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Carriage of chemicals by ship

Regulations governing the carriage of chemicals by ship are contained in the International Convention for the Safety of Life at Sea (SOLAS) and the International Convention for the Prevention of Marine Pollution from Ships, as modified by the Protocol of 1978 relating thereto (MARPOL 73/78).

The regulations cover chemicals carried in bulk, on chemical tankers, and chemicals carried in packaged form.

Regulations covering chemicals carried in bulk
MARPOL Annex II
Transport of vegetable oils
Chemicals carried in packaged form
Liability and Compensation for Damage in Connection with the Carriage of Hazardous and Noxious Substances
Preparedness and response - dealing with pollution incidents involving chemicals

Chemicals carried in bulk

Carriage of chemicals in bulk is covered by regulations in SOLAS Chapter VII - Carriage of dangerous goods and MARPOL Annex II - Regulations for the Control of Pollution by Noxious Liquid Substances in Bulk.

Both Conventions require chemical tankers built after 1 July 1986 to comply with the International Bulk Chemical Code (IBC Code), which gives international standards for the safe transport by sea in bulk of liquid dangerous chemicals, by prescribing the design and construction standards of ships involved in such transport and the equipment they should carry so as to minimize the risks to the ship, its crew and to the environment, having regard to the nature of the products carried.

The basic philosophy is one of ship types related to the hazards of the products covered by the Codes.  Each of the products may have one or more hazard properties which include flammability, toxicity, corrosivity and reactivity.

The IBC Code lists chemicals and their hazards and gives both the ship type required to carry that product as well as the environmental hazard rating.

Chemical tankers constructed before 1 July 1986 should comply with the requirements of the Code for the Construction and Equipment of Ships Carrying Dangerous Chemicals in Bulk (BCH Code) – the predecessor of the IBC Code.

MARPOL Annex II

The Annex II Regulations for the control of pollution by noxious liquid substances in bulk define a four-category categorization system for noxious and liquid substances.

The categories are:

• Category X: Noxious Liquid Substances which, if discharged into the sea from tank cleaning or deballasting operations, are deemed to present a major hazard to either marine resources or human health and, therefore, justify the prohibition of the discharge into the marine environment;
• Category Y: Noxious Liquid Substances which, if discharged into the sea from tank cleaning or deballasting operations, are deemed to present a hazard to either marine resources or human health or cause harm to amenities or other legitimate uses of the sea and therefore justify a limitation on the quality and quantity of the discharge into the marine environment;
• Category Z: Noxious Liquid Substances which, if discharged into the sea from tank cleaning or deballasting operations, are deemed to present a minor hazard to either marine resources or human health and therefore justify less stringent restrictions on the quality and quantity of the discharge into the marine environment; and
• Other Substances: substances which have been evaluated and found to fall outside Category X, Y or Z because they are considered to present no harm to marine resources, human health, amenities or other legitimate uses of the sea when discharged into the sea from tank cleaning of deballasting operations. The discharge of bilge or ballast water or other residues or mixtures containing these substances are not subject to any requirements of MARPOL Annex II.

The annex also includes a number of other requirements reflecting modern stripping techniques, which specify discharge levels of products which have been incorporated into Annex II. For ships constructed on or after 1 January 2007 the maximum permitted residue in the tank and its associated piping left after discharge is set at a maximum of 75 litres for products in categories X, Y and Z (compared with previous limits which set a maximum of 100 or 300 litres, depending on the product category).

The marine pollution hazards of thousands of chemicals have been evaluated by the Evaluation of Hazardous Substances Working Group, giving a resultant GESAMP Hazard Profile which indexes the substance according to its bio-accumulation; bio-degradation; acute toxicity; chronic toxicity; long-term health effects; and effects on marine wildlife and on benthic habitats.

