Introduction to Regulatory Changes in IMO. NACE IMCS Busan October 2008

Transcription

1 Introduction to Regulatory Changes in IMO NACE IMCS Busan October 2008

2 Key Developments IMO Guideline for Maintenance & Repair of Coatings SOLAS amendment for coating of cargo oil tanks of crude oil carriers. Cargo Oil Tank Coating Performance Standard

3 Guidelines for Maintenance DE51 Draft guidelines for maintenance of PSPC coatings The use of certified inspectors Restriction of repairs at sea Definition of maintenance and repair Maintenance means minor coating restoration work regularly performed by a ship s crew using normal shipboard means and tools to maintain GOOD or FAIR coating conditions. Maintenance delays or slows down the coating deterioration and effects short term steel protection. Repair means coating restoration work of a longer term nature, usually performed during ship s dry docking or scheduled repair period (ship idle) to restore the FAIR or POOR coating condition to GOOD condition. This will usually require specialized manpower and equipment such as sand blasting equipment, operators and dehumidifiers.

4 Key Impacts on Industry Inspecting and maintaining before being assessed by Flag or Class. Not maintaining in a Good condition will ultimately lead to expensive repair work. Location for repairs no longer flexible, i.e. at sea or in repair yard. No flexibility in repair specification. All requirements such as records, inspections, and inspector qualifications required in PSPC also will apply to repair. Are repair yards and owners ready.?????

5 Cargo Tank Coatings Draft regulation agreed at DE All cargo oil tanks of crude oil tankers shall be:.1 coated during the construction of the ship in accordance with the Performance standard for protective coatings for cargo oil tanks of crude oil tankers, adopted by the Maritime Safety Committee by resolution MSC.(...), as may be amended by the Organization, provided that such amendments are adopted, brought into force and take effect in accordance with the provisions of article VIII of the present Convention concerning the amendment procedures applicable to the Annex other than chapter I, or

6 Cargo Tank Coatings.2 protected by alternative means of corrosion protection, the effectiveness of which shall be no less than the objectives that are achieved by meeting the requirements under paragraph 3.1 and approved in accordance with the appropriate Performance Standard adopted by the Organization.

7 Cargo Tank Coatings 4.1 The Administration may exempt a crude oil tanker from the requirements of paragraph 3 of this regulation to allow the use of novel prototype alternatives to the coating system specified in paragraph 3.1, for testing provided they are subject to suitable controls, regular assessment and acknowledgement of the need for immediate remedial action if the system fails or is shown to be failing. Such exemption shall be recorded on an exemption certificate.

8 Cargo Tank Coatings 4.2 The Administration may exempt a crude oil tanker from the requirements of paragraph 3 of this regulation if the ship is built to be engaged solely in the carriage of cargoes and cargo handling operations not causing corrosion. Such exemption and conditions for which it is granted shall be recorded on an exemption certificate.

9 JWG-COTCPS DE 51 Draft Performance standard approved. Industry asked to further develop the test standard taking into account the comments received. Meeting 28 th & 29 th October in Busan to finalise the test standard and submission to DE52

10 AREA TO BE COATED

11 Condensation Test * 3 ltrs crude oil / m 3 of chamber: pro rata Surface area must be > 250 cm 2 / litre crude oil

12 Immersion Test Immersion test based on ISO to simulate a crude oil tank in loaded condition Phases Seawater: Crude oil: Vapour - in ratio of 2:10:3

13 Testing Standard Issues Experience from running tests The test procedure is ambigious and leads to different procedures, e.g. heating of immersion vat (Bodycote vs. COT) Panel size and water:oil ratio to be reconsidered for immersion test Procedures for checking inert gas and ph variations during the test required Test temperature of 60 C too high for high BTX oils?

14 JWG/COTCPS Outcome As a result of the problems highlighted by the initial tests the working group were of the opinion that at this time the test procedure in the standard could be replaced by a statement of fit for purpose from the coating manufacturer. It is common practice for manufacturers to test coatings as part of their development and the results of such tests could be used by the manufacturer to issue this statement until such time as a unified test procedure is available. The Industry Working Group of Experts strongly recommends that work to develop a test method is continued under the auspices of coating experts from the coating industry, from classification societies, relevant owner representatives, and shipyards with the objective to develop the standard as soon as possible and with the obligation to regularly keep relevant parties fully informed.

