinion of the Administration, the ship is fit to continue such operation, having regard to the size, age, operational area and structural conditions of the ship and provided that the continued operation shall not go beyond the date on which the ship reaches 25 years after the date of its delivery.

The Administration may allow continued operation of a single hull oil tanker of 600 DWT and above but less than 5,000 DWT, carrying HGO as cargo, if, in the opinion of the Administration, the ship is fit to continue such operation, having regard to the size, age, operational area and structural conditions of the ship, provided that the operation shall not go beyond the date on which the ship reaches 25 years after the date of its delivery.

The Administration may exempt an oil tanker of 600 DWT and above carrying HGO as cargo if the ship is either engaged in voyages exclusively within an area under the Party's jurisdiction, or is engaged in voyages exclusively within an area under the jurisdiction of another Party, provided the Party within whose jurisdiction the ship will be operating agrees. The same applies to vessels operating as floating storage units of HGO.

A Party to MARPOL 73/78 can deny entry of single hull tankers carrying HGO which have been allowed to continue operation under the exemptions mentioned above, into the ports or offshore terminals under its jurisdiction, or deny ship-to-ship transfer of heavy grade oil in areas under its jurisdiction except when this is necessary for the purpose of securing the safety of a ship or saving life at sea.

How many oil tankers are affected by the phase-out in regulation 13G?

It is hard to give an exact figure as the number of oil tankers currently in operation needs to be considered. Oil tankers may be taken out of service for many different reasons or may be laid up at any specific time.

There are some figures available. According to figures produced by SSY Research, reported in Tradewinds (15.10.04), there are 173 single-hull tankers of over 200,000 DWT in existence, out of a total VLCC and ULCC fleet of 455 vessels. The single-hull VLCC fleet comprises a combined 46.8 million DWT, of the world VLCC and ULCC fleet total of 131.4 million DWT. There are still 14 vessels of pre-1980s vintage and 10 built between 1980 and 1984. After that the numbers increase, with 42 ships of 10.75 million DWT built in the period from 1985 to 1989.

Will there be enough ship recycling capacity to absorb all the ships taken out of service?

This issue was raised at the MEPC when the amendments were adopted. The MEPC adopted Resolution MEPC.113(50) Ship recycling for the smooth implementation of the amendments to Annex I of MARPOL 73/78.

The resolution recommends that Member Governments, especially the Governments of countries with shipbuilding, ship recycling and other shipping interests:

(a)	take initiatives to maintain adequate ship recycling facilities at world-wide level, based on the evaluation of the impact of the amendments to Annex I of MARPOL 73/78 on the demand for ships to be recycled; and
(b)	endeavour to promote research and development programmes to improve environment and safety level in ship recycling operation.