Chemical Tanker Committee

05 October 2007 Our Ref.: HS-22713/1400000

AGENDA

Chemical Tanker Committee Meeting # 31

INTERTANKO 9th Floor, St Clare House 30-33 Minories London EC3N 1DD

Telephone + 44 (0) 207 977 7010

17th October 2007. Start: 09:30 12:30-13:30 Buffet Lunch Complete 16:30-17:00

Agenda for the CTC # 31 Page 1 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith 1. ANTI-TRUST/COMPETITION LAW COMPLIANCE INTERTANKO’s Anti-Trust/Competition law Compliance Statement INTERTANKO’s policy is to be firmly committed to maintaining a fair and competitive environment in the world tanker trade, and to adhering to all applicable laws which regulate INTERTANKO’s and its members’ activities in these markets. These laws include the anti-trust/competition laws which the United States, the European Union and many nations of the world have adopted to preserve the free enterprise system, promote competition and protect the public from monopolistic and other restrictive trade practices. INTERTANKO’s activities will be conducted in compliance with its Anti-trust/Competition Law Guidelines.

2. Minutes from the last meeting The minutes from the last meeting pf the CTC # 30 have been approved by the committee via correspondence, circulated in the weekly news, and circulated as a chemical bulletin and placed on the members area of our web site A copy of the minutes are however attached for reference in Appendix 1 to the agenda.

3. Action Point Status Review The action points arising from the last CTC meeting are consolidated in Appendix 2 to the agenda and the status of the action point indicated.

The committee will be invited to review the action point status

4. Issues, Goals, Objectives (Summary of the CTC main Objectives) The Chairman, in conjunction with the secretary felt that it would be beneficial to the work of the committee to identify the committees issues, goals and objectives, such that this would be become a permanent item on the committees agenda that would be reviewed and updated (as may be necessary and as issues are completed or new issues arise), at each committee meeting. In this regard we have included in Appendix 3, a summary of our main issues, goals and objectives for review and comments by the committee.

5. Minutes from the last CTSCA meeting # 9 The (draft) minutes from the last meeting of the CTSCA # 9 is included in Appendix 4 to the agenda. These are not yet approved by the CTSCA however the CTC is invited to review the minutes and raise any questions or contributions they may have to the work of the CTSCA.

6. Reports from Working Groups 6.1 Best Practice VOC working group (Chairman John Salvesen) The working group held its first meeting in Houston on the 11th September 2007, and reported upon its discussions to the CTSCA #9 which met in Houston on the 12th September 2007. This is recorded in the minutes to CTSCA # 9 included in this agenda in Appendix 4. The working group will be holding its second meeting in London on the 16th October. The group has completed stage 1 of its work, which was the production of best practice guidelines for the prevention of inadvertent release of cargo vapour emissions. Phase 2 has been identified as producing best practice guidelines to reduce cargo vapour emissions during tank cleaning. The group has identified a possible phase 3 to its work and this will be further discussed when it meets, it is hoped that a working document and flow chart will be provided for the CTC to review when it meets.

6.2 INTERTANKO/FOSFA Banned last Cargo working group (Chairman Svend Foyn-Bruun) The 3 field tests undertaken by this working group were formulated into a final report of findings and conclusions which was submitted to the FOSFA working group that has been evaluating this work. A copy of the report is included in Appendix 5. The proposals made in this report have been opposed by IPTA via the Oils & Fats working group of FOSFA where this work is been coordinated. As a result of this, FOSFA have contacted several chemical

Agenda for the CTC # 31 Page 2 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith operators who operate stainless steel chemical tankers and sought their views; if these chemical tanker owners felt that the proposal would be an advantage to the trade. To date only 2 companies have responded to FOSFA, thus it appears that unless more support is forthcoming or that more chemical operators with stainless tonnage believe that this will be an advantage to the trade, it is quite likely this project will be shelved by FOSFA.

The committee is invited to take note and also requested to respond positively to FOSFA if they have been one of the companies contacted by them.

6.3 Cleaning Standard Terminology working group (Chairman Svend Foyn-Bruun) The working group has collected a comprehensive list of the various tank cleanliness standards that abound within the industry by different charterers, including different standards by the same charter for the same product. This information is currently been assimilated into a working spreadsheet for review by the working group with the aim of then consolidating this into different standards for different products. The committee will be kept appraised as work progresses. The committee is invited to take note

7. Accidents 7.1 Inert Gas Issue The INTERTANKO position regarding inert gas is well known and is endorsed by Council, and is listed on our web site at the following link http://www.intertanko.com/templates/intertanko/issue.aspx?id=25993. However, we have also produced an INTERTANKO position paper on the issue which we have shared with our industry colleagues. A copy of this will be handed out for review when we meet.

The committee will be provided with a verbal update on the outcome on this issue from IMO’s Marine Safety Committee.

The committee will also be invited to review and discuss the issue further under the Issue, Goals, Objectives item of this agenda (Agenda Item 4),

7.2 IIG Human Factors Task Group A draft submission has been circulated within the CTC for comments and review with regards to a proposed submission to IMO (STW) proposing stricter requirements for sea staff to obtain their Dangerous Cargo Endorsements (DCE’s) as well as expanding certain elements of the DCE to shore staff. Some comments have been received by the secretariat regarding the proposed increase in sea time requirements of 24 months in the proposal for sea staff. The committee will be invited to discuss and conclude on this proposal when we meet.

7.3 Bottle Neck Group Report (re-review) The committee agreed at its last meeting that it would re-review the last report produced by the INTERTANKO “Bottle neck group” that was submitted to the Inter-Industry group for their consideration. Despite the IIG not supporting any of the comments, suggestions or conclusions raised by INTERTANKO within its report, the CTC, none the less, agreed that it stood by the findings in this report. It was agreed that this would be re-circulated to the committee and that time would be made at CTC meeting #31 to re-assess these comments and evaluate how INTERTANKO may take some of these issues forward independently of the Inter Industry Group. The report has been circulated under separate cover but for good order is also included in this agenda in Appendix 6 to the agenda.

