Assessment of Bulk Liquid Chemicals
Chemicals to be transported in bulk must be listed in Chapter 17 (or chapter 19) of the IBC Code or contained in the Provisional Categorization of Liquid Substances in accordance with MARPOL Annex II and the IBC Code (MEPC.2/Circular), which sets out the carriage requirements under which it may be transported.
If a product or substance has not yet been assessed and is therefore not included in either of these lists, then an assessment of the chemical must be carried out through two bodies. Firstly, a product or the components of a mixture must first be assessed by the GESAMP/EHS Working Group and assigned a GESAMP Hazard Profile, which establishes the environmental hazard profile for the substance or component. Once a substance or component of a mixture has been assessed and a hazard profile assigned, it is included in what is known as the GESAMP/EHS Composite List, which is issued once a year.
Based on the assigned GESAMP Hazard Profile, the substance or mixture must then be submitted to the ESPH Working Group of the Sub-Committee on Pollution Prevention and Response (PPR Sub-Committee), for assignment of the appropriate carriage requirements. Once this has been completed, the substance (or trade named mixture) will then be added to the MEPC.2/Circular as an entry for ‘all countries, with no expiry’.
A Tripartite Agreement may be established between interested Governments to allow for the provisional transport of substances that have not yet been assessed and therefore do not appear in either Chapter 17 of the IBC Code or in the MEPC.2/Circular. The expectation is that the establishment of a Tripartite Agreement, which is valid for a period of three years after which it expires permanently, will allow sufficient time for submission of the product to and assessment by the respective bodies, for inclusion of the substance in the GESAMP/EHS Composite List and the MEPC.2/Circular for ‘all countries, and with no expiry’. Once a Tripartite Agreement has been established (or modified within the validity period) and this has been communicated to IMO, it will be added to the IMO web site and then to MEPC.2/Circular, as a provisional entry with an expiry date, to be transported only by those countries identified in the Tripartite Agreement.
With respect to the information provided for Tripartite Agreements concluded under Lists 1, 3 and 4 of the MEPC.2/Circular, the name of the product, the submitting country and the list number are given, while for those assessments concluded under List 2, the product trade name, the contains name, the n.o.s. entry number and the reporting country are presented.
Submitting data to the GESAMP/EHS Working Group
Following the establishment of a Tripartite Agreement, the manufacturer is required to then have their substance or components of a mixture assessed by the GESAMP/EHS Working Group for the establishment of a GESAMP Hazard Profile and inclusion in the GESAMP/EHS Composite List. The information required for submission to GESAMP/EHS is set out in the GESAMP/EHS Product Reporting Form. Once completed, the form together with all supporting documentation should be forwarded to:
The Technical Secretary of GESAMP/EHS Working GroupInternational Maritime Organization (IMO)4 Albert EmbankmentLondon SE1 7SRUnited KingdomE-mail: email@example.com
Electronic submissions of the GESAMP/EHS Product Reporting Form and supporting data are acceptable. Submissions to GESAMP-EHS are fee based, at the rate of US$ 6500 per assessment (i.e. per substance or component assessed).
The full description of the GESAMP Hazard Evaluation Procedure for Chemical Substances carried by Ships, including advice to manufacturers on how to submit data to GESAMP/EHS can be found in the GESAMP Reports and Studies No.64.
Submitting data for evaluation to the IMO
Following the establishment of a GESAMP Hazard Profile and the addition of the substance (or component(s)) to the GESAMP/EHS Composite List, the manufacturer shall then make a request through its national Administration to submit the product for evaluation by IMO. To do so, the manufacturer must submit a completed PPR Product Data Reporting Form to the Administration, proposing, where possible, the Pollution Category, Ship Type and carriage requirements, in accordance with the provisions set out in MARPOL Annex II and the IBC Code. The Administration in turn, will submit a proposal, including the form, to IMO for evaluation. Evaluations are undertaken by the ESPH Working Group of the PPR Sub-Committee.
Once evaluated, the product and its carriage requirements are added to the Provisional Categorization of Liquid Substances in accordance with MARPOL Annex II and the IBC Code (MEPC.2/Circular) as an entry ‘for all countries, with no expiry’, replacing any Tripartite Agreements that may be in place, and, ultimately, as a new complete entry in the IBC Code.