Posted: October 20th, 2022

A study on the IMO regulatory instruments concerning the Assessment of safety and pollution hazards of chemicals in bulk transported by sea (based on MARPOL Annex II and IBC Code)

A STUDY ON THE IMO REGULATORY
INSTRUMENTS CONCERNING THE
Assessment OF SAFETY AND POLLUTION
HAZARDS OF CHEMICALS IN BULK
TRANSPORTED BY SEA
(Based on MARPOL Annex II and IBC Code)

ACKNOWLEDGEMENTS
First of all, I would like to express my gratitude to my government, the Ministry of
Land, Transport and Maritime Affairs, kindly providing me with full fellowship for
my studies in World Maritime University (WMU) in Malmo, Sweden, and Jong-eui
Kim, the President and CEO of Korea Maritime Dangerous Goods Inspection &
Research Institute for giving me a great opportunity to expand my knowledge and
experiences in WMU.
I would like to express my special thank to my supervisor, LCDR Mark SAWYER,
who led and guided me to accomplish my dissertation work with valuable comments
and suggestions, and Inger BATTISTA, who helped me with comments on my
English language. My sincere appreciation also goes to Professor Clive COLE, who
taught me academic English writing and gave me confidences for my successful
studies.
I would like to thank Professor Daniel MOON who has been a supporter for my
dissertation and my family’s life in Malmo. I would also like to thank Jolyn Tay
providing me national regulatory information of the Republic of Singapore for my
dissertation. I would like to appreciate An Kwang, Chae Chong Ju, Min Young Hun
and their families sharing happiness, knowledge and unforgettable memories of
foreign life in Sweden.
Lastly, my sincere thank goes to my wife, Jung Pilhee and my lovely two daughters,
Seyoon and Seungah for living together, giving me enthusiasm, smiles and being my
happiness all the time of studies in WMU.
iii
ABSTRACT
Title of Dissertation: A Study on the IMO Regulatory Instruments Concerning
the Assessment of Safety and Pollution Hazards of
Chemicals in Bulk Transported by Sea (Based on MARPOL
Annex II and IBC Code)
Degree: MSc
The IMO has developed various technical codes to regulate different forms of
hazardous substances transported by sea.
This dissertation is a study to find more effective and user-friendly ways to deal with
complex IMO regulatory instruments concerning the Assessment of safety and
pollution hazards of chemicals in bulk for the benefit of industries and IMO Member
States.
A chemical which is not evaluated by its hazard properties should not be transported
by ships. Evaluated and approved chemicals are listed in the IBC Code. Each of
these chemicals should be assigned carriage requirements and a pollution category
before transporting.
The transportation of petroleum products accounts for 11.7 % of world seaborne
trade and new products will be transported. Over 98% of these products are
hazardous to humans and/or the environment. Therefore, in order to transport new
products, the chemical industry should evaluate the hazards of products using
international instruments.
iv
However, the IMO’s instruments for the Assessment of products are complex and
difficult to implement. The lack of comprehensive information and expertise can be a
burden for the chemical industry.
Additionally, the frequent revisions of these regulatory instruments make it difficult
for IMO Member States to adopt these instruments into their national framework.
Most countries merely reference the IMO instruments within national regulations.
Consequently, IMO’s role as main sources of non-mandatory instruments is
important for the industry.
Therefore, possible solutions are suggested in Chapter 6 of this dissertation based on
the difficulties and complexities of these instruments to benefit the industry and IMO
Member States with a number of recommendations in the concluding Chapter.
Developments of a new Appendix to the IBC Code which references all necessary
relevant guidelines will be informative, and a comprehensive electronic version of
the guidelines can be a user-friendly tool for all maritime stakeholders.
KEY WORDS: Regulatory instruments, IBC Code, MARPOL Annex II, Assessment
of chemical hazards, Products, Noxious Liquid Substance (NLS), GESAMP Hazard
Profiles, Safety, Pollution Category,
v
TABLE OF CONTENTS

DECLARATION ……………………………………………………………………………………………. i
ACKNOWLEDGEMENTS …………………………………………………………………………….. ii
ABSTRACT …………………………………………………………………………………………………. iii
LIST OF TABLES ………………………………………………………………………………………. viii
LIST OF FIGURES ………………………………………………………………………………………. ix
LIST OF ABBREVIATIONS ………………………………………………………………………….. x
CHAPTER 1
INTRODUCTION …………………………………………………………………………………………. 1
1.1 Background of the study ………………………………………………………………….. 1
1.2 Purpose of the study ………………………………………………………………………… 2
1.3 Method of the study ………………………………………………………………………… 2
1.4 Scope of the study …………………………………………………………………………… 3
CHAPTER 2
TRANSPORTATION OF LIQUIDS IN BULK BY SEA ……………………………………. 4
2.1 Seaborne trade of liquid in bulk ………………………………………………………… 4
2.2 Newly transported products and major initiating countries …………………… 6
CHAPTER 3
INTERNATIONAL FRAMEWORK FOR THE CARRIAGE OF DANGEROUS
GOODS AND HARMFUL SUBSTANCES BY SHIPS ……………………………………… 9
3.1 SOLAS 74 and MARPOL 73/78……………………………………………………….. 9
3.2 Various International Codes …………………………………………………………….. 11
3.2.1 IMDG Code ………………………………………………………………………….. 11
3.2.2 IMSBC Code ……………………………………………………………………….. 13
3.2.3 IBC Code and BCH Code ……………………………………………………… 14
3.2.4 IGC Code and GC Code ………………………………………………………… 16
3.2.5 INF Code …………………………………………………………………………….. 17
vi
CHAPTER 4
IMO’S INSTRUMENTS FOR THE Assessment OF SAFETY AND
POLLUTION HAZARDS OF CHEMICALS IN BULK TRANSPORTED BY
SHIPS …………………………………………………………………………………………………………. 19
4.1 International regulations, guidelines and documents ………………………….. 19
4.1.1 MARPOL 73/78 Annex II ……………………………………………………… 21
4.1.2 IBC Code …………………………………………………………………………….. 22
4.1.3 MEPC.2/Circulars ………………………………………………………………… 25
4.1.4 MEPC.1/Circ.512 …………………………………………………………………. 27
4.1.5 GESAMP Report and Study No. 64 ………………………………………… 28
4.1.6 Report of the GESAMP/EHS Working Group …………………………. 29
4.1.7 BLG.1/Circ.33 (09 August 2011)……………………………………………. 30
4.1.8 BLG.1/Circ.27 (18 August 2008) ……………………………………………. 30
4.1.9 BLG.1/Circ.28 (18 August 2008) ……………………………………………. 31
4.1.10 GHS ……………………………………………………………………………………. 31
4.2 Relevant international bodies relating to the Assessment ……………………… 32
4.2.1 BLG Sub-committee …………………………………………………………….. 33
4.2.2 ESPH Working Group …………………………………………………………… 33
4.2.3 GESAMP/EHS Working Group ……………………………………………… 33
4.3 International Assessment criteria ………………………………………………………. 34
4.3.1 GESAMP Hazard Profiles ……………………………………………………… 35
4.3.2 MARPOL 73/78 Annex II, Appendix I ……………………………………. 36
4.3.3 IBC Code Chapter 21 ……………………………………………………………. 37
4.4 International Assessment procedures …………………………………………………. 38
CHAPTER 5
MEMBER STATES IMPLEMENTATION …………………………………………………….. 43
5.1 Republic of Korea (ROK) ………………………………………………………………. 43
5.2 The United States of America (USA) ……………………………………………….. 44
5.3 The United Kingdom of Great Britain and Northern Ireland (GBR) …….. 45
5.4 Republic of Singapore (SGP) ………………………………………………………….. 45
vii
CHAPTER 6
DIFFICULTIES IN USING OR UNDERSTANDING IMO INSTRUMENTS AND
POSSIBLE SOLUTIONS ……………………………………………………………………………… 47
6.1 Difficulties in IMO instruments ………………………………………………………. 47
6.1.1 Complexity of guidelines in usage ………………………………………….. 47
6.1.2 Difficulties in finding information ………………………………………….. 52
6.1.3 Lack of experts to deal with …………………………………………………… 53
6.1.4 The time allotted for acquiring the documents for Assessment …….. 53
6.1.5 Difficulty in Member State implementation …………………………….. 54
6.2 Possible solutions to the current system……………………………………………. 54
6.2.1 Sufficient references of guidance on the Convention and Code ….. 54
6.2.2 Establishment of the integrated electronic version of guidelines …. 59
6.2.3 Development of an integrated single combined guideline ………….. 62
CHAPTER 7
CONCLUSION AND RECOMMENDATIONS ………………………………………………. 64
REFERENCES ……………………………………………………………………………………………. 68
Appendix A …………………………………………………………………………………………………. 73
Appendix B …………………………………………………………………………………………………. 74
Appendix C …………………………………………………………………………………………………. 76
Appendix D …………………………………………………………………………………………………. 78
Appendix E …………………………………………………………………………………………………. 79
viii
LIST OF TABLES
Table 1 -World seaborne trade (year 2006 to 2009)…………………………………………….. 4
Table 2 -Seaborne trade of petroleum products by country group in 2009 …………….. 5
Table 3 -The number of newly transported products and major countries ……………… 7
Table 4 -Summary of the IMO instruments for carriage of dangerous goods and
harmful substances ………………………………………………………………………………… 10
Table 5 -Summary of international regulations, guidelines and documents ………….. 20
Table 6 -Products listed in the IBC Code by pollution categories and hazard type … 23
Table 7 -Products listed in the Chapter 17 of IBC Code by pollution categories and
ship type ………………………………………………………………………………………………. 24
Table 8 -List of Annexes in MEPC.2/Circular ………………………………………………….. 26
Table 9 -Products listed in MEPC.2/Circulars (year 2008 to 2010) …………………….. 27
Table 10 -Information in the annex of the MEPC.1/Circ.512……………………………… 27
Table 11 -Criteria for pollution categorization and laboratory test information …….. 37
Table 12 -Required chemical data for the entry to the IBC Code and the test
information and criteria in the GHS and GESAMP Report and Study No.64 … 38
Table 13 -The legal framework of ROK for the carriage of liquid in bulk ……………. 43
Table 14 -The legal framework of USA for the carriage of liquids in bulk …………… 44
Table 15 -The legal framework of GBR for the carriage of liquid in bulk ……………. 45
Table 16 -The legal framework of SGP for the carriage of liquid in bulk …………….. 45
Table 17 -Information required for identification of a new product …………………….. 48
Table 18 -Information required for provisional assessment ……………………………….. 49
Table 19 -Information required for transportation under Tripartite Agreement …….. 50
Table 20 -Information required for Assessment by GESAMP/EHS ………………………. 50
Table 21 -Information that required for assignment of carriage requirements and
entery into the IBC Code ……………………………………………………………………….. 51
Table 22 -A possible new Appendix to the IBC Code ……………………………………….. 55
Table 23 -The advantages and disadvantages of electronic guidelines…………………. 59
ix
LIST OF FIGURES
Figure 1 -Seaborne trade of petroleum products by country group in 2009 ……………. 6
Figure 2 -The number of products and the percentage of major newly transporting
countries (year: 2006 – 2010) …………………………………………………………………… 8
Figure 3 -Application of various Codes under SOLAS 74 and MARPOL 73/78 ….. 10
Figure 4 -Regulatory structure of various modes of dangerous goods transportation in
packaged forms …………………………………………………………………………………….. 12
Figure 5 -IMO’s regulatory structure of the solid bulk cargoes …………………………… 14
Figure 6 -The regulatory concept of products listed in the IBC Code ………………….. 15
Figure 7 -Regulatory concept and application of IBC Code and BCH Code ………… 16
Figure 8 -Regulatory concept and application of IGC Code and GC Code ………….. 17
Figure 9 -Hazard types of products listed in Chapter 17 of the IBC Code ……………. 23
Figure 10 -Percentage of the pollution categories and ship type …………………………. 24
Figure 11 -The number of products that regulated by tow Conventions ………………. 25
Figure 12 -Organizational structure of the international authorized bodies ………….. 32
Figure 13 -International laboratory test guideline and Assessment criteria for the
hazardous substances …………………………………………………………………………….. 35
Figure 14 -GESAMP/EHS Composite List GESAMP Hazard Profiles ……………….. 36
Figure 15 -Procedural steps for the Assessment and carriage requirements ……………. 39
Figure 16 -Concept of Tripartite Agreement …………………………………………………….. 41
Figure 17 -The procedural diagram for the Tripartite Agreement. ………………………. 42
Figure 18 -Brief steps for the Assessment of chemical hazards ……………………………. 47
Figure 19 -Example of documents linkages …………………………………………………….. 60
Figure 20 -The concept of documents linkage for electronic version of guideline … 62
x
LIST OF ABBREVIATIONS
ADR European Agreement concerning the International
Carriage of Dangerous Goods by Road
AND European Agreement for the International Carriage of
Dangerous Goods by inland Waterway
BC Code Code of Safe Practice for Solid Bulk Cargoes
BCH Code Code for the Construction and Equipment of Ships
carrying Dangerous Chemicals in Bulk
BLG Sub-committee on Bulk Liquids and Gases
CFR Code of Federal Regulations
DSC Sub-committee on Dangerous Goods, Solid Cargoes
and Containers
ESPH Working Group on the Assessment of Safety and
Pollution Hazards of Chemicals
EU European Union
FAO Food and Agriculture Organization of the United
Nations
FRA France
GBR United Kingdom
GC Code Code for the Construction and Equipment of Ships
Carrying Liquefied Gases in Bulk
GESAMP Joint Group of Experts on the Scientific Aspects of
Marine Environmental Protection
GESAMP/EHS GESAMP Working Group on the Assessment of the
Hazards of Harmful Substances Carried by Ships
GHS Globally Harmonized System of Classification and
Labelling of Chemicals
GLP Good Laboratory Practice
IAEA International Atomic Energy Agency
xi
IBC Code International Code for the Construction and Equipment
of Ships Carrying Dangerous Chemicals in Bulk
IGC Code International Code for the Construction and Equipment
of Ships Carrying Liquefied Gases in Bulk
ILO International Labour Organization
IMDG Code International Maritime Dangerous Goods Code
IMO International Maritime Organization
IMSBC Code International Maritime Solid Bulk Cargoes Code
INF Code International Code for the Safe Carriage of Packaged
Irradiated Nuclear Fuel, Plutonium and High-level
Radioactive Wastes on Board Ships
ITA Italy
KOMDI
MARPOL 73/78
Korea Maritime Dangerous Goods Inspection and
Research Institute
International Convention for the Prevention of Pollution
from Ships, 1973, as modified by the Protocol of 1978
MEPC Marine Environment Protection Committee
MSC Maritime Safety Committee
NGO Non-Governmental Organization
NLS Noxious Liquid Substances
NOR Norway
NVIC Navigation and Vessel Inspection Circular in USA
OECD Organization for Economic Co-operation and
Development
OS Other Substances
RID Regulations concerning the International Carriage of
Dangerous Goods by Rail
ROK Republic of Korea
SGP Republic of Singapore
SOLAS International Convention for the Safety of Life at Sea,
xii
1974
TI Technical Instructions for the Safe Transport of
Dangerous Goods by Air
UN United Nations
UNSCEGHS UN Sub-committee of Experts on GHS
UNCETDG UN Committee of Experts on Transport of Dangerous
Goods
UNECE United Nations Economic Commission for Europe
UNEP United Nations Environment Programme
UNCTAD United Nations Conference on Trade And Development
USA United States of America
1
CHAPTER 1
INTRODUCTION
1.1 Background of the study
Chemicals, transported by ships are dangerous for crews and the marine environment,
because most of these chemicals are hazardous due to their toxic, flammable,
explosive, corrosive and reactive properties. Therefore, International Maritime
Organization (IMO) has developed various international regulatory instruments to
evaluate dangerous chemicals1
and noxious liquid substances2
(products3
) for safe
seaborne trade. The MARPOL 73/78 Convention4
(MARPOL) Annex II, SOLAS 74
Convention 5
(SOLAS) and the International Code for the Construction and
Equipment of Ships Carrying Dangerous Chemicals in Bulk (IBC Code) are the
primary regulatory instruments for the safe transportation of products.
However, the international regulations, guidelines and procedures concerning the
hazard Assessment of the products are complicated and difficult for the chemical
manufacturer and the shipping industry to implement. In order to assess a product’s
hazard for seaborne transport, it should be tested in good laboratories, its hazard
should be rated in accordance with international guidance, hazard data should be sent
to expert groups for their judgment, and the entire process requires administrative
procedures.
In addition, the information in these IMO instruments may not be sufficient for the