The committee is invited to review the INTERTANKO Bottle neck report and re-assess how these conclusions may be taken forward independently to the Inter Industry Group

Agenda for the CTC # 31 Page 3 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith 8 Line Draining It was agreed that the committee and sub-committee would make a submission to IMO highlighting the problems encountered when terminals insist on draining shore lines back to the ship on completion of discharge as it defeats the regulations contained with MARPOL Annex II. A draft of this submission will be circulated for review when the committee meets in London

9 Any Other Business

10 Date and Place of Future Meetings

 Tuesday 16th October 2007. Best Practice working Group meeting London Offices.  Wednesday 17th October 2007 CTC Meeting London (INTERTANKO Offices)  Combined CTC # 31/CTSCA #10 – March 2008  Combined CTC # 32 – Singapore May/June 2008 (Date to confirm)  CTSCA # 11 – September 2008 (Date to confirm)

Agenda for the CTC # 31 Page 4 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith Appendix 1 Minutes from last CTC 30 May 2007 Our Ref.: HS-22713/2150000

MINUTES Chemical Tanker Committee meeting # 30

30th May 2007

Conrad Centennial Hotel 2 Temasek Boulevard Singapore 038982 Telephone (65) 6334 8888

Agenda for the CTC # 31 Page 5 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith ATTENDEES:

Company First Name Last Name 1 Dunya Denizcilik Ve Ticaret A.S. Capt. Ozgur Asik 2 Brostrom Tankers SAS Mr. Bruno Caillard 5 Odfjell ASA Mr. Svend Foyn-Brunn 6 Unix Line Pte. Ltd Capt. Amit Jain 7 Iino Singapore Capt. Michihisa Moriya 8 Iino Singapore Mr. Kazuhiro Sakamoto 10 Stolt-Nielsen Transportation Group BV Mr. Bill Millar 11 Norbulk Shipping UK Ltd Capt. John Pocklington 12 Odfjell USA Inc. Mr. John Salvesen 13 INTERTANKO Capt. Howard Snaith 14 Camillo Eitzen & Co AS Capt. Claus Thornberg 15 B & H Equimar Singapore Pte. Ltd Mr. Steffan Tunge 16 Broere Shipping BV Mr. Roel Vermeulen 17 INTERTANKO Mrs. Margaret Doyle

APOLOGIES RECEIVED FROM:

Alasdair Campbell (MOL Tankship (Europe) Ltd.) Steve Hardy (Interorient Navigation Co. Ltd) Harald Nesse (Jo Tankers AS) Mr. Bertil Andersson (Laurin Maritime AB) Capt. Luciano Casella (Finbeta SpA) Capt. Anuj Chopra (Anglo-Eastern Ship management Ltd) Capt. H. Fujino (NYK Bulkship (Europe) Ltd

Agenda for the CTC # 31 Page 6 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith 1. ANTI-TRUST/COMPETITION LAW COMPLIANCE The chairman read out the INTERTANKO anti-trust statement as follows: INTERTANKO’s policy is to be firmly committed to maintaining a fair and competitive environment in the world tanker trade, and to adhering to all applicable laws which regulate INTERTANKO’s and its members’ activities in these markets. These laws include the anti-trust/competition laws which the United States, the European Union and many nations of the world have adopted to preserve the free enterprise system, promote competition and protect the public from monopolistic and other restrictive trade practices. INTERTANKO’s activities will be conducted in compliance with its Anti-trust/Competition Law Guidelines.

2. MINUTES FROM THE LAST MEETING The minutes from the last meeting (which was a combined meeting of the Chemical Tanker Committee (CTC) and the Chemical Tanker Sub-Committee Americas (CTSCA)) were approved by correspondence, circulated in the INTERTANKO weekly news, and circulated as a chemical bulletin and placed on the INTERTANKO member’s area of the web site. It was agreed that action point 3, arising from the last meeting regarding the Medical First Aid Guide, should continue to be followed up by a letter from the secretariat to the chairman of ESPH raising our concerns and seeking a way to rectify these.

Action Point 1: The secretariat to write to the Chairman of ESPH raising our concerns with regards to the inconsistencies within the Medical First Aid Guide and that no response has been received by ESPH to our earlier enquiries.

3. MARPOL Annex II

3.1 – Shipping Document Submission to MEPC 56 The committee noted the submission from INTERTANKO and the aim by us to enhance the shipping document that exists, as referenced in BLG.1/Circ.18 in order that the additional information may be provided. The committee took note that some concerns have been raised outside of INTERTANKO membership, that our request for clarity may be too prescriptive and too detailed by way of requesting the viscosity data. However, as the committee re-affirmed the intent of our submission is that this should be used as an optional shipping document “if” the information is not available elsewhere or if charters will not use the shipping name in the official documentation. The committee agreed that in the fullness of time such information could be assessed for inclusion within the MSDS however the focus at this time was to ensure that the information is provided.

The committee agreed however that even though they initially approved the submission they felt that some changes should be made to the form and covering notes as follows:

 The committee agreed however that the signature requirements should be made clear that it is the shipper that should sign the document.  That the information is required for all solidifying/high viscosity cargoes (where reference to IBC 16.2.6 and/or 16.2.9 are made)and not just vegetable oils should be made clear (remove all reference to vegetable oils).  That the title should include the word “optional” shipping document and that whilst the information is mandatory but the form is optional and the heading should be changed to reflect this accordingly.  Remove Certificate of Fitness from the wording.  Discharge port should read unloading port

Agenda for the CTC # 31 Page 7 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith Once this has been undertaken the committee agreed that we should encourage our members to begin to use the optional shipping document as we have submitted to IMO if the information is not available elsewhere.

Action point 2: Make the changes to the optional shipping document as outlined and then circulate to the committee for their approval and then encourage members to utilise the form “if” the information regarding viscosity and melting point is not available

The committee further agreed to request the INTERTANKO Documentary Committee to make a reference to this shipping document in their revisions to the INTERTANKO pre-wash clause.

Action Point 3: Request the Documentary Committee to make reference to shipping document in the revised INTERTANKO Pre-wash clause.

