Carriage of Biofuels

in Bulk by Sea
The Legislative Process at IMO

Janet Strode
General Manager
International Parcel Tankers Association
IPTA
„ BIOALCOHOL : alcohol obtained from
biological sources such as sugar or corn -
Ethanol

„ BIODIESEL– generic name for fuels

obtained by transesterification of a
vegetable oil or animal fat - Fatty Acid
Methyl Ester (FAME)

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These products considered as
Noxious Liquid Substances
and as such fall under the
purview of MARPOL Annex II
and the IBC Code

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IBC Code - Reg. 16.2.2

“Any cargo offered for bulk shipment

shall be indicated in the shipping
document by the product name under
which it is listed in chapter 17 or 18 of
the IBC Code or the latest edition of the
MEPC.2/Circ. or under which it has
been provisionally assessed.”

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 Biodiesel
Bio-Alcohol
Biofuel

THESE TERMS DO NOT APPEAR

IN THE IBC CODE

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Ethanol

„ IBC Code Chapter 18

„ Pollution Category Z

Therefore carriage on chemical tanker not

required, but discharge requirements for
category Z must be adhered to

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Fatty Acid Methyl Ester
IBC Code Chapter 17 – Ship Type 2
• Pollution Category Y
IBC Code entries:
• Palm oil fatty acid methyl ester
• Coconut oil fatty acid methyl ester
• Rapeseed oil fatty acid methyl ester
• Fatty acid methyl esters (m)

(m) From vegetable oils specified in the IBC Code

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 Pollution Ship Fire Special
Product
Cat. Type Fighting Requirements

Coconut oil
Y 2 A 15.19.6
FAME

Palm oil
Y 2 A 15.19.6, 16.2.9
FAME

Rapeseed
Y 2 A 15.19.6
oil FAME

Fatty acid 15.12.3, 15.12.4,

methyl Y 2 A, B, C 15.19.6, 16.2.6,
esters (m) 16.2.9

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Regulation 15.9.6

Cargoes shall be fitted

with a visible and
audible high level
alarm … which
indicates when the
liquid level in the cargo
tank reaches the
normal full condition

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Regulation 16.2.6
“… the cargo’s viscosity at 200C shall be specified on
a shipping document, and if the cargo’s viscosity
exceeds 50mPa.s at 200C the temperature at
which the cargo has a viscosity of 50m.Pa.s shall
be specified in the shipping document.”

Regulation 16.2.9
“…the cargo’s melting point shall be indicated in the
shipping document”

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Regulation 15.12.3
Products shall:
.1 not be stowed adjacent to oil fuel tanks
.2 have separate piping systems
.3 have tank vent systems separate from tanks
containing non-toxic products

Regulation 15.12.4
Cargo tank relief-valve settings shall be a
minimum of 0.02 MPa gauge

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 Jatropha Oil

„ No data presented on
Jatropha oil
„ No Tripartite Agreements
concluded

Jatropha oil and jatropha oil derivatives (e.g.

Jatropha oil FAME) have therefore not been
evaluated by the IMO and cannot be carried in
bulk by sea

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 Biofuel Blends

„ Biodiesel blended with mineral diesel

„ Bio-alchohol blended with gasoline (gasohol)

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2006 – BLG 10 agrees to interim measures for the
carriage of blends proposed by IPTA, the United
Kingdom and Sweden :
„ Such blends can be carried under the provisions of
MARPOL Annex I providing the proportion of
biodiesel or bioalcohol does not exceed 15 %
(B15/E15).

„ If the proportion of biofuel in the blend exceeds

15%, the shipper should contact his Administration
for a decision on how the product is to be carried

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Subsequent discussions:
‰ 15% cut-off point for Annex II product blended in Annex I
product has no basis in science
‰ Concerns about ability of oil discharge monitoring
equipment (ODME) to cope with these products

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4 scenarios identified:
1. Blending ashore – i.e. prior to the ship’s
manifold
2. Blending during loading - “loading on
top”
3. Blending during discharge – i.e. a
second product being injected into the
line during discharge
4. Blending during the voyage

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Blending on Board
„ currently no regulations that cover the operational
aspects of blending Annex I and Annex II products
on board the vessel
„ while not specifically prohibited, not sanctioned –
or even recognised – from a regulatory point of
view
„ discussions will continue – possibly to include
amendments to MARPOL

„ concern that a waste stream might be generated

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„ Interim measures to remain in place until
July 2009

„ Tests to be carried out by ODME

manufacturer to check to what percentage
(if any) Annex II product can be present in
Annex I product without impairing
functioning of ODME

„ Interested parties urged to provide data on

the types of blends being carried so that
more permanent measures can be developed

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Blends of predominantly Biofuel

Currently no measures in place

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B99 –”Splash and Dash”
Treat as pure product?

Other blends – Tripartite agreement

necessary until agreement reached

Suggestion: carry them under Annex II as

• Category X
• Ship Type 2
• Carriage requirements to be assigned
by reference to comparable products in the
IBC Code, e.g. Pygas

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Etamax and Alcoline

„ Blends of Ethanol and Gasoline – approx.

80%/20%
„ Currently List 2 of MEPC.2/Circ. (Pollution
only Mixtures) as Ship type 3, Pollution
Category Y, N.O.S. 8
„ Suggestion that should be List 3 Mixtures
including Safety Hazards) as Category X,
Ship type 2

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“Renewable Diesel”
„ Finland submits paper to BLG 11 (April 2007)
in respect of a product they produce from
vegetable oil with the aid of hydrogen (rather
than through transesterification)
„ Suggests that this product is more similar to
mineral diesel than FAME and should
therefore be carried under the provisions of
Annex I rather than Annex II
„ Proposes an amendment to the definition of
oil under MARPOL Annex I to include
renewable diesel

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BLG Sub-committee concludes that:
„ the components are products that have
long been carried under the provisions of
MARPOL Annex II and the IBC Code
„ to pick individual products at random out
of Annex II and transfer them to Annex I
would call into question the very basis of
MARPOL Annex II

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„ Finland invited to submit data on
renewable diesel to the GESAMP/EHS
working group in order for an
evaluation to be made
„ GESAMP/EHS has since studied the
product and produced a hazard profile
„ BLG will consider the issue further in
early 2009

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„ Thus, situation currently is:

„ Pure biofuels must be carried under the

appropriate provisions of MARPOL Annex II
‰ must be shipped under the IBC Code name
rather than as “biofuel”

„ Biofuel blends: decision expected by 2009

„ “Renewable diesel”: still under discussion

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Thank you for your attention
International Parcel Tankers Association
Halton Green East
Halton
Lancaster
LA2 6PA

Tel: +44 (0)1524 811892

mail@ipta.org.uk
www.ipta.org.uk

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