1
Dangerous chemicals means any liquid chemicals designated as presenting a safety hazard, based on
the safety criteria for assigning products to Chapter 17 of the IBC Code
2
Noxious Liquid Substance means any substance falling into X, Y or Z pollution category under the
provision of regulation 6.3 of MARPOL Annex II
3
Products is the collective term used to cover both Noxious Liquid Substances and Dangerous
chemicals
4
International Convention for the Prevention of Pollution from Ships, 1973, as modified by the
Protocol of 1978 (IMO)
5
International Convention for the Safety of Life at Sea, 1974 (IMO)
2
chemical industry to fully comprehend the regulatory requirements. Furthermore, a
comprehensive written study or information for these guidelines is non-existing,
although the Assessment of safety and pollution hazards of chemicals has been one of
the main agenda items of the Sub-Committee on Bulk Liquids and Gases (BLG) in
IMO, supported by a formal Working Group on the Assessment of Safety and
Pollution Hazards of Chemicals (ESPH).
Therefore, considering that these guidelines are highly technical and complex, the
lack of enough information and the difficulty in dealing with these guidelines are a
great burden and unexpected obstacles for a chemical manufacturer, especially one
who is not familiar with maritime regulations.
1.2 Purpose of the study
This dissertation will study the complicated IMO instruments concerning the
Assessment of safety and pollution hazards of chemicals. Therefore, the content will
be informative for the chemical and shipping industry involved in the maritime trade
of bulk liquid chemicals. In addition, this study will provide basic information to
make and/or manage effective and user-friendly guidelines which are much simpler
than the current complex and scattered guidelines. Furthermore, the results can be
valuable references for future amendments of IMO’s complex regulatory instruments.
Consequently, this study will be beneficial for the industry if the Member States of
IMO adopts effective ways to simplify the complex guidelines into a simple
consolidated tool.
1.3 Method of the study
This dissertation will combine quantitative and qualitative methodology. However,
qualitative methods will prevail throughout this dissertation, focusing on general
difficulties in IMO instruments which shipping industries may encounter when
transporting new products. Most of the relevant IMO mandatory and non-mandatory
instruments will be reviewed and summarized based on Annex II to MARPOL and
3
the IBC Code. In addition, the interrelationships of these instruments will be
analyzed. Furthermore, the international Assessment and laboratory test criteria for
chemicals will be summarized and analyzed. The source of information will be based
on the various IMO and UN instruments.
The world seaborne trade of products and newly transported bulk liquid chemicals
will be reviewed, and the movement of new products in country groups will be
analyzed by using statistical data. The products which are listed in the IBC Code and
IMO circulars will be analyzed. Furthermore, the pollution categorizations and the
hazard information of these products will be analyzed using statistical data.
The administrative aspect of some of the IMO Member States will be reviewed based
on the national regulatory systems to find how these countries deal with the complex
non-mandatory instruments when incorporating them in their national legal
framework.
1.4 Scope of the study
This study will be limited to the transportation of products by sea, mainly focusing
on the IMO’s regulatory instruments concerning the Assessment of hazardous liquid
chemicals in bulk. The complexity of these instruments will be discussed and
analyzed. However, the procedural steps of the Assessment and the technical criteria
that are contained in those instruments will not be discussed.
The comprehensive summarization of all the relevant sources of the technical
information in the various IMO/UN instruments, and to find a more effective tool to
deal with those guidelines will be the primary focus of this study.
4
CHAPTER 2
TRANSPORTATION OF LIQUIDS IN BULK BY SEA
This chapter will review the seaborne trade of dangerous chemicals and Noxious
Liquid Substances (NLS) in bulk and analyze newly transported products. Data for
the analysis of new products will be supported by MEPC.2/Circulars6
which were
developed and released by the Marine Environment Protection Committee (MEPC)
in IMO.
2.1 Seaborne trade of liquid in bulk
Table 1 shows the world seaborne trade from year 2006 to 2009. An average of 930.0
million tons of petroleum products7
were transported during the last four years. It
accounts for 11.7 % of world seaborne trade. The transportation volume of petroleum
products has also slightly increased as with many other goods (UNCTAD, 2010).
Table 1 -World seaborne trade (year 2006 to 2009)
Year
Goods Loaded Goods Unloaded
Total Crude Products Dry
cargo
Total Crude Products Dry
cargo
Unit: millions of tons
2006 7682.3 1783.4 914.8 4984.1 7885.9 1981.0 894.2 5060.8
2007 7983.5 1813.4 933.5 5236.6 8136.1 1995.5 904.3 5236.3
2008 8210.1 1785.2 946.9 5478.0 8272.7 1942.1 964.1 5366.5
2009 7842.8 1724.5 924.6 5193.6 7908.4 1887.8 957.3 5073.3
Average 7929.7 1776.6 930.0 5223.1 8050.8 1951.6 930.0 5184.2
Unit: percentage
2006 100.0 23.2 11.9 64.9 100.0 24.5 11.3 64.2
2007 100.0 22.7 11.7 65.6 100.0 24.5 11.1 64.4
2008 100.0 21.7 11.5 66.7 100.0 23.5 11.7 64.9

6
Provisional categorization of liquid substances, issued by IMO’s MEPC in December every year
7
Products transported by chemical tankers
5
2009 100.0 22.0 11.8 66.2 100.0 23.7 12.1 64.2
Average 100.0 22.4 11.7 65.9 100.0 24.1 11.6 64.4
Source: UNCTAD8
. (2010). Review of Maritime Transport 2010, pp. 10-11
Table 2 shows seaborne trade of petroleum products by country groups9
in 2009.
Half of the petroleum products were loaded in developing country groups and
unloaded in developed country groups. Figure 1 shows the percentage of the trade.
The developing country group exports (55.3%) more petroleum products than the
developed country group (38.0%). However, the developed country group imported
more petroleum products (57.1%) than the developing country group. Therefore,
petroleum products have been transported from developing countries to developed
countries.
Chemical production areas have been expanded to the Middle East and Asia since
2000. Production capacity of these regions was 22 % in 1990s, 39 % in 2005 and
expected to occupy 49 % of total production of the world in 2015 (KOMDI10, 2007)
Table 2 -Seaborne trade of petroleum products by country group in 2009
Unit: millions of tons
Country group Product loaded Product unloaded
Developed 355.0 529.4
Transition 41.6 3.0
Developing 528.0 428.8
Source: Data was selected from the UNCTAD. (2010). Review of Maritime Transport 2010, pp. 10-11

8
United Nations Conference on Trade And Development
9
Countries Group is classified by Annex I of the Review of Maritime Transport 2010, UNCTAD.
10 Korea Maritime Dangerous Goods Inspection and Research Institute
6
Figure 1 -Seaborne trade of petroleum products by country group in 2009
Source: Drawn by Author based on the table 2
2.2 Newly transported products and major initiating countries
Provisionally or completely assessed and newly transported products are listed in the
MEPC.2/Circular before they are included in Chapter 17 or 18 of the IBC Code. The
products listed in this circular are divided into lists 1, 2, 3 and 411
, based on the
chemical characteristics or component of the mixtures. Most of these products are
transported by Tripartite Agreement12
.
Table 3 shows the number of newly transported products and main exporting
countries based on the MEPC.2/Circ.12 to 16, issued by MEPC from 2006 to 2010.
List 2 products were excluded from the table, because these products do not need

11 List 1: Pure or technically pure products, List 2: Pollutant only mixtures containing at least 99% by
weight of components already assessed by IMO, List 3: (Trade-named) mixtures containing at
least 99% by weight of components already assessed by IMO, presenting safety hazards, List 4:
Pollutant only mixtures containing one or more components, forming more than 1% by weight of
the mixture, which have not yet been assessed by IMO.
12 Tripartite Agreement is concurrence of the Administrations among the shipping or producing
country and the Flag State(s) and receiving countries with product’s Assessment result under
regulation 6.3 of the Annex II to MARPOL 73/78 before the chemical is transported by ships.

7
Tripartite Agreement and can simply be transported based upon a calculated
pollution hazard13
.
In total 134 different new products were transported in the last five years. This
number accounts for 18% of the total products listed in the IBC Code14. Major States
that initiate the carriage of products are France (FRA), the United States of America
(USA), the United Kingdom (GBR) and Norway (NOR) as shown in Figure 2. These
four States transported 95 new products, and account for 70% of total newly
transported products between 2006 and 2010. The number also increased slightly
within the last five years (IMO, 2010).
Table 3 -The number of newly transported products and major countries
Country
abbreviations15
2006 2007 2008 2009 2010
Tot
al
Product
List
Product
List
Product
List
Product
List
Product
List
1 3 4 1 3 4 1 3 4 1 3 4 1 3 4
FRA 3 3 7 7 5 1 1 6 33
USA 1 1 1 2 3 1 10 3 8 30
GBR 4 2 1 12 3 22
NOR 1 1 6 2 10
SGP 1 1 1 2 1 6
ITA 5 5
Other 1 1 0 5 1 1 1 8 0 4 2 0 2 2 0 28
Total
9 1 0 13 10 11 4 14 0 6 31 0 6 28 1
134
10 34 28 37 35
Source: Calculated by Author, based on the products listed in the MEPC.2/Circ.12 to 16 (IMO)

13 Appendix 6 of the MEPC.1/Circ.512 (2006), contains the example of the calculation method for
determination of pollution categories and ship types for mixtures.
14 In total 748 cargoes are listed in the IBC Code, see table 6 in Chapter 4 of this dissertation.
15 Country groups are defined by Annex 7 in the MEPC.2/Circular.
8
Figure 2 -The number of products and the percentage of major newly
transporting countries (year: 2006 – 2010)
Source: Calculated and drawn by Author, based on the table 3
Petroleum products have been transported from developing countries to developed
countries as shown in Table 2. However, the new products have been transported the
other way, from developed countries to developing countries.