3.2 The 3 000m3 Question, an update and report.

The committee remained supportive of the submission made to MEPC 56 on this issue (Document MEPC 56/6/3) but agreed that the verbal introduction to the document should be clear and as concise as possible to make our points clear. The committee requested the secretariat to request a copy of the verbal introduction from Norway for review prior to MEPC 56.

Action Point 4: The secretariat to request a copy of the verbal introduction of the joint submission MEPC56/6/3 from Norway for review prior to MEPC 56.

3.3 Classification of Products The committee took note of the report and also noted that to date no problems had been reported by the committee regarding problems with any unclassified products. However, the committee agreed to keep the issue open and on the committees agenda for the future.

The committee also noted that Chapter 17 of the revised IBC code includes some double entries: the example brought to the attention of the committee was on page 75 of the IBC Code, “Calcium long chain alkyl (C11-C40) phenate” shown as category Z, however listed underneath this entry is a second entry for the same product “Calcium long chain alkyl (C11- C40) phenate (n)” show as category Y. The committee noted that when the code was adopted this was the legal product name, and the IBC code is the legal document. However, when data was re-submitted this produced a different carriage requirement due to the revised profile, thus the printed IBC code contains both entries “but” the current MEPC 2 circ should prevail.

The committee also noted that Chapter 19 of the IBC code also contains small errors but chapter 19 is a guidance list and thus Chapter 17 will prevail. However, the committee noted that a revised Chapter 19 is expected to be produced by ESPH as an addendum to the IBC code via a circular.

3.4 - Biofuels – Training & Carriage Issues The committee took note that the issue surrounding blends will be further discussed by ESPH, but that the current practice today is in line with the proposals submitted by UK & Sweden.

A particular concern raised by the committee related to bio-fuels when carried as an Annex II product with regards to tank cleaning requirements under OPA-90 because both vegetable

Agenda for the CTC # 31 Page 8 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith oil and marine diesel are classed as an OPA 90 product. Therefore, if this was to be dealt with under the P&A manual it raises complications regarding how to deal with tank washings in practice. The committee agreed therefore that should be brought to the attention of the USCG CTAC regarding how to deal with combined products.

Action point 5: Request feedback from the CTAC for thoughts and their consideration regarding how blends will be dealt with under OPA-90.

3.5 Bio-fuel Training The committee raised the question regarding training for ships staff with regards to the carriage of Bio-fuels. The committee agreed this was essential but that it was necessary to first wait for guidance from the IMO with regards to how the products will finally be assessed. Once that is completed we can reassess the training aspects with regards to providing guidance documentation post ESPH.

4. WORKING GROUP REPORTS

4.1 Cleaning Standard Terminology Working Group - Chairman Svend Foyn-Bruun Committee was advised that terms of reference (TOR’s) for the working group are currently under approval by the group. The group members currently include; INTERTANKO; CDI; Dow and Chevron. It was noted by the committee that the end use of the product played a large part in what the cleaning standard was stipulated to be. The committee will be kept advised of progress and it was agreed that when the standards are mature they will be circulated to the committee for approval prior to seeking council endorsement.

Action Point 6: Keep the committee updated of progress with the groups work and when the standards are mature they will be circulated to the committee for approval prior to seeking council endorsement.

4.2 Best Practice Management Working Group – Chairman John Salvesen

The committee took note of the completed work undertaken by working group to date. In addition the committee re-watched the “HAWK” fly-by camera footage and discussed proposals to move forward with stage 2 of this project, which is aimed at addressing cargo vapor emissions that occur during tank cleaning. The committee further agreed that the working group should aim to provide a list of options that could be undertaken to address the issue of cargo vapor release during tank cleaning for review by the committee at its next meeting, where the various options would be reviewed and assessed by the committee.

In addition, it was agreed that the committee would evaluate stage 1 with regards to its application (no feedback had been received by members to date) and provide feedback on its practical applications at the next meeting.

Action Point 7: Provide a report for the committee at its next meeting listing various options that could be undertaken to reduce or avoid cargo vapor emissions during tank cleaning. The committee will review these options when it meets and review which options are the most appropriate.

4.3 FOSFA Working Group Banned Last Cargo – Chairman Svend Foyn-Bruun The committee took note of the report.

Agenda for the CTC # 31 Page 9 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith 5. USCG UPDATES 5.1 The Hazardous Cargo Transportation (HCTS) Subcommittee The committee took note of the report provided by the secretary.

5.2 Report from the CTAC MARPOL Annex II Work Group The committee took note of the report provided by the secretary.

5.3 HOGANSAC report. The CTSCA chairman provided an update of the work of this group covering the following main areas:

 The group regularly reviews accidents in the area and assesses navigational aids damaged in “knock-downs” and replacement of same.  The “Deep Draft Entry Facilitation Group” is currently focusing on collecting security delay information and is trying to expand this facility beyond just the Houston area. Members were re-urged to advise the group of any delays encountered with regards to security related issues as reported and requested in the INTERTANKO weekly news  Dredging Sub-committee, provides periodic surveys to check depths following silting. The committee agreed to highlight this work to our members and actively seek feedback from members of any area in the Houston vicinity that had less water depth than reported, so that this may be brought to the attention of HOGANSAC accordingly.  The Harbour Safe Refuge committee assesses compliance with the IMO safe refuge requirements.  The Maritime awareness committee focuses its work upon the rules of the road and any violation issues. It was agreed that the secretary would circulate the “homeport link to the committee and provide a weekly news item for the benefit of all members.  The Outreach committee: which aims to highlight the work of HOGANSAC www.hogansac.org

The committee was grateful for the detailed update and agreed several action points.

Action Point 8: Members were re-urged to report to HOGANSAC any delays encountered with regards to security related issues as reported and requested in the INTERTANKO weekly news and this article will be re-circulated.

Action Point 9: Highlight the work of the HOGANSAC Dredging sub-committee to INTERTANKO members and actively seek feedback from members of any area of in the Houston vicinity that had less water depth than reported so that this may be brought to the attention of HOGANSAC accordingly.

Action Point 10: Circulate the “homeport link” to the committee and provide a weekly news item for the benefit of all members.

