Letter

Dear Sir

I write in response to the article ‘The Right Conditions’ in the December 2011 edition of Hazardous Cargo Bulletin, which reported on the meeting of the Intertanko Chemical Tanker Sub-Committee.

The article attempts to cover in some detail the meeting of our sub-committee but unfortunately contains a number of inaccuracies that should be pointed out by you for the benefit of your readership and any Intertanko members who may have been misled.

Your statement that the IMO’s adoption of a lower limit of 8,000 dwt as a cut-off for equipping smaller tankers with inert gas equipment is lower than what Intertanko had lobbied for is simply incorrect. You have also incorrectly stated that Intertanko has lobbied for the IG regulations to “apply to all tankers subject to SOLAS (i.e. all those of 500gt or more)”.

It should also be pointed out that while the IMO’s adoption of a lower limit of 8,000 dwt may not have been in line with the Intertanko position on the application of inert gas, we are aligned with the IMO approach that this discussion is pertinent only to new tankers and does not include existing ships.

Intertanko has long campaigned for a consistent application of the inert gas regulations on the principle that inert gas should be applied on the basis of a product-based approach; we believe that inert gas should be applied to those products (oil or chemical) with a flash point of less than 60°C. In line with this principle we have maintained that all new tankers (irrespective of ship size, ship type or cargo tank size) subject to SOLAS should be equipped with inert gas systems. This may not necessarily be the position adopted by other industry organisations that you have made reference to in the article.

The full Intertanko position on inert gas is as follows:

• Intertanko believes the inert gas regulations should be consistent.
• Intertanko supports the principle of installing all new SOLAS tankers with inert gas systems (IG/IGG/N2 as appropriate), irrespective of ship size, ship type or cargo tank size. 
• Intertanko supports the logic that the use of inert gas on new tankers should be a product-based approach. (i.e. the inert gas requirement, IG/IGG/N2 as appropriate, should apply to the annex 1 or annex II products with a flash point less than 60°C).
• Intertanko recognises the importance of the human element aspects and supports the continuation of further studies and training to address these aspects. 
• Intertanko suports the future consideration of inert gas requirements to existing ships, including those which are currently not required to have an inert gas system under SOLAS, in a manner similar to the above use of inert gas on new tankers, (i.e. product-based approach).

Yours Sincerely

Ajay Gour

Senior Manager – Chemicals & Vetting

Intertanko