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9
CHAPTER 3
INTERNATIONAL FRAMEWORK FOR THE CARRIAGE OF
DANGEROUS GOODS AND HARMFUL SUBSTANCES BY
SHIPS
This chapter will review and summarize IMO’s international legal framework for the
carriage of dangerous goods and harmful substances, such as the IMDG Code16, the
IBC Code and their umbrella Conventions: SOLAS and MARPOL and relevant
Codes under both Conventions. Furthermore, the interrelationship of the SOLAS and
MARPOL along with the various Codes will be analyzed.
3.1 SOLAS 74 and MARPOL 73/78
Chapter VII of the SOLAS regulates carriage of dangerous goods and the Chapter is
divided into four parts, and each part regulates different characteristic of goods,
materials or substances. MARPOL Annex II regulates the carriage of NLS in bulk,
and Annex III regulates marine pollutants transported in packaged form. Figure 3
shows applications of various IMO Codes under SOLAS or MARPOL. Some of
those Codes such as the IMDG Code, the IBC Code and the BCH Code17 are
referenced in both Conventions.
Table 4 shows a summary of the IMO instruments for carriage of dangerous goods
and harmful substances. The IMDG Code and the IMSBC Code18 require the
operational carriage requirements of specific dangerous goods or solid bulk cargoes
whereas, the IBC Code and the IGC Code19regulates a ship’s particular requirements
of construction and equipment for carriage of dangerous chemicals or gases.

16 International Maritime Dangerous Goods Code (IMO)
17 The Code for the Construction and Equipment of Ships carrying Dangerous Chemicals in Bulk
(IMO)
18 International Maritime Solid Bulk Cargoes Code (IMO)
19 The International Code for the Construction and Equipment of Ships Carrying Liquefied Gases in
Bulk (IMO)
10
Source: Drawn by Author, based on the SOLAS and MARPOL Conventions
Table 4 -Summary of the IMO instruments for carriage of dangerous goods and
harmful substances
Convention Part/
Annex Application Code Ship Type
SOLAS
Chapter VII
“Carriage of
Dangerous
Goods”
Part A
Carriage of dangerous goods in
packaged form IMDG
Containers
Break bulk
carriers
Part A-1
Carriage of dangerous goods in
solid form in bulk
IMSBC
Bulk carriers
Part B
Construction and equipment of
ships carrying dangerous liquid
chemicals in bulk
IBC
BCH
Chemical
tankers
SOLAS Chapter Ⅶ
Part A Part A-1
IMDG
Code
Part B Part C Part D
IMSBC
Code
IBC Code
BCH Code
IGC Code
GC Code
INF
Code
MARPOL 73/78
Annex Ⅲ Annex Ⅱ
Figure 3 -Application of various Codes under SOLAS 74 and MARPOL 73/78
11
Part C
Construction and equipment of
ships carrying liquefied gases
in bulk
IGC
GC
Gas carriers
Part D
Special requirement for the
carriage of packaged irradiated
unclear fuel, plutonium and
high-level radioactive wastes
on board ships
INF
Ships
carrying INF
cargoes
MARPOL
73/78
Annex II
Regulations for the control of
pollution by noxious liquid
substances in bulk
IBC
BCH
Chemical
tankers
Annex III
Regulations for the control of
pollution by harmful substances
carried by sea in packaged form
IMDG
Containers
Break bulk
carriers
Source: Summarized by Author based on the SOLAS and MARPOL Conventions
3.2 Various International Codes
3.2.1 IMDG Code
The IMDG Code was developed by IMO’s Maritime Safety Committee (MSC)
Working Group with support of the UN Committee of Experts on Transport of
Dangerous Goods (UNCTDG) from 1961 to 1965. The Code was approved by MSC,
and the IMO Assembly recommended the Code to the IMO Member States in 1965.
The present mandatory text of the Code was adopted by resolution MSC. 122(75)20
and has been mandatory since 1 January 2004 under SOLAS Chapter VII, Part A.
The Code applies only to packaged forms of dangerous goods transported by ships. It
has been amended every two years by IMO’s Sub-Committee on Dangerous Goods,
Solid Cargoes and Containers (DSC) followed by a subsequent amendment of the
UN Model Regulation21
.

20 Adoption of the International Maritime Dangerous Goods (IMDG) Code (24 May 2002)
21 Recommendations on the Transport of Dangerous Goods, Model Regulation (UN)
12
As shown in Figure 4, the UN Model Regulations are basic regulatory sources for
various modes of dangerous goods transported, such as TI22, RID23, ADR24 and.
ADN25 to provide international uniformity (Kim, 2008).
The IMDG Code is legally binding for IMO Member States signatory to SOLAS and
MARPOL. SOLAS Chapter VII, Part A, Regulation 1.3 prohibits the carriage of
dangerous goods except in accordance with the Code. MARPOL Annex III
Regulation 1.2 prohibits the carriage of harmful substances in ships except in
accordance with this Code.
The Code consists of Volumes 1, 2 and a Supplement. The regulations cover
principles of classification and definition of classes, listing of the principal dangerous
goods, general packing requirements, marking, labeling and transport documents to
ensure the safe transportation of the dangerous goods in packaged form (IMO, 2008).
Figure 4 -Regulatory structure of various modes of dangerous goods
transportation in packaged forms
Source: Drawn by Author

22 Technical Instructions for the Safe Transport of Dangerous Goods by Air
23 Regulations concerning the International Carriage of Dangerous Goods by Rail
24 European Agreement concerning the International Carriage of Dangerous Goods by Road
25 European Agreement for the International Carriage of Dangerous Goods by inland Waterway
IMO
UN
IMDG Code Model Regulation
TI
RID
ADR
ADN
SOLAS
Chapter Ⅶ, Part A
MARPOL
Annex Ⅲ
Air
Rail
Road
Inland waterway
13
3.2.2 IMSBC Code
The Code of Safe Practice for Solid Bulk Cargoes (BC Code) was developed by the
IMO’s DSC Sub-committee and has been published since 1965. The name of the BC
Code was changed to the International Maritime Solid Bulk Cargoes Code (IMSBC
Code) and it was adopted by resolution MSC.268 (85) 26 . The Code became
mandatory under Chapter VI and VII27 of the SOLAS Convention on 1 January 2011.
The Code applies to solid bulk cargoes which are divided into Cargo Group A28, B29
and C30
.
Figure 5 shows the regulatory structure of the solid bulk cargoes. Cargoes in Cargo
Group B are assigned one of the UN numbers31 which are used for the dangerous
goods listed in the IMDG Code.
The IMSBC Code mainly deals with operational aspects of cargoes before loading,
during loading or in transportation, and it contains provisions for loading, carriage
and unloading precautions, safety of personnel and ship, assessment of acceptability
of consignments for safe shipment and trimming procedures. Especially, Section 13
of the Code references the related information and recommendations and appendixes
of the Code containing individual schedules of solid bulk cargoes32 and laboratory
test procedures, associated apparatus and standards33 (IMO, 2008).

26 Adoption of the International Maritime Solid Bulk Cargoes (IMSBC) Code(4 December 2008)
27 Chapter VII, Part A-1
28 May liquefy if shipped at moisture content in excess of their transportable moisture limit
29 Possess a chemical hazard which could give rise to a dangerous situation on a ship
30 Neither liable to liquefy (Group A) nor to possess chemical hazards (Group B)
31 Four-digit numbers that identify hazardous substances, and articles (such as explosives, flammable
liquids, toxic substances, etc.) in the framework of international transport ,which assigned by the
United Nations Committee of Experts on the Transport of Dangerous Goods(http://en.wikipedia.org)
32 Appendix 1 of the IMSBC Code
33 Appendix 2 of the IMSBC Code
14
Figure 5 -IMO’s regulatory structure of the solid bulk cargoes
Source: Drawn by Author
3.2.3 IBC Code and BCH Code
The IBC Code was adopted by resolution MSC.4 (48)34. This Code primarily deals
with ship design and equipment for carrying dangerous chemicals listed in Chapter
17 of the Code. The Code also covers marine pollution substances under Annex II to
MARPOL by resolution MEPC.19 (22)35 from 1985. In addition, Chapter 16 of the
Code deals with operational requirements such as cargo information, personnel
training and opening and entry into cargo tanks (IMO, 2007).
Figure 6 shows the regulatory concept of liquid in bulk transported by ships. SOLAS
regulates safety aspects of dangerous chemicals and MARPOL regulates marine
pollution aspects of NLS cargoes. The IBC Code contains lists of products which are
regulated by two umbrella Conventions. Products listed in Chapter 17 of the Code
are under SOLAS. All products which are listed in Chapters 17 or 18 and that are
categorized as the X, Y and Z have to meet the MARPOL Annex II. Other
Substances (OS) are not regulated by either of the Conventions.

34 Adoption of the International Code for the Construction and Equipment of Ships Carrying
Dangerous Chemicals in Bulk (IBC Code) (17 June 1983)
35 Adoption of the International Code for the Construction and Equipment of Ships Carrying
Dangerous Chemicals in Bulk (IBC Code) (5 December 1985)
IMDG Code
Carriage of Dangerous Goods
in Solid Form in Bulk
Carriage of Cargoes
IMSBC Code
Cargoes
SOLAS
Group A Group C Group B
Chapter Ⅵ
Part A & B
Chapter Ⅶ
Part A-1
15
Figure 6 -The regulatory concept of products listed in the IBC Code
Source: Drawn by Author
Figure 7 shows the regulatory concept of the IBC and BCH Codes. The IBC Code
applies to chemical tankers built after 1 January 1986 and it is a mandatory
instrument under SOLAS and MARPOL Annex II. The BCH Code applies to
chemical tankers built before 1 January 1986 and it is mandatory under SOLAS and
recommendatory under MARPOL Annex II (IMO, 2006).
Not regulated
IBC Code Chapter 18
(Category OS)
Regulated by SOLAS Regulated by MARPOL
Transportation of liquid in bulk
Safety Marine pollutant
SOLAS
Chapter Ⅶ, Part B
MARPOL 73/78
Annex Ⅱ
IBC Code
IBC Code
Chapter 17
IBC Code
Chapter 17 & 18
(Pollution categories
X, Y, Z)
Aspect
Convention
Code
Cargo list
16
Figure 7 -Regulatory concept and application of IBC Code and BCH Code
Source: Drawn by Author
3.2.4 IGC Code and GC Code
The IGC Code was developed and adopted by the MSC by resolution MSC.5 (48)36
.
This Code regulates ship’s construction and equipment to carry liquefied gases listed
in Chapter 19 of the Code. It was made mandatory by resolution MSC.6 (48)37 under
Chapter VII, Part C of the SOLAS. Figure 8 shows the regulatory concept of the IGC
and the GC Code38. The IGC Code applies to gas carriers built after 1 January 1986,
and The GC Code applies to gas carriers built before 1 January 1986 and it is
recommendatory under SOLAS.
The IGC Code contains general and specific requirements for gas carriers such as
ship survival capability, location of cargo tanks, cargo containment material and
cargo control and tank venting systems. In addition, Chapter 18 of the Code contains
operational requirements (IMO, 1993).

