LR Statutory Alert: Bio-Fuels
Statutory alert: Changes to the requirements for the carriage of blends of petroleum oil and bio-fuels.
Applicabilty: All owners, operators and charterers of vessels carrying MARPOL bio-fuels and bio-fuel blend cargoes in bulk
The 62nd session of the IMO Marine Environment Protection Committee (MEPC 62) agreed that from September 1, 2011, bio-fuel/petroleum oil blends should be carried in accordance with new Guidelines for the Carriage of Blends of Petroleum Oil and Bio-fuel. These are contained in IMO Circular MEPC.1/Circ.761. The Guidelines define bio-fuels as: ethyl alcohol (ethanol), fatty acid methyl esters (FAME), vegetable oils (triglycerides) and alkanes (C10-26), linear and branched with flashpoint of either 60ºC or less or more than 60ºC. Further bio-fuels identified as falling under the scope of the Guidelines will be listed in a new Annex 11 of the MEPC.2/Circular. The Guidelines split bio-fuel blends and requirements for their carriage into three bands, as follows:
Band 1: bio-fuel blends containing 75% or more of petroleum oil
These can be carried as an oil cargo under MARPOL Annex I. However, when carrying such bio-fuel blends, Oil Discharge Monitoring Equipment (ODME) shall be in compliance with Regulation 31 of Annex I and should be approved for the mixture being transported. If the ODME is not capable of monitoring the bio-fuel mixtures, until January1, 2016, all tank residues and washings are to be pumped ashore. When considering the deck fire-fighting system requirements of SOLAS chapter II-2, Regulations 1.6.1 and 1.6.2, when carrying bio-fuel blends containing ethyl alcohol, alcohol-resistant foams should be used.
Band 2: blends containing more than 1% but less than 75% of petroleum oil
These will be subject to MARPOL Annex II, and should be carried under the conditions specified in the table on page 3 of MEPC.1/Circ.761.
With respect to new bio-fuels identified as falling under the scope of the Guidelines, carriage requirements for specific bio-fuel/petroleum oil blends to be shipped as MARPOL Annex II cargoes will be incorporated into List 1 of the MEPC.2/Circular, as appropriate. Other blends are to be treated as tripartite mixture in line with MEPC.1/Circ.512.
Band 3: blends containing 1% or less of petroleum oil
These bio-fuel blends are subject to MARPOL Annex II.
Blending of Petroleum and bio-fuel on board
Blending on board describes the mixing of two products resulting in one single product (a blended mixture) and reflects only physical mixing as distinct from any chemical processing. No physical blending on board the vessel is allowed while at sea, as per MSC-MEPC.2/Circ.8 -Prohibition of Blending MARPOL Cargoes on Board During the Sea Voyages.
Proposed replacement of MSC-MEPC.2/Circ.8
MSC-MEPC.2/Circ.8 is proposed to be replaced by an amendment to SOLAS Chapter VI which was approved at the 89th session of the IMO Maritime Safety Committee (MSC 89) for adoption at MSC 90. The following new regulation 5-2 is proposed to be added after regulation 5-1:
"Regulation 5-2 Prohibition of the blending of bulk liquid cargoes during the sea voyage
1. The physical blending of bulk liquid cargoes during the sea voyage is prohibited. Physical blending refers to the process whereby the ship's cargo pumps and pipelines are used to internally circulate two or more different cargoes with the intent to achieve a cargo with a new product designation. This prohibition does not preclude the master from undertaking cargo transfers for the safety of the ship or protection of the marine environment.
2. The above prohibition does not apply to the blending of products for use in the search and exploitation of sea-bed mineral resources on board ships used to facilitate such operations."
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