6. CHEMICAL ACCIDENTS

6.1 IIG Update The committee took note of the reports and submissions to the IMO by the IIG but agreed that the secretary should re-circulate the findings of the INTERTANKO “bottle neck group” report for review and reconsideration by the committee.

Action Point 11: Re-circulate the findings of the “bottle neck group” report for review and reconsideration by the committee to assist and guide the committee accordingly regarding how this work should be addressed at IMO

Agenda for the CTC # 31 Page 10 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith Following due review by the committee it was agreed that the inert gas issues for new buildings and existing ships was not moving forward sufficiently and that too many associations were still blocking positive forward action on this issue to the detrimental safety of those at sea. The committee agreed therefore that INTERTANKO should begin to highlight its position.

Action Point 12: INTERTANKO should begin to highlight its position regarding outfitting inert gas to new buildings and existing ships.

6.2 IMO Correspondence Group

Following due review of the issue by the committee it was agreed that any problems or misunderstandings relating to bonding cables were by the shore not by the ship and that not all terminals were fully up to date with the requirements and recommendations regarding bonding cables.

7. ANY OTHER BUSINESS

7.1 Draining Ships Lines It was reported that many owners are faced by shore terminal requests to drain shore lines back to the ships tank following completion of discharge. The committee noted that was clearly in contravention to MARPOL as these requests are made after the ship has used its super stripping system and complied with minimum stripping requirements under MARPOL Annex II. Thus, when shore lines are drained back to the ship it defeats the regulations contained with MARPOL Annex II. The committee agreed that a submission should be made to IMO to highlight this problem.

Action Point 13: Make a submission to IMO highlighting the problems encountered when terminals insist on draining shore lines back to the ship on completion of discharge as it defeats the regulations contained with MARPOL Annex II

7.2. Pre-Wash Machine Washing Cycles A question was raised regarding the definitions of "wash cycle" as defined within the ships P&A Manual, for example reference is commonly made to a wash "cycle" the enquiry related to the duration of the wash cycle to ensure that a "full" cargo tank was washed. The committee agreed that reference should be made to the tank cleaning machines operational manual and confirmed that a "cycle" will be defined within that manual with regards to the duration of the cycle and operating pressure to ensure that a full tank wash would be achieved within the P&A Manual.

Related to the pre-wash issue it was also noted that under regulation 13- para 7.1.2 of MARPOL Annex II it is mentioned if a category Y & Z product is not unloaded as per the P&A Manual then a pre-wash is mandated. However, under Appendix 6 which lays down the prewash procedures, category Z is not included. It was agreed that further guidance/comments would be obtained on the issue and shared with the committee.

Action Point 14: Investigate the pre-wash issue regarding Category Z and advise the committee accordingly.

Agenda for the CTC # 31 Page 11 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith 8. FUTURE MEETINGS CTC AND CTSCA

a. Tuesday 11th September CTSCA Cargo Vapour Working Group Meeting Houston b. Wednesday 12th September CTSCA Meeting Houston c. Wednesday 17th October CTC Meeting London (INTERTANKO Offices)

Agenda for the CTC # 31 Page 12 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith Appendix 2 Action Point CTC # 30 Status 05 October 2007 Our Ref.: AG-22713/1000089 Action Point Action Status

Action Point 1 The secretariat to write to the Chairman of This will be brought up at the ESPH raising our concerns with regards to the next CTAC Meeting in inconsistencies within the Medical First Aid November which fortunately Guide and that no response has been received will directly follow the ESPH 13 by ESPH to our earlier enquiries. where the blends issue will also be discussed Action point 2 Make the changes to the optional shipping Completed document as outlined and then circulate to the committee for their approval and then encourage members to utilise the form “if” the information regarding viscosity and melting point is not available.

Action Point 3 Request the Documentary Committee to make Completed. The documentary reference to shipping document in the revised will circulate the model clause INTERTANKO Pre-wash clause. for review to the CTC once completed. Action Point 4 The secretariat to request a copy of the verbal Completed introduction of the joint submission MEPC56/6/3 from Norway for review prior to MEPC 56.

Action point 5 Request feedback from the CTAC for This will be brought up at the thoughts and their consideration regarding next CTAC Meeting in how blends will be dealt with under OPA-90. November which fortunately will directly follow the ESPH 13 where the blends issue will also be discussed. Action Point 6. Keep the committee updated of progress with Work in progress an update the groups work and when the standards are will be provided when the mature they will be circulated to the committee meets. committee for approval prior to seeking council endorsement

Action Point 7 Provide a report for the committee at its next The working group has met meeting listing various options that could be twice and will provide a written undertaken to reduce or avoid cargo vapor report for the CTC when it emissions during tank cleaning. The meets. committee will review these options when it meets and review which options are the most appropriate.

Action Point 8 Members were re-urged to report to Completed vie weekly news. HOGANSAC any delays encountered with regards to security related issues as reported and requested in the INTERTANKO weekly news and this article will be re-circulated.

Agenda for the CTC # 31 Page 13 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith Action Point 9 Highlight the work of the HOGANSAC Completed. Dredging sub-committee to INTERTANKO members and actively seek feedback from members of any area of in the Houston vicinity that had less water depth than reported so that this may be brought to the attention of HOGANSAC accordingly.

Action Point 10 Circulate the “homeport link” to the Completed committee and provide a weekly news item for the benefit of all members.

Action Point 11 Re-circulate the findings of the “bottle neck Completed. group” report for review and reconsideration by the committee to assist and guide the committee accordingly regarding how this work should be addressed at IMO.

Action Point 12 INTERTANKO should begin to highlight its This work is well underway position regarding outfitting inert gas to new with several news articles buildings and existing ships. published to date

Action Point 13 Make a submission to IMO highlighting the A revised draft of the problems encountered when terminals insist submission will be available for on draining shore lines back to the ship on CTC # 31 to review when it completion of discharge as it defeats the meets. regulations contained with MARPOL Annex II.

Action Point 14 Investigate the pre-wash issue regarding An update will be provided Category Z and advise the committee when the committee meets accordingly.

Agenda for the CTC # 31 Page 14 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith Appendix 3 (DRAFT) CTC Issues Goals Objectives (Status October 2007).