36 Adoption of the International Code for the Construction and Equipment of Ships Carrying
Liquefied Gases in Bulk (IGC Code) ) (17 June 1983)
37 Adoption of amendments to the international convention for the safety life at sea, 1974 (17 June
1983)
38 The Code for the Construction and Equipment of Ships Carrying Liquefied Gases in Bulk
SOLAS Chapter Ⅶ, Part B
Mandatory
Recommendatory
Chemical tanker built
after 1 July 1986 Application
IBC Code BCH Code
MARPOL Annex II
Chemical tanker built
before 1 July 1986
Mandatory
17
Figure 8 -Regulatory concept and application of IGC Code and GC Code
Source: Drawn by Author
3.2.5 INF Code
The International Code for the Safe Carriage of Packaged Irradiated Nuclear Fuel,
Plutonium and High-level Radioactive Wastes on Board Ships (INF Code) was
developed by the joint working group, which consists of IMO, IAEA and UNEP39
and adopted by resolution A.748 (18)40 in 1993. The Code has been mandatory since
1 January 2001 by resolution MSC.87 (71)41 under Part D, Chapter VII of SOLAS
Convention. The Code applies to all ships regardless of build date, which are
carrying INF cargoes, regulated by the IAEA42 and classified as class 743 under the
IMDG Code.
INF cargo ships are assigned to Class INF 1, 2 and 3 ships44 under the Code,
depending on the total radioactivity of INF cargoes carried on board ships. This Code

39 United Nations Environment Programme (Nairobi)
40 Code for the Safe Carriage of Irradiated Nuclear Fuel, Plutonium and High-level Radioactive
Wastes in Flasks on Board Ships(4 November 1993)
41 Adoption of Amendments to the International Convention for the Safety of Life At Sea, 1974, as
amended (27 May 1999)
42 International Atomic Energy Agency (Vienna)
43 Packaged radioactive materials
44 Class INF I ship – Ships which are certified to carry INF cargo with an aggregate activity less than
4,000 TBq. Class INF 2 ship – Ships which are certified to carry irradiated nuclear fuel or highlevel radioactive wastes with an aggregate activity less than 2 x 106 TBq and ships which are
certified to carry plutonium with an aggregate activity less than 2 x 105
TBq. Class INF 3 ship –
Ships which are certified to carry irradiated nuclear fuel or high-level radioactive wastes and ships
which are certified to carry plutonium with no restriction of the maximum aggregate activity of the
materials(INF Code, Chapter 1.1.2)
SOLAS Chapter Ⅶ, Part C
Mandatory Recommendatory
Gas Carrier built
after 1 July 1986
Gas Carrier built
before 1 July 1986
Status
Application
IGC Code GC Code
18
regulates items such as damage stability, fire safety measures, temperature control of
cargo space, radiological protection, management and training, shipboard emergency
plan and notification in the event of an incident involving INF cargo (IMO, 2007).
19
CHAPTER 4
IMO’S INSTRUMENTS FOR THE Assessment OF SAFETY
AND POLLUTION HAZARDS OF CHEMICALS IN BULK
TRANSPORTED BY SHIPS
This chapter focuses on the specific IMO instruments concerning Assessment of safety
and pollution hazards of chemicals in bulk, specifically all the relevant IMO
guidelines and documents under MARPOL Annex II and the IBC Code. In addition,
the products which are listed in the IBC Code and relevant IMO documents will be
analyzed. The international authorized bodies, including organizational structure and
functions of relevant IMO Committees and its Working Group, involved in the
Assessment of chemicals will be reviewed. Furthermore, the Assessment criteria and
the procedures will be summarized and analyzed based on the Globally Harmonized
System of Classification and Labelling of Chemicals (GHS) developed by OECD45
.
4.1 International regulations, guidelines and documents
Table 5 shows various regulations, guidelines and documents for the Assessment of
safety and pollution hazards of chemicals. Most of these documents are the result of
IMO’s MEPC or BLG Sub-committee. The GESAMP Report and Study No. 64 was
developed by the GESAMP Group46. Industries are required to review most of these
documents before they transport a new product which is not listed in the IBC Code or
the latest version of MEPC.2/Circular. These instruments are binding under the
SOLAS Chapter VII, Part B and/or MARPOL Annex II.

45 Organization for Economic Co-operation and Development (Paris)
46 Joint Group of Experts on the Scientific Aspects of Marine Environmental Protection (sponsored by
eight UN Agencies)
20
Table 5 -Summary of international regulations, guidelines and documents
Instruments Section Contents
MARPOL
Annex II
Regulation 6
– Marine pollution categorization
– Administrative procedures for transportation
of new products
Appendix 1 – Pollution category Assessment criteria
IBC Code Chapter 21 – Criteria for assigning carriage requirements
MEPC.1/Circ.512(16 May 2006) – Guidelines for the provisional assessment
MEPC.2/Circs.(Annually issued)
– Provisional Categorization of Noxious
Liquid Substances
GESAMP Report and
Study No. 64
– The Revised GESAMP Hazard Assessment
Procedure for Chemical Substances Carried
by Ships
BLG.1/Circ.33 (09 August 2011)
– Summary of decisions taken on the
interpretation of the ratings of GESAMP
Hazard Profiles and other related decisions
with respect to the categorization and
classification of products
Report of the GESAMP/EHS
Working Group
– Report of the GESAMP/EHS Working
Group on the Assessment of the Hazards of
Harmful Substances Carried by Ships which
is issued annually as BLG.1/Circulars
BLG.1/Circ.27(18 August 2008) – Tripartite Agreement on the IMO website
BLG.1/Circ.28(18 August 2008)
– The introduction of in charges for product
Assessment work undertaken by
GESAMP/EHS
GHS
– Basic Assessment and laboratory criteria for
Chapter 21 of IBC Code
Source: Summarized by Author
21
4.1.1 MARPOL 73/78 Annex II
MARPOL Annex II regulates marine pollution aspects when evaluating NLS.
Regulation 6 of Annex II to the Convention contains the framework for the pollution
categorization and administrative procedures for the transportation of new NLS in
bulk by ships. The categorization of NLS and OS are as follows under the
Convention.
Category X: Deemed to present a major hazard to either marine
resources or human health and, therefore, justify the prohibition of the
discharge into the marine environment
Category Y: Deemed to present a hazard to either marine resources
or human health or cause harm to amenities or other legitimate uses of
the sea and therefore justify a limitation on the quality and quantity of
the discharge into the marine environment
Category Z: Deemed to present a minor hazard to either marine
resources or human health and therefore justify less stringent
restrictions on the quality and quantity of the discharge into the marine
environment
Category OS: Considered to present no harm to marine resources,
human health, amenities or other legitimate uses of the sea when
discharged into the sea. “Other Substances” shall not be subject to any
requirements of the) Annex
Regulation 6.3 requires the governments of Parties to the Convention to establish and
to agree on a provisional assessment for the proposed operation on the basis of the
guidelines 47 for liquid substances in bulk, which have not been categorized.
Regulation 6.2 references the guidelines in Appendix 1 to Annex II. In addition, the
Regulation requires that when the agreement has been reached among the involved
countries, the shipping country has to notify the IMO within 30 days of the

47 Guidelines in the Appendix 1 of Annex II to MARPOL 73/78
22
agreement. The notification will be kept by IMO until the next amendment of the
IBC Code is carried out (IMO, 2006).
Appendix 1 of Annex II is the guidelines for the categorization of NLS and it details
a pollution category Assessment criteria based on the GESAMP Hazard Profiles. The
Appendix references MEPC/Circ.265 48 , as amended for the guidelines for
provisional assessment of chemicals, which was superseded by MEPC.1/Circ.512.
The revised Guidelines for the provisional assessment of liquid substances
transported in bulk were approved by the MEPC at its fifty-fourth session in 2006.
4.1.2 IBC Code
Chapter 21 of the IBC Code has guidelines for the criteria for assigning carriage
requirements for products to be listed into Chapter 17 of the Code or
MEPC.2/Circular. The basic criteria are developed under GHS for a uniform
approach. However, it emphasizes that these are only guidelines. The Chapter
contains criteria for safety and pollution, and the assignment of minimum carriage
requirements for products, such as ship type, tank type and tank environmental
control.
4.1.2.1 Products listed in the IBC Code
Table 6 shows the number of products listed in the IBC Code. 709 products are listed
in Chapter 17, and 39 products in Chapter 18. In total 748 products are listed in the
Code. Figure 9 shows hazard types49 of products listed in Chapter 17 of the Code.
45.7 % of the products has safety and pollution (S/P) hazards, and 53.88% has only a
pollution hazard (P), and less than 0.5% has only safety hazard (S).

48 The Guideline for Provisional Assessment of Chemicals
49 “S” means that the product is included in the Code because of its safety hazards; “P” means that the
product is included in the Code because of its pollution hazards; and “S/P” means that the
product is included in the Code because of both its safety and pollution hazards (IBC Code,
Chapter17: explanatory notes)
23
Table 6 -Products listed in the IBC Code by pollution categories and hazard
type
Chapter
Pollution
Categories
Hazard type
Total
S S/P P
17
X 0 30 59 89
Y 1 244 233 478
Z 2 50 90 142
Sub-total 3 324 382 709
18
Z – – – 26
OS – – – 13
Sub-total – – – 39
Total 3 324 382 748
Source: Calculated by Author, based on the products listed in the IBC Code50
Figure 9 -Hazard types of products listed in Chapter 17 of the IBC Code
Source: Drawn by Author based on the table 6

50 Published in 2007 and has been mandatory since 1st January 2009

Hazard type
$ ,
–
$ ,
– .
/
) /
24
Table 7 shows the number of products under the pollution categorization and ship
type51 in Chapter 17 of the IBC code. The majority of the substances are required to
be carried by Type 2 ships, followed by Type 3 ships and Type 1 ships. Figure 10
indicates that pollution category Y substances account for about 63.9 % of all
products listed in the Code, followed by Z that occupies 22.5 %, and then X that is
11.9 % of the total listed substances.
Table 7 -Products listed in the Chapter 17 of IBC Code by pollution categories
and ship type
Chapter Pollution
Categories
Ship type
Total
1 2 3
17
X 22 67 0 89
Y 3 307 168 478
Z 0 13 129 142
Total 25 387 297 709
Source: Calculated by Author, based on the Chapter 17 of the IBC Code

Figure 10 -Percentage of the pollution categories and ship type
Source: Drawn by Author

51 A type 1 ship is a chemical tanker intended to transport chapter 17 products with very severe
environmental and safety hazards which require maximum preventive measures to preclude an
escape of such cargo. A type 2 ship is a chemical tanker intended to transport chapter 17 products
with appreciably severe environmental and safety hazards which require significant preventive
measures to preclude an escape of such cargo. A type 3 ship is a chemical tanker intended to
transport chapter 17 products with sufficiently severe environmental and safety hazards which
require a moderate degree of containment to increase survival capability in a damaged condition
(IBC Code, Chapter 2.1.2)
0

1

2

($

–

+

–

+

–

+

Figure 11 shows the number of
709 substances have to
substances have been assigned one of the pollution
MARPOL Annex II. Only 13
hazard. Therefore, more than 98% of
hazardous substances to human
Figure 11 -The number of
Source: Compiled by Author, based on the
Considering most of the
and Annex II to MARPOL
Appendix 1 of the Annex II to MARPOL and Chapter 21 of the IBC Code
single instrument may be
criteria referenced in those IMO instruments.
4.1.3 MEPC.2/Circular
MEPC.2/Circulars are revised
II and have 10 annexes. Annexes 1
synonyms for vegetable oils
reporting of Tripartite Agreements
Cargo listed in the IBC Code:(chapter 17 + category X,Y, Z + OS)
748
(709+26+13)
Under MARPOL 73/78 Annex II: pollution category X, Y and Z
735
(709+26)
25
shows the number of products that are regulated under both
have to meet the IBC Code requirements under SOLAS
substances have been assigned one of the pollution categories X, Y and Z
Only 13 OS products (1.7%) do not have safety or pollution
herefore, more than 98% of the products listed in the IBC Cod
hazardous substances to human beings and/or the environment.
The number of products that regulated by tow Conventions
uthor, based on the products listed in the IBC Code
the products listed in the IBC are subject to both
MARPOL. Therefore, integration of the separated guidelines
Appendix 1 of the Annex II to MARPOL and Chapter 21 of the IBC Code
single instrument may be considered in the future, including all relevant Assessment
criteria referenced in those IMO instruments.
MEPC.2/Circulars
revised annually under Regulation 6.3 of the MARPOL Annex
annexes. Annexes 1 through 5 provide lists of NLS
ynonyms for vegetable oils and Annex 7 and 8 have information to support the
reporting of Tripartite Agreements as shown in Table 8.
Cargo listed in the IBC Code:(chapter 17 + category X,Y, Z + OS)
Under MARPOL 73/78 Annex II: pollution category X, Y and Z
735
(709+26)
Under SOLAS 74
709(listed in the chapter 17 of IBC Code)
both Conventions.
SOLAS and 735
X, Y and Z under
do not have safety or pollution
listed in the IBC Code are
tow Conventions
listed in the IBC are subject to both the IBC Code
. Therefore, integration of the separated guidelines both in
Appendix 1 of the Annex II to MARPOL and Chapter 21 of the IBC Code into a
in the future, including all relevant Assessment
the MARPOL Annex
NLS. Annex 6 has
have information to support the
Cargo listed in the IBC Code:(chapter 17 + category X,Y, Z + OS)
Under MARPOL 73/78 Annex II: pollution category X, Y and Z
709(listed in the chapter 17 of IBC Code)
26
Table 8 – List of Annexes in MEPC.2/Circular
Annex Contents
1 List 1: Pure or technically pure products
2 List 2: Pollutant only mixtures containing at least 99% by weight of
components already assessed by IMO
3 List 3: (Trade-named) mixtures containing at least 99% by weight of
components already assessed by IMO, presenting safety hazards
4 List 4: Pollutant only mixtures containing one or more components,
forming more than 1% by weight of the mixture, which have not yet been
assessed by IMO
5 List 5: Substances not shipped in pure form but as components in mixtures
6 Synonyms for vegetable oils
7 Country abbreviations
8 Tripartite contact addresses
9 Manufacturers authorized to conduct pollutant-only assessments by
calculation
10 Cleaning additives
Source: IMO. (2010). Provisional Categorization of Liquid Substances (MEPC.2/Circ.16)
4.1.3.1 Products listed in the MEPC.2/Circular
This circular contains substances which have not been listed in the IBC Code since
the latest amendment of the Code and are currently being transported. The
amendment of the 2007 IBC Code included substances which were listed in the
MEPC 2/Circ.1352. Therefore, Circulars which have been issued since 2008 contain
substances which were not included in the current edition of the IBC Code53. Table 9
shows the number of products listed in MEPC.2/Circulars between 2008 and 2010.
403 products were listed at the end of 2010.

