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Report of the IMO Working Group

on Evaluation of Safety and
Pollution Hazards (ESPH 21),
October 26-30, 2015

Prepared by:
Capt. Soren C. Ibsen
V.P. Milbros Systems
Q88 LLC
 October 30, 2015
Meeting: ESPH 21
Location: IMO Headquarters, London
ESPH Chairman: Mr. D. MacRae (United Kingdom)
ESPH Secretary: Ms. Patricia Charlebois (IMO)

Attending Delegations to the ESPH Working Group:

Member Governments: Australia, Belgium, Canada, China, Finland, France, Germany, Japan, Malaysia, Marshall Islands,
Netherlands, Norway, Republic of Korea, Russian Federation, Spain, South Africa, Sweden, United Kingdom, United
States

NGOs: International Association of Classification Societies (IACS), International Assoc. of Independent Tanker Owners
(INTERTANKO), Dangerous Goods Advisory Council (DGAC), Oil Companies International Marine Forum (OCIMF),
International Parcel Tankers Assoc. (IPTA), European Chemical Industry Council (CEFIC)

1. Adoption of agenda
The agenda was adopted as printed, except taken in slightly different order.

2. Outcome of other bodies

Dr. Thomas Höfer, Chairman GESAMP/EHS reviewed the latest meeting of GESAMP and the meeting report PPR.1/Circ.2.

GESAMP prepared hazard profiles for 5 new products and did a review of 21 existing products.
Refer to PPR.1/Circ.2 for details. This document is available in the Milbros System Library.

Next GESAMP Meeting has been scheduled for 23-27 May 2016, and submission deadline will be about 6 weeks prior to
the meeting.

Back at ESPH 20 the group agreed on a model Certificate of Protection for products requiring oxygen dependent
inhibitors. The action item to issue a MSC-MEPC Circular with this model certificate was missed at PPR 2. This item will
be brought back to PPR 3 for approval.

3. Evaluation of products

The following new products were evaluated by the group for inclusion in List 1 of MEPC.2/Circ. and will be included in
the revision of Chapter 17 of the IBC Code scheduled for 2020.

List 1 Entry – 1-Dodecene

Submitted by United States ESPH 21/3/7
All Countries, No Expiry Pollution Category Y, Ship Type 2
Approved with a minor revisions to the paper.
The Product Name Dodecene (all isomers) which is currently in Chapter 17 of the IBC Code as Pollution Category X, Ship
Type 2 will remain in Chapter 17 for all other isomers of Dodecene.

List 1 Entry – Cyclohexane-1,2-dicarboxylic acid, diisononyl ester

Submitted by Germany ESPH 21/3/18
Changes existing Tripartite agreement to All Countries, No Expiry
Pollution Category Y, Ship Type 2
Approved with a minor revision to the paper.
Page 2
List 1 Entry – Urea Ammonium nitrate solution
Submitted by Norway ESPH 21/3/16
This paper was submitted to remove confusion about two similar entries in Chapter 17
It was decided to remove entry Urea/Ammonium nitrate solution (containing less than 1% free ammonia) from Chapter
17. Entry Urea Ammonium nitrate solution will remain, but will have amended carriage requirements.
Pollution Category will change from Cat. Z to Cat. Y
Based on past interpretations this change will only take effect with the next update of Chapter 17 of the IBC Code which
is expected to take place in 2020.

List 1 Entry – Renewable hydrocarbons of wood origin

Submitted by Finland ESPH 21/3/13
This paper was submitted in order to add the two recent Renewable hydrocarbons tripartite agreements to the Bio-Fuel
Annex 11 in the MEPC.2/Circ.
It was decided that the Tripartite names will change as follows:

Renewable hydrocarbons of wood origin (diesel type fraction) will be renamed to

Alkanes (C9-C24) linear, branched and cyclic
Pollution Category Y, Ship Type 2
Note: There will be two entries for this product name. One with a flashpoint ≤60°C and another with a flashpoint of
>60°C

Renewable hydrocarbons of wood origin (naphtha type fraction) will be renamed to

Alkanes (C4-C12) linear, branched and cyclic
Pollution Category X, Ship Type 2

Mixtures of these products with Diesel/Gasoil and Gasoline will also be added to List 1 as tripartite agreements.
Pollution Category X, Ship Type 2

These will all be listed in MEPC.2/Circ.21 when published in December.

List 1 Entry – Used Cooking Oil (Triglycerides, C16-C18 and C18 unsaturated) (m)
Submitted by Belgium ESPH 21/3/14

At PPR 2 it was agreed to add entry Used Cooking Oil (m) to List 1 of the MEPC.2/Circ. as Pollution Cat. X, Ship Type 2.
After this classification data was submitted to GESAMP for Used Cooking Oil used for the production of bio-fuels.
GESAMP has evaluated this product and has produced a hazard profile for the product.

ESPH evaluated this new hazard profile and a new entry to List 1 of the MEPC.2/Circ. will be added:
Used Cooking Oil (Triglycerides, C16-C18 and C18 unsaturated) (m)
All Countries, No Expiry Pollution Category Y, Ship Type 2

ESPH also decided to retain the existing Used Cooking Oil (m) Pollution Cat. X, Ship Type 2 in List 1

To use the new Used Cooking Oil, Triglycerides, C16-C18 and C18 unsaturated (m) entry the shippers will need to
provide confirmation that the composition of the particular cargo contains this triglycerides description and will need to
use the proper Product Name on the shipping documents to describe the cargo. Otherwise the generic Used Cooking Oil
entry will need to be used and the product will be a Pollution Cat. X, Ship Type 2.
Addendums to ships Certificate of Fitness will be needed for carriage of cargo under this new List 1 entry.
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The following papers regarding new or amended List 3 entries were reviewed.
Confidential Mixture information was only shared with member states during the evaluation and collected after the
discussion is complete. Non-Member states attendees were able to stay in the room to hear the discussions, but the
confidential formulations were only shared with member states.

List 3 Entry – Gyptron SD250

Submitted by Norway ESPH 21/3
This existing List 3 entry, was evaluated by the group and confirmed it should move to List 2 as submitted.
Gyptron SD250 n.o.s. 9 (contains Potassium carbonate solution) Pollution Category Z, Ship Type 3

List 3 Entry – 10% Scaletreat 8199C in 6% NaCl

Submitted by Norway ESPH 21/3/1
Updated List 3 entry, Approved as with minor changes to the paper.
All Countries, No Expiry Pollution Category Z, Ship Type 3

List 3 Entry – 30-50% Scaletreat SD 12154 in 3% KCl

Submitted by Norway ESPH 21/3/2
New List 3 entry, Approved as submitted
All Countries, No Expiry Category Z, Ship Type 3
This new entry will replace the two existing tripartite agreements in List 1
30% Scaletreat SD 12154 in 3% KCl
50% Scaletreat SD 12154 in 3% KCl

List 3 Entry – SOLVETREAT 12093

Submitted by Norway ESPH 21/3/3
Updated List 3 entry, Approved as submitted.
All Countries, No Expiry Pollution Category Z, Ship Type 3

List 3 Entry – Crosslinker TB-41

Submitted by Norway ESPH 21/3/4
Updated List 3 entry, Approved as with minor changes to the paper.
All Countries, No Expiry Pollution Category Y, Ship Type 3

List 3 Entry – Gyptron SD250 in KCl Solution

Submitted by Norway ESPH 21/3/5
This existing List 3 entry, was evaluated by the group and confirmed it should move to List 2 as submitted.
Gyptron SD250 n.o.s. 9 (contains Potassium carbonate solution) Pollution Category Z, Ship Type 3

List 3 Entry – Secure SC2020

Submitted by Norway ESPH 21/3/6
Updated List 3 entry, Approved as submitted.
All Countries, No Expiry Pollution Category Z, Ship Type 2

List 3 Entry – AP 13246

Submitted by the United States ESPH 21/3/8/Rev.1
Updated List 3 entry, Approved as with minor changes to the paper.
All Countries, No Expiry Pollution Category Y, Ship Type 2

Page 4
List 3 Entry – Lubrizol 16005
Submitted by the United States ESPH 21/3/9
Updated List 3 entry, Approved as with minor changes to the paper.
All Countries, No Expiry Pollution Category Y, Ship Type 2

List 3 Entry – Lubrizol CV2301

Submitted by the United States ESPH 21/3/10
Updated List 3 entry, Approved as with minor changes to the paper.
All Countries, No Expiry Pollution Category Y, Ship Type 2

List 3 Entry – Lubrizol CV6503

Submitted by the United States ESPH 21/3/11
Updated List 3 entry, Approved as with minor changes to the paper.
All Countries, No Expiry Pollution Category Y, Ship Type 2

List 3 Entry – Lubrizol CV7050

Submitted by the United States ESPH 21/3/12
Updated List 3 entry, Approved as with minor changes to the paper.
All Countries, No Expiry Pollution Category Y, Ship Type 2

List 3 Entry – Precut

Submitted by South Africa ESPH 21/3/15
After discussion by the group is was determined that this trade name can be carried as existing Product Name:
Ethyl Alcohol

List 3 Entry – Secure SD-4127

Submitted by Norway ESPH 21/3/17
Updated List 3 entry, Approved as submitted.
All Countries, No Expiry Pollution Category Y, Ship Type 3

There was a remark by Germany/GESAMP Chairman that for many Lube Oil Additives evaluated under List 3 could be
covered under a number of generic entries if they were to be developed.

4. Evaluation of cleaning additives

35 cleaning additives were presented to the group for evaluation.
27 cleaning additives met the criteria outlined in MEPC.1/Circ.590.
These additional cleaning chemicals can be used starting immediately.
5 cleaning chemicals are being removed from the list.
15 cleaning chemicals had the manufacturer name revised.
A list of these new cleaning chemicals and revisions can be found on the last page of this report.

Page 5
5. Review of MEPC.2/Circular - Provisional classification of liquid substances transported in bulk and other related
matters

List of Proposed Changes to MEPC.2/Circ. 20

The group undertook a review of a draft version of MEPC.2/Circ.21 which will be published 1 December 2015.
The following products currently listed as tripartite agreements in MEPC.2/Circ.20 will be removed from the list as their
expiry date has been reached and no submissions have been made for review and to make these permanent entries.
These cargoes will not be able to be carried after 31 December 2015.

List 1

• Methyl Cyclopentane (KOR)

• Parachlorobenzotrifluoride (USA)
• Salt of polyamino carboxylic acid (70% or less) in KCL Brine Solution(4% or less) (GBR)

List 3

• C5 Raffinate (BRA)
• EC1602A (GBR)
• Octimise G10 (BEL)
• Propanol 98 (USA)
• SAFETHERM EG (GBR)

List 4

• MCP Solvent

While adding these cargoes back to the list is not possible without a paper being submitted to PPR-2 or ESPH-21, should
any of these cargoes being removed cause an issue for you, please advise so we can follow up with the proper authority
to urge them to submit a paper on the products.

It was also noted that the following numbers of cargoes in the MEPC.2/Circ. will expire on 31 December 2016

List 1 – 2 cargoes
List 3 – 24 cargoes
List 4 – 3 cargoes

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6. Revision of IBC Code – Chapters 17, 18 and 21

Work continued on the revisions of Chapter 21. The intention is to have a full list of expected changes of carriage
requirements under Chapter 17 for review at PPR 3 in February 2016. The group will need to review all the changes
include the Toxic ratings to determine the impacts of the Chapter 21 revisions. Estimated time frame for a new Chapter
17 to come into effect is 1 January 2020.

7. Revision of MEPC.1/Circ.512 – Guidelines for the provisional assessment of liquid substances transported in bulk

Work continued on the revisions to MEPC.1/Circ.512. Some progress was made. Work on this agenda item will
continue at PPR 3.

8. Development of minimum carriage requirements for contaminated bulk liquids carried in OSVs

No papers were submitted to ESPH 21 on this agenda item, so no work was done on this agenda item. Interested parties
are urged to submit papers to PPR 3.