Issue Goal Objective Chemical Tanker Safety  Simplify standards  Reduce accidents & fatalities by  Explosions  Inert Gas requirement applied to increasing and simplifying the use and  Increasing accidents product not ship application of inert gas.  Complicated regulations  Simplify regulations  International application through the  Training Standards  Apply IG regs to new & existing ships IMO  Conflicting Requirements  Address Tank Entry Concerns  Increase awareness of tank entry  Different standards different ship types  Investigate IG from shore (small dangers tankers)  By 2012. FOSFA Banned Last Cargo Rules  Undertake a number real time Field  To conclude field tests and report to  Investigate INTERTANKO proposal Tests to substantiate our proposal (or FOSFA for their consideration 2007. for a testing regime which would otherwise) facilitate the loading of edible oils into  Utilise third party chemical analysis. stainless steel tanks following a  Cooperate with FOSFA FOSFA banned list cargo.  Report to Oils & Fats Committee  If such a scheme were feasible due to  Develop “Suit case Type test” if initial more robust testing methods, it should filed tests indicate the proposal is be possible to effectively increase the feasible. size and flexibility in the shipping fleet available to the oils and fats industry, while still meeting the receiver’s demands for uncontaminated cargoes.

Agenda for the CTC # 31 Page 15 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith Tank Cleaning Terminology  Establish a limited set of tank cleaning  Produce first set of proposed unified  Cleaning levels are getting stricter standards that can be applied for the cleaning terminology standards for  Varies from port to port for same majority of bulk liquids carried on consideration by 2008. product Chemical tankers.  Tank cleaning standards shall reflect  Varies for same product by same  Promulgate use within the industry Charterers needs for objective charterer  Cooperate with shippers & Charterers requirements for tank cleanliness as  Encourages solvent spraying well as ships need for an objective and  Does not clean the tank just passes concrete target value for tank WWT preparation.  Each standard should scientifically and practically balance acceptable risk of last cargo contamination. Finally the number of standard must be set to a practical minimum. Cargo Vapour Emission Reduction  Produce Best Practice guidelines for  Increased focus by regulators on cargo use by INTERTANKO members vapour emissions :  Stage 1 Inadvertent cargo vapour  Stage 1 Completed  Released inadvertently release  Released during Tank cleaning  Stage 2 Cargo vapour release during  Stage 2 to complete by March 2008.  Associated problems associated with tank cleaning Vapour Balancing  Stage 3? Addressing vapour Balancing  Stage 3 Under Review and needs to be problems concluded.

Agenda for the CTC # 31 Page 16 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith MARPOL Annex II  Produce guidance documentation for  Completed  New revisions entered into force members MARPOL Annex II 1/1/2007  Ensure members best interests  Ongoing Process  Smooth transition protected  Ensure information available to  Coordinate and highlight through  On going process members and regulators IMO/ESPS Ref: MSDS/MFAG  Application and guidelines in the USA problems  Bio Fuels – rules & Training  Cooperate with USA regarding NVIC  Completed  MSDS requirements and guidance Standardisation under the revisions  Ensure Bio-Fuel training and guidance  On going Process  MFAG requirements and guidelines available under the revisions  Shipping Documentation  Completed  Viscocity/Solidifying information Pre- wash

Agenda for the CTC # 31 Page 17 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith Appendix 4 Draft Minutes CTSCA Meeting # 9 Wednesday, September 12, 2007 Our Ref.: MD-22713/950000

(DRAFT) MINUTES Chemical Tanker Subcommittee (Americas) MEETING Number 9 12 September 2007 Southshore Harbor Resort and Conference Center 2500 Southshore Blvd League City, Texas 77060 281-334-1000

ATTENDEES:

Company First Name Last Name

Dow Chemical Company Mr. James Prazak Stolt Nielsen Transportation Group BV Mr. Soren Ibsen Lloyds Register Mr. Jim McInnis Broere Shipping BV Mr. Roel Vermeulen Stolt Nielsen Transportation Group Inc. Mr. Soren C. Ibsen Odfjell USA Inc. Mr. John Salvesen Odfjell USA Inc. Mrs. Denise Schaefer Odfjell ASA Inc. Mr. Leif Gunnar Alvaer Odfjell USA Inc. Capt George Pontikos Anglo-Eastern Ship Management Ltd. Capt. Anuj Chopra Odfjell ASA Mr. Svend Foyn-Brunn ChevronTexaco Shipping Mr. Cliff Frye ChevronTexaco Shipping Mr. Tim Hewlett-Parker INTERTANKO Mrs. Margaret Doyle INTERTANKO Capt Howard Snaith ABS Mr. Graham Marshall

Invited Guests

Company First Name Last Name

US Coast Guard – Houston VTS Mr. Steve Nerheim US Coast Guard – Sector Houston-Galveston LT TJ Parker US Coast Guard Haz Mat Standards Div - HQ CDR Rick Raksnis Foret Enterprises – HOGANSAC Ms. Tava Foret West Gulf Maritime Association Mr. Niels Aalund

Apologies from: Capt. Moriya Michihisa (Iino Singapore Pte. Ltd) Capt. Amit Jain (Unix Line Pte. Ltd) Capt. Victor Goldberg (Crowley Petroleum Services) Mr. Harald Nesse (Jo Tankers AS) Capt. Amarjit Singh (Aurora Tankers Sdn)

Agenda for the CTC # 31 Page 18 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith (Appendix 1 includes the business cards of those attending the meeting)

1. ANTI-TRUST/COMPETITION LAW COMPLIANCE

INTERTANKO’s Anti-Trust/Competition law Compliance Statement INTERTANKO’s policy is to be firmly committed to maintaining a fair and competitive environment in the world tanker trade, and to adhering to all applicable laws which regulate INTERTANKO’s and its members’ activities in these markets. These laws include the anti-trust/competition laws which the United States, the European Union and many nations of the world have adopted to preserve the free enterprise system, promote competition and protect the public from monopolistic and other restrictive trade practices. INTERTANKO’s activities will be conducted in compliance with its Anti-trust/Competition Law Guidelines.