52 Issued in 17th December 2007
53 The latest version of IBC Code, published in 2008 and entered into force from 1st of January in
2009
27
Table 9 -Products listed in MEPC.2/Circulars (year 2008 to 2010)
Year Circ. No.
Noxious Liquid Substances(NLS)
Total
List 1 List 2 List 3 List 4
2010 16 58 268 76 1 403
2009 15 52 367 56 7 482
2008 14 40 374 25 9 448
Average 50 336 52 6 444
Source: Calculated by Author, based on the products listed in the MEPC.2/Circ.14 to 16(IMO)
4.1.4 MEPC.1/Circ.512
MEPC.1/Circ.512 is the revised guidelines for the provisional assessment of liquid
substances transported in bulk which were approved by the MEPC fifty-fourth
session in 2006. These guidelines contain information concerning the Assessment, and
its procedures for assigning the carriage requirements for all new products. Table 10
shows the contents of the guidelines in the MEPC.1/Circ.512. In addition, this
circular is a main source of all the relevant other guidelines for Assessment criteria.
Table 10 -Information in the annex of the MEPC.1/Circ.512
Contents Information and guidance
Section 1
– Definition of the liquid products and application of the
guidelines
Section 2 – Identification of the assessed products
Section 3
– Division of the unassessed products groups and general
information for the provisional assessment
Section 4
– Guidance for the Administration to assess the pure or technically
pure product’s pollution, safety hazard, and Administrative
aspect for the Tripartite Agreement
Section 5
– Guidance for the calculation of the Pollution Category for
pollutant only mixtures containing products already assessed by
IMO to assign the carriage requirements
Section 6 – Guidance for assessment of trade named mixtures presenting
28
safety hazards containing only products already assessed by IMO
Section 7
– Assessment of mixtures containing one or more components
which have not yet been assessed by IMO
Section 8
– Necessary information to submit data to GESAMP/EHS and
IMO
Appendix 1 – Procedural diagrams for the assessments and its administration
Appendix 2
– Example of an addendum to the ship’s certificate of
fitness/International certificate of fitness/International pollution
prevention certificate for the carriage of Noxious Liquid
Substances in bulk
Appendix 3
– Format for proposing Tripartite Agreements for provisional
assessment of liquid substances
Appendix 4 – BLG Products Data Reporting Form
Appendix 5
– Guidelines on the completion of the BLG Product Data
Reporting Form
Appendix 6
– Example of the calculation method for determination of pollution
categories and ship types for mixtures
Source: IMO. (2006 May 16). Revised guidelines for the provisional assessment of liquid substances
transported in bulk (MEPC.1/Circ.512)
4.1.5 GESAMP Report and Study No. 64
The GESAMP Report and Study No. 64 is the Revised GESAMP Hazard Assessment
Procedure for Chemical Substances Carried by Ships, which was developed by
GESAMP in consultation with OECD for the harmonization with the GHS. The first
draft publication was in 199854
.
These guidelines are closely linked to Appendix 1 of the MARPOL Annex II. It
contains the hazard Assessment rationale, procedures and laboratory test information,
especially focused on human and environmental hazards. In addition, it offers advice
to manufacturers and administrations, such as submitting data to GESAMP based on

54 GESAMP Report and Study No. 64, p. v
29
scientific aspects. Furthermore, it contains detailed Assessment criteria such as
bioaccumulation and biodegradation, aquatic toxicity, acute mammalian toxicity,
skin corrosion and long term health effects (GESAMP, 2002).
The recommended guidance on the required quality standards of test reports are as
follows55
.
– Laboratories carrying out such studies are registered as being in
compliance with OECD GLP 56 or have appropriate alternative
accreditation, e.g. for testing physical properties
– The reports of such studies contain a quality assurance statement and
– The tests met the stated validity criteria of the appropriate test
Guidelines.
Therefore, the contents of these guidelines are significantly important for the
chemical manufacturer to collect the necessary Assessment data and laboratory test
information. Especially, considering that the GESAMP/EHS meeting is only held
once a year. The quality of data, which is submitted to the GESAMP/EHS might
determine the period of time for Assessment. Improper submission of required data to
the GESAMP/EHS may make the manufacturer wait one more year for resubmission, delaying the time of entry to the IBC Code.
4.1.6 Report of the GESAMP/EHS Working Group
The Report of the GESAMP/EHS Working Group on the Assessment of the Hazards
of Harmful Substances Carried by Ships is circulated normally once a year after the
Group’s meeting as BLG.1/Circulars57. This report deals with various matters which
arise from IMO relating to the results of the ESPH Working Group, BLG Sub-

55 GESAMP Report and Study No. 64, p. 23
56 Good Laboratory Practice is a quality system for reliable and efficacy laboratory tests, outlined by
OECD
57 The latest circular is BLG.1/Circ.31(20 April 2011), IMO
30
committee and MEPC Committee, concerning the Assessment of harmful substances
under MARPOL Annex II.
The report contains the resultant hazard profiles for those products which become
basic data for the assignment of carriage requirements for the specific substance.
Annex 6 of the report also has an updated composite list of hazard profiles for the
chemical industry to check whether the chemicals which are supposed to be carried
by ships were already evaluated or not. If the chemical composite hazard profile is
available in the list, the industry does not need to further evaluate the chemical.
Therefore, the information in the composite list is a valuable source for the industry
to find chemical hazard Assessment data (GESAMP/EHS, 2011).
4.1.7 BLG.1/Circ.33 (09 August 2011)
This Circular contains decisions with regard to the categorization and classification
of products which are based on the interpretation of the ratings of GESAMP Hazard
Profiles and other related decisions with respect to the categorization and
classification of new products. This interpretation was developed by the ESPH
Working Group for the Assessment of NLS. It has all the summarized relative
decisions form BLG meeting documents and report of the GESAMP/EHS Working
Group, such as “NI”, or “ratings in brackets” in the GESAMP Hazard Profiles and
the procedures for estimating acute inhalation toxicity ratings. Therefore, this
Circular can be valuable information for the chemical industry for the chemical
hazard Assessment, especially to understand the GESAMP Hazard Profiles (IMO,
2011).
4.1.8 BLG.1/Circ.27 (18 August 2008)
This Circular (see Appendix A) was proposed by the BLG, in 200758 to ensure that

58 BLG 11/3/8(23 February 2007), proposed by INTERTANKO
31
information on provisional assessments is available on IMO’s public website59 to
reduce unnecessary burdens on both the industry and IMO Member States. Because
the MEPC.2/Circulars have been updated in December each year; therefore, the
Member States may not know the Tripartite Agreement information for the
transportation of certain products between subsequent MEPC.2/Circulars are released.
This Circular was circulated in 2008. Therefore, the industry can check its new
product whether it has been transported or not on the IMO’s website before initiating
new Tripartite Agreement (IMO, 2008).
4.1.9 BLG.1/Circ.28 (18 August 2008)
This Circular (see Appendix B) is an introduction of product Assessment work
undertaken by GESAMP/EHS. The industry requires the GESAMP Hazard Profile
for Assessment of unassessed substances. However, the GESAMP/EHS Working
Group had worked, on behalf of industry, to assess the hazards of chemicals and had
issued the hazard profile for the industry without an Assessment fee. Therefore,
considering the work performed by the Group and for the long-term funding solution,
the MEPC at its fifty-sixth session in 2007 agreed to share the funding costs with
IMO and the industry. Therefore, the industry incurs costs60 for the chemical
Assessment (IMO, 2008).
4.1.10 GHS
GHS was developed through efforts from many countries and international and
intergovernmental organizations such as OECD, ILO61, UNSCETDG, FAO62 and
EU63 to enhance the protection of human health and the environment through
harmonized hazard communication. It was adopted by UNCETDG and GHS in 2002

59 IMO website: Marine Environment/Carriage of Chemicals/Tripartite Agreements
60 The industry should pay non-refundable fee of US$6,500 in advance for each component of
chemicals directly to the GESAMP/EHS as the same way for the submission of data to the Group
61 International Labour Organization
62 Food and Agriculture Organization of the United Nations
63 European Union
32
and the first edition was published in 2003. It has been amended by UNSCEGHS64
.
GHS provides harmonization of standards for regulations on chemical related matters
(UNECE65 website, 2011).
Chapter 3 of the GHS provides criteria and recommended laboratory test methods,
which are referenced in Chapter 21 of the IBC Code, such as acute mammalian
toxicity, toxic to mammals by prolonged exposure, skin sensitization/corrosive and
respiratory sensitization, which have become the principal information for hazard
Assessment of substances (UN, 2009).
4.2 Relevant international bodies relating to the Assessment
Figure 12 shows the organizational structure of the international authorized bodies
that are directly involved in the development of regulations and guidelines for the
Assessment criteria and procedures of liquids in bulk. MSC deals with safety aspects
concerning SOLAS, and MEPC handles the marine pollution related matter
concerning MARPOL. The BLG Sub-committee considers technical details for the
safe carriage of harmful liquids in bulk under the MSC and MEPC Committees. The
ESPH Working Group deals with various technical matters relating to the Assessment
of safety and pollution hazards of chemicals.
Figure 12 -Organizational structure of the international authorized bodies
Source: Drawn by Author

64 UN Sub-committee of Experts on GHS
65 United Nations Economic Commission for Europe
IMO
BLG
GESAMP/
EHS WG
MSC MEPC
ESPH WG UNSCEGHS
33
4.2.1 BLG Sub-committee
The BLG Sub-committee, which was organized in 1996, works under MSC and
MEPC. The BLG considers various matters related to the prevention of marine
pollution from ships involved in the technical aspects of handling and transporting
dangerous chemicals and NLS in bulk. Therefore, BLG’s main work is the
amendment and preparation of relevant regulatory instruments, such as MARPOL
Annex II, IBC Code, IGC Code and their non-mandatory guidelines. Consideration
of the Assessments and carriage requirements of newly transported substances has
been one of the main working agenda items of the BLG. In addition, BLG shares and
discusses scientific and technical aspect of marine pollution matters with GESAMP.
4.2.2 ESPH Working Group
The ESPH is a formal Working Group that works under the MEPC and the BLG in
IMO. The Group consists of member governments of IMO and NGO66. Meetings are
normally held twice a year. One is an intercessional meeting, normally held in
October and the other is a working group meeting which is held during the BLG Subcommittee meeting. The Group’s work particularly focuses on the issues relating to
the Assessment of new products and their carriage requirements, as well as Assessment
of cleaning additives. Additionally, the Group reviews the MEPC.2/Circular and any
other matters as instructed by the BLG Sub-committee. The Group’s meeting report
or working paper is reported to the BLG or directly to the MEPC for further
consideration.
4.2.3 GESAMP/EHS Working Group
GESAMP is an advisory body, which consists of specialized experts nominated by
the sponsoring agencies67. The Group was established in 196768 by the United
Nations Agencies and provides scientific advice concerning marine environment

66 Non-Governmental Organization
67 IMO, FAO, UNESCO-IOC, WMO, WHO, IAEA, UN, UNEP
68 Source by IMO website
34
protection. The GESAMP/EHS69 evaluates the hazards of liquid substances carried
by ships under MARPOL Annex II. The GESAMP/EHS has developed the
GESAMP Hazard profiles for the substances during their meeting based on the
chemical data70 submitted by the industry, and returns the profile to the industry.
The Group’s meeting is normally held every year between February and April in the
IMO building. The Group meeting report has been circulated as BLG.1/Circulars71
.
4.3 International Assessment criteria
Figure 13 shows the international laboratory test guidelines and Assessment criteria
for hazardous substances. The criteria basically consist of three steps, namely
laboratory test, Assessment of chemical hazards and assignment of carriage
requirements and a pollution category. The principal guidelines for the laboratory
and Assessment are GHS. The GESAMP Report and Study No. 64 were developed for
the chemical industries based on the GHS. In addition, the GHS is guidance for the
criteria in Chapter 21 to the IBC Code. The GESAMP/EHS Working Group
considers the technical information of the specific substances during their meetings
and develops the GESAMP Hazard Profiles based on the data submitted by the
chemical industry. The Hazard Profiles contain necessary hazard rating information
for further Assessments by Administrations and the BLG Sub-committee to assign a
pollution category and carriage requirements of a specific chemical.

69 GESAMP Working Group on the Assessment of the Hazards of Harmful Substances Carried by
Ships
70 Data based on the GESAMP/EHS Product Data Reporting Form
71 The latest version: BLG.1/Circ.31 (20 April 2011), Report of the forty-eighth session of the
GESAMP/EHS Working Group On the Assessment of the Hazards of Harmful Substances Carried
by Ships, by IMO
35
Figure 13 -International laboratory test guideline and Assessment criteria for the
hazardous substances
Source: Drawn by Author
4.3.1 GESAMP Hazard Profiles
GESAMP Hazard Profiles72 provides hazard information for each NLS and the

72 The latest circulation was in Annex 6 of the BLG.1/Circ.31(20 April 2011)
GESAMP Report
and Study No. 64
Laboratory Test
Guideline
GESAMP Hazard
Profiles
– Contains necessary
hazard data of a
substance for next
Assessments
Assessments
Criteria
MARPOL 73/78
Annex II, Appendix I
– Guideline for the
categorization of
noxious liquid
substances
Pollution Category
Global Harmonized System (GHS)
IBC Code Chapter 21
– Criteria for assigning
carriage requirements
Carriage requirements &
Ship Type
Requirement for
the IBC Code
Chapter 17 & 18
entry
Other test
data
36
criteria for the categorization of the respective product. This Profile is reviewed
annually by the GESAMP/EHS Working Group. The assignment of marine pollution
aspect ship types are also based on the Hazard Profile. Figure 14 shows the
composite of Hazard Profiles. Among the information in the profiles the A1, A2, B1,
B2, D3 and E2 are used to define pollution categories under the Appendix I of the
Annex II to MARPOL.
Figure 14 -GESAMP/EHS Composite List GESAMP Hazard Profiles
Source: IMO. (20 April 2011). Annex 6 of the BLG.1/Circ.31
4.3.2 MARPOL 73/78 Annex Ⅱ, Appendix I
Appendix I of Annex II to MARPOL (see Appendix C) contains criteria for the
categorization of the NLS based on the GESAMP Hazard Profiles. The detailed
information for the criteria and test procedures are made in the GESAMP Report and
Study No.64. Table 11 shows the requirements of hazard information in the
Appendix I and their test guidance in the GESAMP Report and Study No.64. Most
data are principally based on the test results, except some criteria such as chronic
toxicity and long term health effects which are strongly dependent on reliable
evidence, human experiences and the expert’s judgment. Therefore, the GESAMP
Group is playing an important role as an expert group for the judgment of chemical
hazards.
The GESAMP Report has sufficient information for the Assessment of the severity of
the hazards as well as the test criteria to collect data for pollution categorization of
chemicals. The severity of chemical hazards are defined as X, Y, Z or OS
37
categorizations based on the Appendix I of Annex II to MARPOL.
Table 11 -Criteria for pollution categorization and laboratory test information
Criteria for categorization
Appendix I to Annex II
Criteria and laboratory test information in
GESAMP Report and Study No.64
Symbol Criteria for
categorization Subsection Guidance for test or
collection of hazard evidence
A1 Bioaccumulation 4.1.1
Sub-column A1
– Box 2 Guidance for
experimentally measuring and
calculating the log Pow
– Box 3 Guidance for
measuring bioconcentration in
fish
A2 Biodegradation 4.1.2
Sub-column A2
– Box 4 Guidance for
measuring ready
biodegradability
B1 Acute toxicity 4.2.1
Sub-column B1
– Box 5 Guidance for
measuring acute aquatic
toxicity
B2 Chronic toxicity 4.2.2
Sub-column B2
– Box 6 Guidance for
measuring chronic aquatic
toxicity
D3 Long-term health
effects
4.4.3
Sub-column D3
– Animal experiments
– Depend on reliable evidence
and on expert judgment.
E2
Effects on marine
wildlife and on
benthic habitats
4.5.2
Sub-column E2
– Supported by data on
environmental and human
health hazards from columns A
to D
Source: Summarized by Author
4.3.3 IBC Code Chapter 21
Chapter 21 of the IBC Code has guidelines for the minimum safety and pollution
criteria in determining carriage requirements of products subject to Chapter17 (see
Appendix D). The criteria are based on the GHS. In addition, the GESAMP Report
and Study No.64 have most of the information that are required by Chapter 21 of the
38
IBC Code as shown in Table 12. However, some information such as air reactive
substances is not available in the GHS73 or the GESAMP Report.
Table 12 -Required chemical data for the entry to the IBC Code and the test
information and criteria in the GHS and GESAMP Report and Study No.64
Assessment criteria for the
products subject to the IBC Code
Test information and criteria
GHS Chapter
GESAMP Report and
Study No.64 subsection
Acute mammalian toxicity
– Oral toxicity (LD5074)
– Dermal toxicity (LD50)
– Inhalations toxicity(LC5075)
Chapter 3.1 4.3 Column C
– 4.3.2 Sub-column C1
– 4.3.3 Sub-column C2
– 4.3.4 Sub-column C3
Toxic to mammals by prolonged
exposure
– C, M, R, N, and I76

Chapter 3.5,
Chapter 3.6,
Chapter 3.7
4.4.3 Sub-column D3:
Skin sensitization/corrosive Chapter 3.2 4.4.1 Sub-column D1
Respiratory sensitization Chapter 3.3 Nil
Water reactive substance Chapter 2.12 Nil
Air reactive substance Nil Nil
Source: Summarized by Author
4.4 International Assessment procedures
The step-by-step procedures for the Assessment of safety and pollution hazards
depend on the property of chemicals. However, normally the manufacturer has to
collect all necessary information and laboratory test results based on guidelines.

73 Based on the third edition of GHS published in 2009 (UN)
74 LD50, lethal dose to 50% of the exposed population
75 LC50, lethal Concentration to 50% of the exposed population
76 Stand for Carcinogen, Mutagen, Reprotoxic, Neurotoxic and Immunotoxic
39
Figure 15 -Procedural steps for the Assessment and carriage requirements
Source: Drawn by Author based on MEPC.1/Circ.512
Figure 15 shows the Assessment procedures for a pure or technically pure product
based on MEPC.1/Circ. 512. First, a manufacturer or shipper should check the IBC
Code Chapters 17, 18, 19 and the latest version of MEPC.2/Circular to identify
whether the chemical to be carried by ships has previously been transported or not.
Responsibility Procedures
Check whether the product has previously been
transported or not
Supply pollution and safety data to the Administration
for provisional assessment
Manufacturer/Shipper
Administration Check the product is assessed by GESAMP/EHS or not
Derive provisional hazard profiles and assess the new
product’s pollution category and carriage requirements
Propose Tripartite Agreements and transport the
chemical upon the agreements
Inform IMO within 30 days of Agreements
Keep the provisionally agreed information in
MEPC.2/Circular for three years validation
Submit GESAMP/EHS all data necessary for a formal
hazard Assessment
Carry out necessary laboratory test based on the GHS
and GESAMP Report and Study No.64
Submit hazard data of the chemical to the
Administration with proposed pollution category, ship
type and carriage requirements
Submit a proposal for a new and complete entry in the
IBC Code to IMO’ BLG Sub-committee or ESPH
The product will be included in the IBC Code
Manufacturer/Shipper
Administration
Administration
Manufacturer
IMO
Manufacturer
Manufacturer
Manufacturer
Administration
IMO
40
If the chemical was not carried previously by ships and it is expected to be
transported before a full assessment of hazards, the manufacturer and Administration
have to assess provisional hazards of the product. Then the exporting government
should propose the provisionally assessed pollution category, ship type and carriage
requirements of the product to Flag State and receiving governments for the
Tripartite Agreement and seek their consent under regulation 6.3 of Annex II of
MARPOL as shown in Figure 16.
The receiving governments and Flag State should respond to the proposed Assessment
results when they receive the Tripartite Agreement proposal from the exporting
government. If there is no response from the related parties within 14 days of the
proposed date, the proposal is deemed to be accepted. If there is no agreement
associated with the proposal, the most severe condition should be assigned for the
provisional carriage requirements. Figure 17 shows a detailed procedural diagram for
the Tripartite Agreement.
Consequently, the chemical can be transported by ship in bulk only amongst agreed
countries with issuance of ship’s certificate for shipment of the chemicals by Flag
State. After establishing a Tripartite Agreement, the exporting government should
communicate the Tripartite Agreement information to IMO within 30 days of the
agreement date.
IMO should list the product name and agreed provisional carriage requirements in
the MEPC.2/Circular or IMO website. If the chemical manufacturer expects to
transport the chemical beyond the three years expiration date of the agreement, the
chemical should be formally evaluated by GESAMP/EHS Working Group. The
Group will develop the GESAMP Hazard Profiles for the new product based on the
test data submitted by the manufacturer.
41
The final step is to bring the BLG Products Reporting Form to the BLG Subcommittee with proposed pollution category, ship type and carriage requirements by
the Administration for the final approval. The ESPH Working Group will review the
proposal. Finally, the product will be included in Chapter 17 or 18 of the IBC Code
or MEPC.2/Circular without expiration date of transport. See Appendix E for
detailed procedures for the pure or technically pure product or aqueous solution.
A manufacturer has to face a relatively long route and complex procedures for the
Assessment. In order to understand the full procedures and criteria for effective
Assessment, the collection of all necessary information will be the first step for the
manufacturer.
Figure 16 -Concept of Tripartite Agreement
Source: Drawn by Author
Provisional
Assessment
result
Flag State(s)
Shipping or producing
country
Receiving countries
Agree
Agree Agree
42
Figure 17 -The procedural diagram for the Tripartite Agreement.
Source: IMO. (2006 May 16). Revised guidelines for the provisional assessment of liquid substances
transported in bulk (MEPC.1/Circ.512)
43
CHAPTER 5
MEMBER STATES IMPLEMENTATION
This chapter will review national regulatory systems of some Member States to
determine how they adopt and implement these complex international instruments
into their national systems. The study will be based on the legal framework of those
governments. In addition, the difficulty and effectiveness of implementation of these
complex guidelines will be discussed.
According to the data analyzed in Chapter 2 of this study, the USA and the United
Kingdom are major exporters of new products and the Republic of Singapore
represents the leading major new chemical exporter in East Asia. Therefore, these
four countries including the Republic of Korea were selected to be analyzed.
5.1 Republic of Korea (ROK)
As shown in Table 13, the ROK adopted MARPOL Annex II into the Marine
Environment Management Act and the detailed requirements are specified by the
Regulation for the Prevention of Marine Pollution from Ships. The Regulation for the
Construction and Equipment of Ships Carrying Dangerous Chemicals in Bulk
regulates carriage of dangerous chemicals and ship’s specific requirements under the
Ship Safety Act. In addition, the Regulation accepts the products listed in the
MEPC.2/Circular and references MEPC.1/Circ.512 as provisional guidelines without
placing it into a national regulatory framework.
Table 13 -The legal framework of ROK for the carriage of liquid in bulk
IMO instruments Legal framework
MARPOL Annex II
– Marine Environment Management Act, Chapter 3,
Section 2, Article 27
– Regulation for the Prevention of Marine Pollution from
Ships (pollution categories X,Y, Z and OS)
44
IBC Code
– Ship Safety Act, Article 41
– Regulation for the Construction and Equipment of Ships
Carrying Dangerous Chemicals in Bulk
MEPC.1/Circ.512
– Not adopted into national regulation or guidelines.
However, directly bind and accept the international
guidelines77

Other documents – MEPC.2/Circular products: accepted78

Source: Summarized by Author
5.2 The United States of America (USA)
As shown in Table 14, the Code of Federal Regulations (CFR) Titles 33 and 46
adopted the MARPOL Annex II and the IBC Code respectively. NVIC79 03-06 is
guidelines developed to Help the industry, the public, the Coast Guard, and other
regulatory bodies. Enclosure 4 of this circular has detailed information regarding the
MEPC.1/Circ.512. In addition, the Enclosure 4 demonstrates each step to be taken by
the manufacturer for provisional assessment of a new product. However, all
necessary information and documents regarding full assessment by GESAMP/EHS
and final entry to the IBC Code might not be enough for the industry.
Table 14 -The legal framework of USA for the carriage of liquids in bulk
IMO instruments Legal framework
MARPOL Annex II – CFR Titles 33, Parts 151 and 158
IBC Code – CFR Titles 46, Parts 30, 98, 151 and 153
MEPC.1/Circ.512
– Guidance Regarding Classification of Product and
Tripartite Agreements (Enclosure (4) in NVIC 03-06)
Other documents – MEPC.2/Circular products: accepted by NVIC 03-06
Source: Summarized by Author

