Web alert: IMO SOLAS Chapter VI - Carriage of Cargoes - Regulation 5.2 - Bulk liquid blending

1 January 2014 saw the entry into force of a number of amendments to SOLAS. Amongst these amendments, the changes to SOLAS Chapter VI – Carriage of cargoes, Regulation 5.2 have a particular significance for the conduct of cargo operations onboard tankers.  Regulation 5.2 now prohibits the practice of physical blending of bulk liquid cargoes during sea voyages.

Definitions

For the purposes of the SOLAS amendments, physical blending operations have been 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 cargo with a new product designation’.

The regulation goes on to state that ‘any production process on board a ship during sea voyages is prohibited’ whilst defining a production process as ‘any deliberate operation whereby a chemical reaction between a ship’s cargo and any other substance or cargo takes place’.

It should be noted, however, that this regulation ‘does not preclude the master from undertaking cargo transfers for the safety of the ship or protection of the marine environment’, nor does it apply to the ‘blending of products for use in the search and exploitation of seabed mineral resources on board ships used to facilitate such operations’.

Sea voyage

SOLAS does not define the meaning of ‘sea voyage’ and this ambiguity has led to a number of enquiries from members.  Whilst we are seeking advice from our industry partners on the matter, the intention of the regulation would appear to prohibit the physical blending of bulk liquid cargoes using the ship’s cargo pumps and pipelines outside port limits, whether at anchor or not.

If a member intends to undertake physical blending operations within port limits, whether at anchor or moored, authorisation should first be sought from the local port state administration.

Whether blending is permitted if a ship is at anchor outside port limits is still open for discussion, depending on the interpretation of ‘sea voyage’.  We will revert on this once we have received further information.

Members' ships should endeavour to maintain close contact with local Port State authorities in order to ensure that the local interpretations of regulation 5.2 are understood and complied with. 

The regulation does not apply where cargo is recirculated within a ship's cargo tank or through an external heat exchanger during the voyage for the purpose of maintaining cargo homogeneity or temperature control.  This includes when two or more different products have previously been loaded into the same cargo tank within port limits.