2. CTSCA Chair Welcome John Salvesen welcomed all, initiated introductions and gave an overview of the days schedule.

3. USCG Update

3.1 – Lt. TJ Parker, Assistant Chief of the Port Stae Control for Sector Houston Galveston, addressed the subcommittee on behalf of the Captain Diehl (CO Sector Houston) who was unable to attend because of a pollution incident that occurred earlier that morning. Lt Parker discussed in detail the activities in Sector Houston relative to the CTSCA.

3.2 - Steve Nerheim (VTS Houston) updated the CTSCA on the ANOA policy and the Houston Galveston Implementation. A copy of Mr. Nerheim's presentation is included below:

2007 Chem Tanker SubComm.ppt (...

3.3 - CDR Rick Raksnis (Chief, Hazardous Materials Standards Branch) will discuss current CTAC and MARPOL Implementation issues.

Intertanko-Mtg-907 .ppt (207 KB...

CDR Raksnis also addressed the CTSCA regarding the U.S. Coast Guard (USCG) Chemical Transportation Advisory Committee (CTAC) most recent meeting on the 12th April 2007 in Quincy Massachusetts. Agenda items from the full CTAC meeting included a report from the CTAC Hazardous Cargo Transportation Security (HCTS), the NFPA 472 and Outreach Sub- committees. Also included under the umbrella of the Outreach Sub-committee are the Barge Emissions and Placarding and the MARPOL Annex II Work Groups. CDR Raksnis also reminded the CTSCA that applications are still being accepted for the future slate of CTAC.

4. Dialogue with other associations

4.1 - Tava Foret updated the CTSCA on the latest activity of the HOGANSAC Navigation Operations Subcommittee, and on behalf of Beverly Clark discussed the current activities of

Agenda for the CTC # 31 Page 19 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith the HOGANSAC Deep Draft Entry Facilitation Sub-committee as well as any other HOGANSAC activities of relative interest. A copy of the HOGANSAC NAVOPS presentation can be found below:

HOGANSAC Nav Ops - CTSCA 09120...

4.2 – INTERTANKO has recently established a reciprocal membership with the NIOP in order to enhance the dialogue with the manufacturers and shippers of oilseed products, which has proven very useful to our members. The CTSCA Secretary reminded the subcommittee that, at the request of the Board of Directors of the National Institute of Oilseed Products (NIOP), on 5 June 2007, INTERTANKO participated in the NIOP Technical Committee in Washington, DC. INTERTANKO updated the NIOP Technical Committee on relevant IMO issues including an update from the 11th session of the Sub-Committee on Bulk Liquid and Gases (BLG), the subsequent Working Group on Environmental Safety and Pollution Hazards (ESPH) and the upcoming 56th Session of the Marine Environment Protection Committee (MEPC) to be held next month in London.

5. MINUTES OF THE LAST MEETING: (CTC # 30, # 29 and CTSCA # 8).

5.1. - The CTSCA reviewed the minutes of the CTC #29/CTSC #8 meeting that were circulated within the committee and subcommittee. The minutes were approved in the usual manner and were subsequently circulated in the Weekly NEWS, as a chemical contact bulletin and placed on the members’ area of the web site.

5.2. - The minutes of the CTC #30 in Singapore 30 May 2007 were also circulated within the committee and subcommittee and have been approved in the usual manner. These meeting minutes were included within the meeting materials.

The Subcommittee addressed three overlapping issue with regard to CTC #30. They are CTC Action Points, 1 (MFAG was included under the IMO Report) 5 and 13 stem from this meeting. These action points are being raised in this CTSCA meeting because of the timelines associated with the CTAC meeting and possible BLG 12 submissions.

CTC # 30 Action Point -5/CTSCA 9 Action point - 1: - Request feedback from the CTAC for thoughts and their consideration regarding how blends will be dealt with under OPA-90. – This will be brought up at the next CTAC Meeting in November which fortunately will directly follow the ESPH 13 where the blends issue will also be discussed.

CTC # 30 Action point 13/CTSCA Action Point – 2: - Make a submission to IMO highlighting the problems encountered when terminals insist on draining shore lines back to the ship on completion of discharge as it defeats the regulations contained with MARPOL Annex II. A revised draft of the submission will be prepared for the next CTC Meeting

6. WORKING GROUP REPORTS

6.1 - Report from the INTERTANKO Cargo Vapour Emissions Work Group

Agenda for the CTC # 31 Page 20 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith Last year the CTSCA proposed that INTERTANKO should consider producing guidelines to reduce inadvertent cargo vapour release, similar to that developed by the American Waterway Operators, Best Management Practice (BMP) for INTERTANKO members with the intent of encouraging INTERTANKO members to incorporate these BMPs into their operations in order to proactively contribute to the control and reduction of emissions from tankers without the necessity of federal or state regulation. This proposal was subsequently endorsed by the INTERTANKO Council in November 2006 and the committee was requested to proceed with its work with the intent that this would be presented to Council at its meeting in Houston in March 2007 for final endorsement by Council. The BMPs have been published and members are encouraged to review and incorporate them into their own practices.

As a follow up, the committee further agreed that once the BMPs were completed, a small working group would be established to undertake an assessment of a second stage of these guidelines with regard to addressing cargo vapour emissions in relation to tank cleaning.

This “stage 2” best practices work group met on 11 September 2007. During the CTSCA #9 INTERTANKO Marine and Chemical Director Howard Snaith gave a verbal report on the CTSCA working group meeting the day before. As was reported, the next phase will address the steps taken to deal with your cargo vapors during tank cleaning, possibly creating a set of voluntary guidelines.

One best practice proposed is based on a study conducted in the Port of Rotterdam, focused on an additional cycle wash as a means to reduce the vapours released. We are seeking permission from the Port of Rotterdam to formally circulate their presentation.

Extensive debate ensued regarding the Port of Rotterdam approach and data the RGS study. The draft meeting minutes and work plan were developed and will be distributed prior to the next WG meeting which will be held 16th October 2007 in London.

CTSCA Action Point # 3 – In conjunction with the drafting BMP Stage 2 report, request from RGS a copy of the Rotterdam study looking into the questions posed by the work group.

CTSCA Action Point # 4 – Starting with the flow chart developed during the Best Practice working group meeting on 11 September, prepare a draft document to be distributed to the WG, CTSCA and CTC that will address the step by step process involved in tank cleaning and the updated TOR for the WG.

The group also agreed that the next logical step (Stage 3) will aim to be a bit more specific; possibly focusing on vapour balancing practices. This may be discussed at the next BMP WG Meeting tentatively scheduled for 16 October 2007 in London.

6.2 - Report from the INTERTANKO Tank Cleaning Terminology Work Group

This issue was raised at the previous CTC meeting and carried forward to CTC #29/CTSCA #8, and focuses on the problems stemming from the many different cleaning standards within the industry today for different grades of products. The concept of the proposal, however, is “not” to create standard cleaning techniques but rather a simplification of the standard they need to be cleaned to. The issue stems from the IIG work on concerns

Agenda for the CTC # 31 Page 21 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith regarding over cleaning of cargo tanks and the associated pressure placed on ships' crews to utilize solvents for tank cleaning. CDI has agreed to participate in this effort.

6.3 - Report on the implications of the recent TCEQ activity

Over the last six months, INTERTANKO has forwarded a number of bulletins relative to TCEQ flyovers similar to this sent 27 July:

“TCEQ will be conducting over-flights over pipelines, oil and gas production areas, and industrial areas along the Gulf Coast of Texas in the following counties: Orange, Jefferson, Chambers, Galveston, Harris, Brazoria, Calhoun, Victoria, San Patricio, and Nueces.”

The subcommittee is invited to discuss any implications of these surveys.

7. IMO Update

7.1 - MEPC 56 Report

The CTSCA Secretary reported on the 56th Session of the meeting of IMO's Marine Environment Protection Committee (MEPC 56), which was held 9-13 July 2007, mentioning that the final official report was forwarded. As soon as it was released This report reflects much of what was reported in INTERTANKO Weekly NEWS Nos. 28 and 29 immediately after MEPC 56 concluded. Issues of concern to the CTSCA include clarification on the application of regulation 4.1.3 of MARPOL Annex II (discussed on page 51 of the report) and the proposal submitted by INTERTANKO regarding high viscosity cargoes were both reported on by Howard Snaith who attended all of MEPC 56.

In conjunction with the INTERTANKO proposal, it was also proposed at MEPC 56 that a Circular be issued to ensure that manufacturers and shippers understand their obligations relative to regulations 16.2.6 and 16.2.9. MEPC 56 agreed and approved the development of a joint MSC/MEPC Circular. MSC will be asked to endorse the Circular in October of 2007. In the meantime, if guidance is needed prior to October, INTERTANKO will be making some minor amendments to its document submitted to MEPC and then recommending its members utilize this form “if” the information is not supplied via the official shipping document. Both the MEPC 56 Report and Draft Circular were included in the meeting materials distributed.

The CTSCA was invited to take note

7.2 FAME Special Requirements – Inconsistencies

The CTSCA Secretary reported that the following inconsistencies have been discovered within the amended IBC Code. The generic entry for Fatty Acid Methyl Ester (FAME) carries a special requirement under column O of 15.12.3. Under 15.12.3 Products shall:

.1 not be stowed adjacent to oil fuel tanks;

.2 have separate piping systems; and

.3 have tank vent systems separate from tanks containing non-toxic products.

In researching this further if you assume that the GESAMP hazard profile would need a "2"

Agenda for the CTC # 31 Page 22 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith in C1, C2, or C3 for the requirement to apply. The inconsistencies exist when you look at the other FAME products; Coconut Oil FAME, Palm Oil FAME and Rapeseed Oil FAME and notice that they do not have this reference. Clarification of this has been requested of GESAMP who have deferred it to Mr. Ken McDonald, the ESPH Secretary.

CTSCA Action Point # 5 – Follow up with the ESPH Chair and the IMO Secretariat prior to ESPH 13. If this is not addressed by then, the decision to submit something to BLG 12 will be made at the next CTC Meeting

7.3 - Report from the ESPH and BLG Meetings

The CTSCA Secretary, who regularly attends the IMO Working Group on the Evaluation of Safety and Pollution Hazards (ESPH) gave a brief overview of the meeting held during the 11th Session of the Bulk Liquids and Gases Sub-committee (BLG 11) 16-20 April 2007. Agenda items discussed included:

 The evaluation of cleaning additives

 The evaluation of new products

 Consideration of the practical implications regarding the long term funding of the GESAMP/EHS Work Group

 Review of MEPC.2 Circ - posting provisional tripartite agreements on the IMO website

7.4 - Latest update on the Carriage and Classification of Biofuels

The carriage of biofuels continues to be an issue of discussion at IMO and will finally be discussed in detail at ESPH 13. Confusion still exists regarding the percentages of cargoes, such as ethanol and MTBE when combined with Annex I cargoes. The document submitted to BLG 11/10 (for further review by ESPH) suggests how to deal with the percentage mix issue within biofuels. In the interim period, many administrations are agreeing that any blend containing 85% or more mineral diesel oil or gasoline should be carried as an Annex I product. INTERTANKO suggests that if you have concerns in this regard you should contact the administration in question relative to that enquiry. The document currently being used (by the UK, Sweden and IPTA) was included as part of the CTSCA #9 meeting materials. The subcommittee was informed that this issue will hopefully, finally be addressed at ESPH 13.