77 Regulation for the Construction and Equipment of Ships Carrying Dangerous Chemicals in Bulk,
Chapter 3, Section 1, Article 124, attached Table 5
78 Regulation for the prevention of marine pollution from ships Article 3, Paragraph 5
79 Navigation and Vessel Inspection Circular
45
5.3 The United Kingdom of Great Britain and Northern Ireland (GBR)
The GBR adopted MARPOL Annex II and IBC Code into the Merchant Shipping
Regulation 1994 as shown in Table 15. These Regulations are closely linked to the
mandatory IMO instruments and has been their national framework.
Table 15 -The legal framework of GBR for the carriage of liquid in bulk
Source: Summarized by Author
5.4 Republic of Singapore (SGP)
SGP adopted MARPOL Annex II and IBC into the Prevention of Pollution of the Sea
(Noxious Liquid Substances in Bulk) Regulations 2006 under the Prevention of
Pollution of the Sea Act and the Regulations reference MEPC/Circ.265 as guidelines
for provisional assessment of chemicals. The Maritime and Port Authority of
Singapore Act adopted the IBC Code as national legal framework as shown in Table
16.
Table 16 -The legal framework of SGP for the carriage of liquid in bulk
IMO instruments Legal framework
MARPOL Annex II
– Prevention of Pollution of the Sea Act (Chapter 243),
Prevention of Pollution of the Sea (Noxious Liquid
Substances in Bulk) Regulations 2006
IBC Code
– Maritime and Port Authority of Singapore Act (Chapter
170A), Maritime and Port Authority of Singapore
(Dangerous Goods, Petroleum and Explosive)
Regulations 2005
IMO instruments Legal framework
MARPOL Annex II
– The Merchant Shipping (Control of Pollution by Noxious
Liquid Substances in Bulk) (Amendment) Regulations
1994
IBC Code
– Merchant Shipping (IBC Code) (Amendment)
Regulations 1994
46
MEPC.1/Circ.512
– Appendix 1 of the Prevention of Pollution of the Sea
(Noxious Liquid Substances in Bulk) Regulations 2006
references the Guidelines for provisional assessment of
chemicals, MEPC/Circ.265 as amended
Source: Summarized by Author
This chapter found that most of the IMO Member States do not provide detailed
guidance within their national framework. They just referenced the MEPC.1/Circ.512
and/or MEPC.2/Circular because IMO’s Assessment instruments are not mandatory.
Furthermore, the documents are too complex to be adopted and need administrative
work to update the latest information. Therefore, just referencing the IMO guidelines
require the chemical industries to search and study the necessary information by
themselves with support by experts. Therefore, IMO’s non-mandatory instruments
are significantly important as the main sources of information.
47
CHAPTER 6
DIFFICULTIES IN USING OR UNDERSTANDING IMO
INSTRUMENTS AND POSSIBLE SOLUTIONS
This chapter will analyze and discuss the complexities of the current IMO
instruments. The difficulties to find regulations and guidelines as well as expertise
will be discussed. In addition, the possible ways for more effective and user-friendly
guidelines will be proposed to the IMO and the Administrations who are interested
and might find it beneficial.
6.1 Difficulties in IMO instruments
6.1.1 Complexity of guidelines in usage
Figure 18 shows the brief necessary steps to evaluate chemical hazards. Each step
requires sources of information and guidance.
Figure 18 -Brief steps for the Assessment of chemical hazards
Source: Drawn by Author
Steps of Assessment Required Information
See Table 17
See Table 18
See Table 19
Identification of the chemical
Provisional assessment
Transportation under tripartite
agreement
Assessment by GESAMP/EHS
Assign carriage requirements
and entry into the IBC Code
STEP 1
STEP 2
STEP 3
STEP 4
STEP 5
See Table 20
See Table 21
48
Table 17 shows the necessary sources to identify a product (STEP 1) whether it was
previously transported or not. The industry has to check Chapters 17, 18, 19 and the
latest version of MEPC.2/Circular, including the IMO website to check if there is a
Tripartite Agreement on that chemical.
Table 17 -Information required for identification of a new product80

Procedural tasks
(Responsibility) Required information Source
Check whether the
product is transported or
not before or currently
(Manufacturer/Shipper)
– IBC Code(Ch.17, 18 & 19)
– Products listed in the latest
version of MEPC.2/Circular
– IBC Code
– MEPC.2/Circular
Check IMO, if there is
Tripartite Agreement on
that chemical
(Manufacturer/Shipper)
– Tripartite Agreement on the
IMO website (Marine
Environment/ Carriage of
Chemicals/Tripartite
Agreements)
– BLG.1/Circ.27
Source: Compiled by Author
Table 18 shows the information required for provisional assessment (STEP 2). A
manufacturer or shipper should supply available chemical hazard data to the
Administration. The Administration should check the composite list of hazard
profiles of substances carried by ships which is annexed in the latest report of the
GESAMP/EHS Working Group Report. In addition, in order to assess provisional
hazards of the chemical, the Administration should follow the guidelines in
Appendix 1 of Annex II to MARPOL and Chapter 21 of the IBC Code.

80 A pure or technically pure product or mixture containing more than 1% by weight of unassessed
components
49
Table 18 -Information required for provisional assessment
Procedural tasks
(Responsibility) Required information Source
Supply pollution and
safety data to the
Administration
(Manufacturer/Shipper)
– Nil
Check the
product/components are
assessed by
GESAMP/EHS or not
(Administration)
– Composite list of hazard
profiles of substances
carried by ships
– The latest Report
of the
GESAMP/EHS
Working Group
(BLG.1/Circular)
Derive provisional hazard
profile and assess the new
product’s pollution hazard
(Administration)
– MARPOL, Annex II,
appendix 1
– MARPOL
Assess presents a safety
hazard and assign Ship
Type and carriage
requirements
(Administration)
– Chapter 21 of the IBC Code – IBC Code
Source: Compiled by Author
Table 19 contains information for the Tripartite Agreement (STEP 3). The
Administration should be well aware of the procedures in the MEPC.1/Circ. 512 to
complement the Tripartite Agreement. Furthermore, the Administration should check
the governments contact point in the MEPC.2/Circular. A ship owner has to check
how to issue the relevant ship’s certificate to transport the provisionally agreed
chemicals when necessary.
50
Table 19 -Information required for transportation under Tripartite Agreement
Procedural tasks
(Responsibility) Required information Source
Propose tripartite
agreements and inform
IMO
(Administration)
– Appendix 3 of the
MEPC.1/Circ.512,
– MEPC.2/Circular for
Governmental contact point
information
– MEPC.1/Circ.512
– MEPC.2/Circular
Relevant ship’s certificate
may be issued
(Ship owner)
– Appendix 2 of the
MEPC.1/Circ.512
– MEPC.1/Circ.512
Source: Compiled by Author
Table 20 shows the information for formal Assessment of chemicals by the
GESAMP/EHS Working Group (STEP 4). In order to submit the necessary chemical
hazard data to the GESAMP/EHS Group, a manufacturer should know what hazard
data and laboratory test are required. Additionally, available test facilities and their
standards should be checked. Furthermore, the manufacturer should be well aware of
the procedures, Assessment fees and document forms for submission. Therefore,
Chapter 21of the IBC Code, GHS, Appendix 1 to Annex II to MARPOL, GESAMP
Report and Study No. 64 and BLG.1/Circ. 28 should be checked.

Table 20 -Information required for Assessment by GESAMP/EHS
Procedural tasks
(Responsibility) Required information Source
Submit GESAMP/EHS
all data necessary for a
formal hazard Assessment
(Manufacturer)
– Chapter 21of IBC Code and
GHS laboratory test
information
– Appendix 1 of Annex II to
MARPOL and GESAMP
Report and Study No. 64
– BLG.1/Circ.28: The
– IBC Code
– GHS
– MARPOL
– BLG.1/Circ.28
– ESAMP Report
and Study No. 64
51
introduction of in charges
for product Assessment work
undertaken by
GESAMP/EHS
– GESAMP/EHS Data
Reporting From
Source: Compiled by Author
Table 21 shows sources for final approval of IMO and to assign carriage
requirements of the product (STEP 5). A manufacturer should use the BLG Product
Data Reporting Form, and has to review the relevant guidelines to assign all carriage
requirements in Chapter 17 of the IBC Code based on the GESAMP Hazard profiles.
Table 21 -Information that required for assignment of carriage requirements
and entery into the IBC Code
Procedural tasks
(Responsibility) Required information Source
Submit to the
Administration a
completed BLG Product
Data Reporting Form
(Manufacturer)
– BLG Product Data
Reporting Form which can
be downloaded from IMO
website
– IMO website
www.imo.org
Proposed assessment for
Pollution Category and
Ship Type and carriage
requirements
(Manufacturer)
– MARPOL, Annex II,
appendix 1
– Chapter 21 of the IBC Code
– BLG.1/Circ.33: Summary
of decisions taken on the
interpretation of the ratings
of GESAMP Hazard
Profiles
– IBC Code
– MARPOL
– BLG.1/Circ.33
Submit a proposal – Appendix 4 of the – MEPC.1/Circ.512
52
including the form for a
new and complete entry
in the IBC Code to IMO
(Administration)
MEPC.1/Circ.512
Source: Compiled by Author
As shown in Table 17 through Table 21, most of the guidelines and documents can be
found in different sources, such as IMO’s publications, website and circular
documents, and most of these instruments are linked to GESAMP guidelines and
GHS, and even each other. Considering that most product manufacturers are not
familiar with maritime affairs, this complex and separated IMO instruments can
place a great burden and unnecessary difficulty on the industry.
6.1.2 Difficulties in finding information
The MARPOL Annex II, Regulation 6.2 referenced the guidelines for the
categorization of NLS in accordance with Appendix 1 to the Annex II, and the
Appendix references the MEPC/Circ.265, as amended. However, this guideline had
been superseded by the MEPC.1/Circ.512, the revised guidelines in 2006. Chapter 21
of the IBC Code also does not reference the revised guidelines. Only IMO’s
published IBC Code contains MEPC.1/Circ.512. However, the guideline is not
sufficient for all information on the Assessment and transportation of hazardous liquid
substances in bulk.
Considering that provisional assessment should review the criteria for assigning
carriage requirements in Chapter 21 of the IBC Code and most products are subject
to Chapter 17 of the IBC Code; therefore, referencing all sources of relevant
guidelines in the IBC Code would be beneficial for the industry.
The procedures and information in the guidelines are mainly focused on the
administrative aspect rather than the industry. For example, the industry should
53
supply the pollution and safety data to the Administration for the provisional
assessment. However, there is no specific guideline for how the industry achieves the
necessary data for submission and its reporting form. In addition, the manufacturer
should submit GESAMP/EHS data necessary for a formal hazard Assessment.
However, the guidelines only reference GESAMP Reports and Studies No. 64.
6.1.3 Lack of experts to deal with
Assessment of chemical hazards and assignment of carriage requirements are highly
technical. Therefore, in order to achieve full compliance for the entry into the IBC
Code, it requires chemical experts, the shipping industry and Administrations who
are well aware of all the IMO regulatory instruments concerning MARPOL Annex II,
IBC Code and their relevant guidelines.
However, lack of information may result in a lack of expertise. Consequently, only
those who have attended IMO’s ESPH Working Group meetings or have similar
experiences can properly deal with these complex procedures and instruments.
Therefore, looking for an expert might be another burden for the industry.
6.1.4 The time allotted for acquiring the documents for Assessment
Numerous instruments and circulars are required to complete the Assessment process.
Chemical manufacturers are not intimately familiar with the shipping industry. They
may not have IMO publications such as MARPOL and IBC Code. In addition, they
have difficulties finding the sources of necessary guidelines for the chemical
Assessment and transportation.
Even when the chemical industry contacts an expert in the Administration and has
sufficient information concerning the Assessment, the industry should also locate and
study all these technical instruments. Therefore, the time for seeking these
documents takes a lot of efforts, which cost valuable money and resources.
54
6.1.5 Difficulty in Member State implementation
The complexity and frequent update of newly transported product information and
the revision of guidelines make it difficult for Member State implementation,
adopting these non-mandatory IMO instrument into their national legal framework or
guidance. Therefore, as reviewed in Chapter 5 of this dissertation, most countries
reference the IMO instruments directly or indirectly within national regulations.
Furthermore, in order to Help the industry, the Administration should keep track of
all international criteria for Assessment and test facilities. However, the scattered
sources of information might require extra workload on the Administration which
decreases ability for consultation on the matter.
6.2 Possible solutions to the current system
6.2.1 Sufficient references of guidance on the Convention and Code
First, Appendix 1 of Annex II to MARPOL should reference MEPC.1/Circ.512
instead of MEPC/Circ.265, because MEPC/Circ.265 is not used any more. In
addition, MEPC/Circ.265 does not reference the revised MEPC.1/Circ.512, which
provides step-by-step procedures for Assessment of new chemicals including most
relevant guidance and criteria. Therefore, the industry has difficulties locating the
revised new guidelines without any further information.
Therefore, the current reference; “Reference is made to the Guidelines for
provisional assessment of chemicals, MEPC/Circ.265 as amended” in Appendix 1 of
Annex II to MARPOL should be amended as “Reference is made to the revised
Guidelines for the Provisional assessment of liquid substances transported in bulk,
MEPC.1/Circ.512 as amend, and the present circular supersedes MEPC/Circ.265”.
Second, there should be made a new Appendix to the IBC Code which contains
necessary sources of documents and information, including the locations of their
55
sources. For example, the IMSBC Code Section 13 has a reference list to the IMO
instruments relevant to the requirements to the Code. Furthermore, Appendix 2 of the
Code has laboratory test procedures, associated apparatus and standards.
Therefore, a possible new Appendix to the IBC Code which references necessary
IMO/UN instruments for Assessment of chemical hazards, and their locations and
subject is suggested in Table 22. This Appendix will be beneficial for IMO Member
States and their chemical and shipping industry.
Table 22 -A possible new Appendix to the IBC Code

