Review of chapters 17 and 18 of the IBC Code

Inconsistencies identified in chapters 17 and 18 of the IBC Code have led to concern that strict application of the current criteria for assigning carriage requirements in chapter 21 of the IBC Code to products originally evaluated prior to 2004 could lead to unnecessarily stringent carriage requirements for a number of high volume products.  Since one of the prime triggers that would lead to a higher ship type is acute toxicity, the sixteenth session of the IMO's BLG Sub-Committee  considered possible ways of qualifying the application of mammalian toxicity as a criterium for assigning carriage requirements.  The key properties examined were saturated vapour concentration (SVC) together with behaviour in water, and the group examined the possible influence of these parameters in relation to the guidance contained in chapter 21 of the IBC Code, the logic being that where the SVC is low and the product is likely to dissolve or evaporate in water, then it should not be necessary to apply such stringent carriage requirements.

Initial indications are that this approach would result in some changes from Ship Type 3 to Ship Type 2, but  eliminate the more drastic changes (e.g. to Ship Type 1 and/or tank type 1G) that had  been indicated if the current criteria had been assigned.   It was agreed that a small group of pilot materials should be selected in order to undertake a systematic evaluation process, encompassing all aspects of the carriage requirements.  This process is intended to probe the practical boundaries associated with the proposals made to date and lead to a refinement of the criteria for assigning carriage requirements  in chapter 21 of the IBC Code.  This process should be completed by 2014.

Once agreement has been reached on the criteria for assigning carriage requirements the new criteria will be applied to individual products in chapters 17 and 18.  It is currently foreseen that this exercise should be completed by 2015, leading to entry into force of any new carriage requirements by 2018, but we have pointed out that industry will need adequate time to adjust to any new requirements and that date may need to be adjusted.  IPTA will be closely involved in the review process over the next few years and will keep members advised at every stage.

Estimated timeline for review work: