MARPOL / SOLAS update: Prohibition on blending of bulk liquid cargoes

Cargo

Published: 6 January 2014

Members are advised that as of 1 January 2014, the further SOLAS regulations VI/5-2 will have come into force. It can be found under Chapter VI "Carriage of Cargoes", Part A General Provisions, and is added after the previous regulation 5-1.

This new regulatory provision provides that:

  1. "The physical blending of bulk liquid cargoes during a sea voyage is prohibited"
     
    This is further defined as the "process whereby the ship's cargo pumps and pipelines are used to internally circulate two or more different cargoes with the intent to achieve a new product designation".
    The exception is that a Master will not be prohibited from making cargo transfers where either the safety of the vessel or the marine environment are concerned.
    The prohibition does not apply to blending of products used in the search and exploration of seabed mineral resources on board such specialist vessels.
     
  2. "Any production process on board a ship during a sea voyage is prohibited"
     
    This is defined as "any deliberate operation whereby a chemical reaction between a ship's cargo and any other substance or cargo takes place".
    This prohibition does not apply to the production processes of cargoes used in the search and exploration of seabed mineral resources on board such specialist vessels.

Members active in the bulk liquid cargo trade should take due note, in particular where the trade may involve requests from Charterers / Shippers other cargo interests for the blending of cargoes on board vessels.

It would be prudent to review any existing charter arrangements and terms which may make express reference to such operations and to ensure future fixture terms are suitably amended to take account of these new SOLAS regulations.

If Members are uncertain as to whether a proposed activity falls within the scope of these regulations they should contact their Class and Flag for appropriate guidance.