Reference to
IMO/UN
instruments
Reference to
subsection
Subject
Report of the
GESAMP/EHS
Working Group
GESAMP
Hazard Profiles
– Chemical hazard rating information
for pollution categorization of NLS
※ Issued annually as
BLG.1/Circulars
GESAMP Report
and Study No. 64
4.1.1:
Sub-column A1
– GESAMP hazard profile rating
scheme for bioaccumulation (A1)
– Guidance on the required quality
standards of test reports for A1
– Guidance for experimentally
measuring and calculating the log Pow
– Guidance for measuring
bioconcentration in fish
4.1.2:
Sub-column A2
– Rating scheme for ready
biodegradability (A2)
– Guidance for measuring ready
biodegradability
56
Reference to
IMO/UN
instruments
Reference to
subsection
Subject
4.2.1:
Sub-column B1
– GESAMP rating scheme for acute
toxicity(B1)
– Guidance for measuring acute aquatic
toxicity
4.2.2:
Sub-column B2
– Ratings information for chronic
aquatic toxicity (B2)
– Guidance for measuring chronic
aquatic toxicity
4.4.3:
Sub-column D3
– Ratings information for long-term
health effects(D3)
4.5.2:
Sub-column E2
– GESAMP hazard profile ratings for
determining potential effects on
wildlife and benthic habitats (E2)

Reference to
IMO/UN
instruments
Reference to
subsection
Subject
GHS Chapter 3.1 Ratings and test information for acute
mammalian toxicity
– Oral toxicity (LD5081)
– Dermal toxicity (LD50)
– Inhalations toxicity(LC5082)
Chapter 3.5
Chapter 3.6,
Chapter 3.7
Rating information for toxic to
mammals by prolonged exposure
– C, M, R, N, and I83

81 LD50, lethal dose to 50% of the exposed population
82 LC50, lethal Concentration to 50% of the exposed population
83 Stand for Carcinogen, Mutagen, Reprotoxic, Neurotoxic and Immunotoxic
57
Reference to
IMO/UN
instruments
Reference to
subsection
Subject
Laboratory test guidance
Chapter 3.2 – Test procedure and rating scheme
information for skin
sensitization/corrosive
Chapter 3.3 – Test procedure and rating scheme
information for respiratory
sensitization
Chapter 2.12 – Definition and criteria information for
water reactive substance

Reference to
IMO/UN
instruments
Reference to
subsection
Subject
IBC Code Chapter.17 – Products lists subject to IBC Code
Chapter.18 – Products lists not subject to IBC Code
Chapter.19 – Index of products carried by bulk with
synonyms for products listed in IBC
Code
Chapter.21 – See the references relating to the
Chapter 21 of IBC Code
※ See “B: References relating to the
Chapter 21 of IBC Code” of this
Table in detail references
MEPC.2/Circular Annex 1 to 5 – Provisionally assessed products lists
Annex 6 – Information for synonyms for
vegetable oils
Annex 7 – Country abbreviations information
58
Reference to
IMO/UN
instruments
Reference to
subsection
Subject
Annex 8 – Tripartite contact addresses
information
Annex 9 – Information for manufacturers
authorized to conduct pollutant-only
assessments by calculation
Annex 10 – Information for cleaning additives
BLG.1/Circ.27 IMO website – Tripartite Agreement information on
IMO website(Marine Environment/
Carriage of Chemicals/Tripartite
Agreements)
The Report of the
GESAMP/EHS
Working Group
Annex 7
(GESAMP/EHS
Composite List)
– Information for the
product/components which already
assessed by GESAMP/EHS
MARPOL 73/78 Appendix 1 of
Annex II
– Information for provisional
assessment for a new product’s
pollution category
※ See “A: References relating to the
Appendix 1 of Annex II to the
MARPOL” of this Table in detail
references)
GESAMP Report
and Study No. 64
Annex VII – Information for submitting data
GESAMP/EHS for a formal hazard
Assessment
– GESAMP Product Data Reporting
Form
BLG.1/Circ.28 – – The introduction of in charges for
product Assessment work undertaken
59
Reference to
IMO/UN
instruments
Reference to
subsection
Subject
by GESAMP/EHS
BLG Product Data
Reporting Form
– – The form should be used for
submission of proposed carriage
requirement of chemical to IMO’ BLG
to be included in the IBC Code.
BLG.1/Circ.33 – – Information for interpretation of the
ratings of GESAMP Hazard Profiles
Source: Developed by Author
6.2.2 Establishment of the integrated electronic version of guidelines
Internet is a great tool today. Using advanced technology supports the IMO’s
environmentally-friendly policy. It can decrease the time spent looking for complex
documents and to make separate puzzle pieces into a comprehensive box format, just
clicking the name of the relevant documents and check or achieve the necessary
information which is supplied by linkages to the electronic documents, especially if
the complex cross checking is required to complete processes.
Electronic versions of the guidelines can be a great benefit for the industry and the
Administration. It can integrate complex relevant information on IMO’s public
website. Table 23 shows the advantages and disadvantages of electronic guidelines.
Table 23 -The advantages and disadvantages of electronic guidelines
Advantage Disadvantage
– Not require to collect all instruments
– Save time to locate information
– Effective guidance
– Easy to check cross linkage for
necessary data
– IMO should maintain the system
– Must keep in update of amendments
60
– User-friendly tool
– Environmentally-friendly tool
Source: Author
Therefore, IMO should consider development of electronic guidelines. It can be
developed by the IMO or respective Administrations supported by very simple
techniques and can be a very effective, user-friendly tool for the industry. The ESPH
Working Group can review the detailed technical documents that are required and
basic concepts of systems for electronic linkages and its function. MEPC.1/Circ.512
can be a main source to achieve and link all the necessary sources as shown in Figure
19, as an example of document linkages.
Figure 19 -Example of documents linkages
Source: Drawn by Author
MEPC.1/Circ.512
ANNEX
Page 2
Section 2: ASSESSED PRODUCTS
2.1 If a liquid substance is to be shipped as a product, the shipper should
first check whether the product is listed in chapter 17 or 18 of the IBC Code,
or in chapter 19 (Index of Products Carried in Bulk) or in the latest edition of
MEPC.2/Circular
2.2 A product must be shipped under the product name listed in chapter 17
or 18 of the IBC Code or in the latest edition of MEPC.2/Circular
MEPC.2/Circ.
NLS List 1
NLS List 2
NLS List 3
NLS List 4
IBC Code
Chapter 17
Chapter 18
Chapter 19
List 1: Pure or…
61
Figure 20 shows the concept of document linkages in electronic version. The basic
functions may include as follows:
All forms must be provided with an example for respective guidance.
All product lists must be provided with necessary links and search functions
for the product list in the IBC Code, its Index, and MEPC.2/Circular. Lists
must be updated by IMO.
The latest version of the GESAMP Composite Hazard profiles must link to
the product list if possible.
Pollution categorization criteria must link to the test standards in the
GESAMP Studies and Reporter No. 64.
IBC Code Chapter 21 must link to the laboratory test criteria in the GHS if
possible.
62
Figure 20- The concept of documents linkage for electronic version of guideline
Source: Drawn by Author
6.2.3 Development of an integrated single combined guideline
Development of an integrated single guideline by combining all guidelines and
circulars under MARPOL Annex II and IBC Code which is related to the Assessment
of products except periodical circulars could be a viable solution to the complexity.
MEPC.1/Circ.512
Documents for the
identification of
the chemical
– MEPC.2/Circ.
– IBC Code (Ch.17, 18
& 19)
– IMO Tripartite
information
–
Documents for
Tripartite
Agreement
– Composite list of
hazard profiles
– MARPOL 73/78,
Annex II, appendix 1
– Chapter 21 of the
IBC Code
–
Documents for
Assessment by
GESAMP/EHS
– BLG.1/Circ.28
– GESAMP/EHS
Product Data
Reporting Form
– GESAMP Report and
Studies No. 64
Document forms
with a sample
– All necessary forms
must be included
Documents for
Assign carriage
requirements
– MARPOL 73/78,
Annex II, appendix 1
– Chapter 21 of the
IBC Code
– BLG.1/Circ.33
– BLG Product Data
Reporting Form
Documents for
Provisional
assessment
– Tripartite Agreement
Documents form
– Government contact
point
63
According to the statistical data in Chapter 4.1.2 of this dissertation, most products
listed in the IBC are subject to both the IBC Code and Annex II to MARPOL.
Therefore, integration of the separate guidelines; Appendix 1 of Annex II to MARPOL
and Chapter 21 of the IBC Code, should be taken into account for a possible long
term solution. Furthermore, the single guideline can be attached to the IMO’s
published version of the IBC Code as a new Supplement to the IBC Code.

64
CHAPTER 7
CONCLUSION AND RECOMMENDATIONS
The transportation of petroleum products account for 11.7% of world seaborne trade
and the transportation volume has been increasing every year, not to mention new
bulk chemicals that are continuously transported by sea. 98% of these products are
hazardous substances to human beings and/or the environment, because most of
these chemicals have hazardous properties. This dissertation found that 748 products
are listed in the IBC Code and 45.7% of these products have safety and pollutions
hazard together, 53.88% have only pollution hazards and less than 0.5% have safety
hazards. Pollution category Y accounts for about 63.9 % of all products followed by
Z (22.5%) and X (11.9%). Only 1.7% (13 substances) does not have safety or
pollution hazards.
IMO has developed various international regulatory instruments to protect crew and
the marine environment from these harmful substances. The SOLAS, Chapter VII
regulates carriage of dangerous chemicals, MARPOL Annex II regulates carriage of
NLS in bulk, and Annex III regulates marine pollutants in packaged form. In addition,
there are various technical Codes such as the IMDG Code, the IMSBC Code, the
IBC Code, the IGC Code and the INF Code and all these Codes apply to different
forms of products transported by sea.
Liquid bulk substances are regulated by MARPOL Annex II and Part B of the
Chapter VII in the SOLAS. SOLAS regulates safety aspects of chemicals and
MARPOL regulates marine pollution aspects. The IBC Code provides specific
technical requirements under both Conventions. Products listed in Chapter 17 of the
IBC Code are under SOLAS and all X, Y and Z category substances are regulated by
MARPOL Annex II.
65
Sea transportation of a new product requires Assessment of the hazards and minimum
carriage requirements before it is carried by ships. Appendix 1 of Annex II to
MARPOL has the pollution category Assessment criteria based on the GESAMP
Hazard Profiles. Chapter 21 of the IBC Code has guidelines for the criteria for
assigning carriage requirements based on the GHS standards. In addition, there are
many international non-mandatory instruments concerning Assessment of safety and
pollution hazards of chemicals as follows but not exclusive.
MEPC.1/Circ.512 contains various information concerning the Assessment
and procedures for ascertaining the carriage requirements.
MEPC.2/Circular provides lists of NLS information to support the reporting
of Tripartite Agreements.
The GESAMP Report and Study No.64 is closely linked to the Appendix 1
of the MARPOL Annex II and contains hazard Assessments rational,
procedures and laboratory test information.
The Report of the GESAMP/EHS Working Group has the composite list for
the industry to find chemical hazard Assessment data.
BLG.1/Circ.33 contains decisions on the interpretation of the ratings of
GESAMP Hazard Profiles and categorization and classification of new
products.
GHS provides criteria and laboratory test information for the Chapter 21 of
the IBC Code
The amendments to those IMO instruments and Assessment of hazardous substances
have been a main agenda item of the BLG. In addition, the ESPH technical working
group deals with Assessment of chemicals and assignment of carriage requirements of
the substances. The GESAMP/EHS develops a GESAMP Hazard profile based on
the chemical data and considers various matters relating to the Assessment of
substances under MARPOL Annex II.
66
The complexity and frequent updates of newly transported product information and
the revision of guidelines make it difficult for Member States to adopt these nonmandatory instruments into their national framework. Therefore, IMO’s regulatory
instruments are significantly important as central sources of information for chemical
and shipping industries.
However, MARPOL Annex II and the IBC do not contain sufficient information on
the guidelines. Consequently, the industry should find and study all these necessary
sources. Locating these documents may take significant time and effort. In addition,
these documents are highly technical and complex, which requires several experts.
Therefore, looking for experts might be another monetary burden for the industry.
In conclusion, this dissertation found possible solutions to the benefit of the industry
and Member States. Therefore, based on these solutions in Chapter 6, the author
recommends that:
Appendix 1 of Annex II to MARPOL should reference MEPC.1/Circ.512
instead of MEPC/Circ.265.
A separate new Appendix should be made to the IBC Code which references
necessary IMO/UN instruments for Assessment of safety and pollution
hazards of chemicals, and their locations and subject.
IMO should take into consideration developing an electronic version of the
guidelines and put it in the IMO’s public website to give benefits for the
chemical and shipping industry and the Member States.
Integration of the all separate guidelines under both MARPOL Annex II and
the IBC Code as a single guideline should be taken into account for a long
term solution, including all relevant laboratory test guidance referenced in
those IMO/UN instruments.
67
Furthermore, development of electronic version of guidelines for other complex IMO
non-mandatory instruments should be taken into account in the future to benefit all
maritime stakeholders.

68
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73
Appendix A
74
Appendix B
75

76
Appendix C
77
Source: Appendix 1 of the Annex II to the MARPOL
78
Appendix D
Source: Chapter 21 of the IBC Code (IMO)

79
Appendix E
Guidance for the provisional assessment of pure or technically pure products in
Section 4 of the MEPC.1/Circ.512
80
81 Source: Scheme 2 of Appendix 1 to MEPC.1/Circ.512 (2006 May 16),

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