As a result of the hazard evaluation process and the categorization system, vegetable oils which were previously categorized as being unrestricted are now required to be carried in chemical tankers. The Annex includes, under regulation 4 Exemptions, provision for an Administration to exempt ships certified to carry individually identified vegetable oils, subject to certain provisions relating to the location of the cargo tanks carrying the identified vegetable oil.

Transport of vegetable oils
An MEPC resolution on Guidelines for the transport of vegetable oils in deep tanks or in independent tanks specially designed for the carriage of such vegetable oils on board dry cargo ships was adopted in October 2004. It allows general dry cargo ships that are currently certified to carry vegetable oil in bulk to continue to carry these vegetable oils on specific trades. The guidelines took effect on 1 January 2007.

Consequential amendments to the IBC Code
Consequential amendments to the International Bulk Chemical Code (IBC Code) have been adopted, reflecting the changes to MARPOL Annex II. The amendments incorporate revisions to the categorization of certain products relating to their properties as potential marine pollutants as well as revisions to ship type and carriage requirements following their evaluation by the Evaluation of Hazardous Substances Working Group.

Ships constructed after 1986 carrying substances identified in chapter 17 of the IBC Code must follow the requirements for design, construction, equipment and operation of ships contained in the Code.

Chemicals carried in packaged form

Chemicals which are carried in packaged form or in solid form or in bulk are regulated by Part A of SOLAS Chapter VII - Carriage of dangerous goods which includes provisions for the classification, packing, marking, labelling and placarding, documentation and stowage of dangerous goods.

Contracting Governments are required to issue instructions at the national level and the Chapter refers to International Maritime Dangerous Goods (IMDG) Code, developed by IMO, which is constantly updated to accommodate new dangerous goods and to supplement or revise existing provisions.

The IMDG Code was developed as a uniform international code for the transport of dangerous goods by sea covering such matters as packing, container traffic and stowage, with particular reference to the segregation of incompatible substances. The IMDG Code includes products considered to be marine pollutants.  IMO’s Maritime Safety Committee decided in principle, at its 73^rd session in Nov-Dec 2000, to make some parts of the IMDG Code mandatory.

MARPOL Annex III includes regulations for the prevention of pollution by harmful substances in packaged form and includes general requirements for the issuing of detailed standards on packing, marking, labelling, documentation, stowage, quantity limitations, exceptions and notifications for preventing pollution by harmful substances. For the purpose of Annex III, “harmful substances” are those identified as “marine pollutants” in the IMDG Code.

International Convention on Liability and Compensation for Damage in Connection with the Carriage of Hazardous and Noxious Substances  (HNS) by Sea 1996

The Convention, when it enters into force,  will make it possible for compensation to be paid out in compensation to victims of accidents involving HNS, such as chemicals.

HNS are defined by reference to lists of substances included in various IMO Conventions and Codes. These include oils; other liquid substances defined as noxious or dangerous; liquefied gases; liquid substances with a flashpoint not exceeding 60°C; dangerous, hazardous and harmful materials and substances carried in packaged form; and solid bulk materials defined as possessing chemical hazards.

The Convention also covers residues left by the previous carriage of HNS, other than those carried in packaged form.

The Convention defines damage as including loss of life or personal injury; loss of or damage to property outside the ship; loss or damage by contamination of the environment; the costs of preventative measures and further loss or damage caused by them.

The Convention introduces strict liability for the shipowner and a system of compulsory insurance and insurance certificates.

Preparedness and response - dealing with pollution incidents involving chemicals

The 2000 Protocol on Preparedness, Response and Co-operation to pollution Incidents by Hazardous and Noxious Substances, 2000 (HNS Protocol) is based on the International Convention on Oil Pollution Preparedness, Response and Co-operation (OPRC), which was adopted in November 1990 and is designed to help Governments combat major oil pollution incidents.

The Convention and Protocol are designed to facilitate international co-operation and mutual assistance in preparing for and responding to a major oil pollution incident and to encourage States to develop and maintain an adequate capability to deal with pollution emergencies.