Page 7
CARGO TANK CLEANING ADDITIVES EVALUATED AND FOUND TO MEET THE REQUIREMENTS OF REGULATION 13.5.2
OF ANNEX II OF MARPOL

Name of cleaning additive Name of manufacturer Reporting Country

ROX®CARE AC80SL ALKALI TANK & CALLINGTON HAVEN PTY LTD AUS
PIPE CLEANER
ROX®CARE MC2600 TANK CALLINGTON HAVEN PTY LTD AUS
CLEANER
ALCLEAN G&E Bridge Ltd. KOR
ALCLEAN SAFE G&E Bridge Ltd. KOR
ALCLEAN HD G&E Bridge Ltd. KOR
TC-HD G&E Bridge Ltd. KOR
TC-PCT G&E Bridge Ltd. KOR
TC-NEUTRAL G&E Bridge Ltd. KOR
CareClean Citric Acid Marine Care B.V. NLD
CareClean CR Marine Care B.V. NLD
ECOSOLUT 14 OTI-Greentech AG DEU
ECOSOLUT 24 OTI-Greentech AG DEU
EC-Alkaclean HD / PC Cleaner EFLOCHEM Chemicals Blending LLC NLD
EC-Alkaclean Safety EFLOCHEM Chemicals Blending LLC NLD
EC-Bufferclean 5.5 EFLOCHEM Chemicals Blending LLC NLD
EC-Coal Tar Cleaner EFLOCHEM Chemicals Blending LLC NLD
EC-Coldwash HD EFLOCHEM Chemicals Blending LLC NLD
EC-Ecoclean EFLOCHEM Chemicals Blending LLC NLD
EC-Genepol EFLOCHEM Chemicals Blending LLC NLD
EC-Seaclean EFLOCHEM Chemicals Blending LLC NLD
EC-Ciean Break EFLOCHEM Chemicals Blending LLC NLD
EC-Uniclean GP EFLOCHEM Chemicals Blending LLC NLD
EC-Uniclean HCF Eco EFLOCHEM Chemicals Blending LLC NLD
EC-Resin Remover EFLOCHEM Chemicals Blending LLC NLD
EC-Rust Remover EFLOCHEM Chemicals Blending LLC NLD
EC-Uniclean Steam Cleaner EFLOCHEM Chemicals Blending LLC NLD
EC-Uniclean Tank I Separating EFLOCHEM Chemicals Blending LLC NLD
The Manufacturer names of the below cleaning chemicals will change from Unimarine International BV –
Eflochem to UNIMARINE INTERNATIONAL BV
Alkaclean HD / PC Cleaner UNIMARINE INTERNATIONAL BV NLD
Alkaclean Safety UNIMARINE INTERNATIONAL BV NLD
Bufferc lean 5.5 UNIMARINE INTERNATIONAL BV NLD
Coal Tar Cleaner UNIMARINE INTERNATIONAL BV NLD
Coldwash HD UNIMARINE INTERNATIONAL BV NLD
Ecoclean UNIMARINE INTERNATIONAL BV NLD
Genepol UNIMARINE INTERNATIONAL BV NLD
Seaclean UNIMARINE INTERNATIONAL BV NLD
Uniclean Break UNIMARINE INTERNATIONAL BV NLD
Uniclean GP Extra UNIMARINE INTERNATIONAL BV NLD
Uniclean HCF Eco UNIMARINE INTERNATIONAL BV NLD
Uniclean Resin Remover UNIMARINE INTERNATIONAL BV NLD
Uniclean Rust Remover UNIMARINE INTERNATIONAL BV NLD
Uniclean Steam Cleaner UNIMARINE INTERNATIONAL BV NLD
Uniclean Tank I Separating UNIMARINE INTERNATIONAL BV NLD

Page 8
Cleaning Products that shall be deleted from annex 10 of the MEPC.2/Circular.

Ecosolu 14 Marine OTI-Greentech AG CHE

ECOSOLUT 14 SHD Marine OTI-Greentech AG CHE
ECOSOLUT 14S Marine OTI-Greentech AG CHE
ECOSOLUT 18 Marine OTI-Greentech AG CHE
ECOSOLUT 24 HD Marine OTI-Greentech AG CHE

Page 9