15 Amending PSPC MSC 76 Dec 2002 DE 46 Feb 2003 MSC 77 May 2003 MSC 79 Dec 2004 MSC 78 May 2004 DE 47 Feb 2004 DE 48 Feb 2005 MSC 80 May 2005 DE 49 Feb 2006 Entry Into Force July 2008 MSC 82 Dec 2006 MSC 81 May 2006

16 Amendment procedure* New work programme items 2.9 In compliance with resolutions A.500(XII) and A.777(18), the Committees, in determining inclusion of new work programme items, should be guided by priorities established in accordance with the guidelines set out in paragraphs 2.10 to General acceptance 2.10 Before deciding to include a new item in the work programme of an IMO body, the following considerations should be taken into account:.1 has a need for the measure proposed been documented and, in case of proposals calling for new conventions or amendments to existing Conventions, has a compelling need been demonstrated?.2 is the subject addressed by the proposal considered to be within the scope of IMO s objectives and the Strategic Plan for the Organization?.3 do adequate industry standards exist or are they being developed thereby reducing the need for action within IMO?.4 do the benefits vis-à-vis enhanced maritime safety, maritime security or protection of the marine environment expected to be derived from the inclusion of the new item proposed justify such action?.5 has the analysis of the issue sufficiently addressed the cost to the maritime industry as well as the relevant legislative and administrative burdens?.6 the achievability in the number of sessions. * MSC-MEPC.1/Circ.2

17 Amendment procedure* Proposals for new, or amendments to existing, mandatory instruments In such cases, a compelling need for such amendments should be demonstrated by the proponent(s), and an analysis of the implications of such amendments, particularly those with far-reaching implications and consequential proposals for other amendments, having regard to the costs to the maritime industry, the legislative and administrative burden involved and benefits which would accrue there from, should be provided so as to give Member Governments a clearer perception of the scope of the proposed new requirements and an improved basis on which to take decisions. A certain degree of flexibility might be allowed in the application of this paragraph in exceptional circumstances, in particular in the case of proposed amendments on operational safety matters.

18 Then once the need for an amendment has been justified. The committee must decide its priority on the work program.

19 Establishment of priorities In deciding the priority of an item proposed for the work programme of the two Committees and their subsidiary bodies, a higher priority should be assigned to items that can be shown, or estimated, to have the greatest effect on safety of life, prevention of serious injury, protection of the marine environment and the highest ratio of benefit to be gained from the implementation of the proposal compared with the cost of its implementation. In addition, the following points should also be taken into account, where subparagraphs.1 to.6 below would indicate a higher priority and subparagraphs.7 to.9 would indicate a lower priority:

20 .1 measures to promote the widest possible implementation and enforcement of IMO instruments by the shipping community as a whole;.2 measures aimed at substantially preventing maritime casualties or marine pollution incidents;.3 measures following a major maritime casualty involving substantial loss of life, significant injuries to persons or major marine pollution;.4 measures following a series of incidents causing or indicating risk of loss of life, significant injuries to persons or major marine pollution;.5 measures aimed at improving the safety and health of ships' crews or personnel;.6 measures to correct significant inadequacies identified in existing instruments;.7 measures necessary to align IMO rules and standards with those of other relevant international instruments and organizations;.8 measures required to take into account the introduction of new technology and methods in maritime transportation, including the carriage of new hazardous substances; and.9 measures other than those referred to above.

21 A lot of work is to be done before submitting anything to IMO. Once submitted it needs to be supported by the committee and subcommittee.

22 if we want to make changes! The process will be longer not shorter. A case has to be made by an Administration, and supported, to IMO that amendments are needed. Normally this is not a problem for a something that has been in force for sometime, but to a something that has only just entered into force.??? Industry must support the Administration and work together.

23 If we cannot change it? We must live with it! In which case we must all work together as with the industry guidelines on implementation.

24 Thank You For Your Attention