Statutory Alert: Clarification on the use of generic cleaning products for tank washing.
19 December, 2014
Applicability: Owners, managers and operators of vessels complying with MARPOL Annex II
Regulation 13.5.1 of MARPOL Annex II states that “when a washing medium other than water, such as mineral oil or chlorinated solvent, is used instead of water to wash a tank, its discharge shall be governed by the provisions of either Annex I or Annex II which would apply to the medium had it been carried as cargo.”
However, there has been some misunderstanding that only those products listed in Annex 10 of the MEPC.2/Circular – “Cargo Tank Cleaning Additives” – can be used for tank washing.
To address this, the following note will be added to Annex 10 to clarify that products listed in chapters 17 or 18 of the IBC Code and list 1 of MEPC.2.Circular can also be used:
“It should be noted that where products or their solutions that appear in chapter 17 or 18 of the IBC Code or list 1 of the MEPC.2/Circular are used as washing media, their discharge shall be governed by regulation 13.5.1 of MARPOL Annex II and they do not need to be listed here."
What companies need to do
Owners, managers and operators of vessels complying with Annex II of MARPOL should bring this information to the attention of their masters and all relevant employees and parties, and take any necessary action to avoid any misunderstanding with authorities.
For further information
Lloyd’s Register offers consultancy services to help and advise shipbuilders, owners and suppliers to the marine industry on meeting the requirements of the MARPOL Convention. For more information on these services, please contact your local Lloyd's Register group office. Or contact us via:
marpol@lr.org