7.5 Overview of the submissions to ESPH 13

The 13th Session of the BLG Working Group on the Evaluation of Safety and Pollution Hazards of Chemicals will be held from Monday, 22 October to Friday, 26 October 2007 in Tokyo. In preparation for this meeting all of the current submissions were reviewed by INTERTANKO and the ESPH 13 Agenda reviewed by the subcommittee

7.6 - Discussion of MFAG with the ESPH

CTSCA 8 Action Point requests that a possible submission be made to ESPH regarding the discrepancies between the Amended IBC Code and the Medical First Aid Guide with a particular note regarding the lack of antidotes for certain cargoes. A submission may be

Agenda for the CTC # 31 Page 23 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith made in 2008 to BLG 12. (4-8 February 2008) This will be brought up at ESPH in October. The submission dates for this meeting are:

 Bulk Submissions - 02/11/07

 Non-Bulk - 30/11/07

 Reactions - 14/12/07

CTSCA Action Point # 6 – Follow up with the ESPH Chair and the IMO Secretariat prior to ESPH 13. If this is not addressed by then, the decision to submit something to BLG 12 will be made at the next CTC Meeting

8. Other Issues and Future Meeting Dates

Any other Business – Classification of phosphoric Acid Residue

Problems are being encountered by members transporting phosphoric acid residue in slurry ( gypsum format). Discussion of the proper classification of this cargo followed.

The futures meetings of the committees have previously been agreed as follows:

 Wednesday 17th October 2007 CTC Meeting London (INTERTANKO Offices)  Combined CTC # 31/CTSCA #10 – March 2008  Combined CTC # 32 – Singapore May/June 2008  CTSCA # 11 – September 2008

Agenda for the CTC # 31 Page 24 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith Agenda for the CTC # 31 Page 25 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith Agenda for the CTC # 31 Page 26 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith Appendix 5 REPORT OF TANK CLEANING GROUP

INTRODUCTION

Following a meeting of the Oils and Fats Sub-committee on Tank Coatings and Cleaning, it was agreed that a small group would meet to investigate the proposal from Intertanko for a testing regime which would facilitate the loading of edible oils into stainless steel tanks following a banned list cargo. If such a scheme were feasible due to more robust testing methods, it should be possible to effectively increase the size and flexibility in the shipping fleet available to the oils and fats industry, while still meeting the receivers demands for uncontaminated cargoes. At its first meeting in May 2004, the group (Mr S Foyn-Bruun, Dr J Hancock and Captain H Snaith) co-opted Mr T de Heer of Chemical Laboratories Dr A Verwey, who has much experience with the analysis of contaminants in oils and fats.

The flow chart for the proposed testing scheme is attached to this report (Annex 1). It is applicable only to stainless steel tanks as it is well documented that coated tanks absorb cargoes and then desorb them into the next cargo. For practical and commercial purposes, the testing scheme depends on the availability of an on-board test method to check that the ships tanks are indeed clean, following the cleaning process. The use of such tests is standard practice in the chemical tanker industry, particularly before high purity chemicals are loaded. The tests used most frequently are the permanganate test (PTT), the chemical oxygen demand test (COD) and the miscibility test. Chemical Laboratories Dr Verwey were asked to evaluate which FOSFA banned previous cargoes would be suitable for testing using robust on-board tests which are already well tried and tested in the Chemical Industry. As can be seen in Annex 2, over 60% of the substances on the FOSFA Banned List can be detected using one or more of these tests, and several of these substances are transported around the world in high volumes. Thus, the scheme could facilitate vessel availability in many origin ports.

APPROACH

The group agreed that although laboratory testing of the scheme could be carried out, practical trials were deemed essential. It was proposed to select voyages and vessels which comply with the rules of the testing scheme and monitor the performance of the on- board tests in demonstrating whether the tank was fit for the subsequent loading of edible oils. Previous cargoes with a reputation for persistence would be chosen where possible. It was not commercially viable to load edible oil after a banned list cargo as this could not be sold within the food chain after the trial. By way of a reasonable compromise, it was agreed to use subsequent cargoes which would not react with the previous cargoes. Any residues would be analysed in a laboratory to confirm, or otherwise, the decision arrived at following the so-called “suitcase test”. FIRST TRIAL

The first test was carried out in November 2004 utilising the vessel BOW FIRDA. For the discharge/cleaning/loading sequence under study, the previous cargo was acrylonitrile

Agenda for the CTC # 31 Page 27 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith (ACN) and the following load was toluene. ACN is a FOSFA banned list substance, and as toluene does not react with ACN, it represented the vegetable oil. ACN can be detected using the permanganate (PPT) wall-wash test. This wall-wash test (ASTM D1363-06: Standard Test Method for Permanganate Time of Acetone and Methanol) detects the presence of impurities that reduce potassium permanganate. A minimum time of three hours is required to confirm the absence of residue following the cleaning of the stainless steel tanks. The wall-wash tests confirmed the suitability of the tank for loading high-purity chemicals. During the loading of the tanks with toluene, samples were taken at various points and times to monitor any residue level of ACN. These samples where then sent for laboratory analysis using the industry standard method, gas chromatography followed by mass spectrometry (GCMS), for quantification of any residue. The Verwey Report of this trial (No. 10421253) is attached as Annex 3.

These results, together with the wall-wash test times demonstrated the following:

 it is possible to clean stainless steel tanks to an acceptable level for the chemical industry following the carriage of acrylonitrile;  there was a very small amount of acrylonitrile which was left in the tank loading pipe work.  This could be detected by GCMS in the first foot sample, (at the level of 0.04mg/kg in about 10t of cargo, equivalent to about 0.5 g in the tank);  when the tanks were fully loaded, any contamination in the cargo was below the limit of detection using GCMS. (LOD = 0.01mg/kg).

The group agreed that these results showed in this scenario that it may be possible to clean stainless steel tanks to an acceptable level to meet food industry demands. However, even though the loading lines and pumps are stainless steel, the first foot sample from any tank was important as it was likely to contain the highest concentration of any residue left in the tank or lines. Thus, it was agreed to conduct a second test to further investigate these points.

SECOND TRIAL

For this trial, the unloading and loading of the BOW CHAIN in Rotterdam was monitored. The previous cargo was styrene monomer, a known persistent residue substance, and after cleaning and wall-wash testing, tank WS8 was charged with acetone. Again, there is no reaction between styrene monomer and acetone, so any residue in the cargo could be found by GCMS and any residues on the walls would be characterised by a reduced time for the permanganate test. The Verwey report for this investigation (No. 10520396) is attached (Annex 4).

As in the previous test all the wall-wash tests and the UV test, and the physical tank inspection showed that they were fit to load cargoes of high purity chemicals. In total, six samples were taken during the loading procedure as described in the report. The discharge sample (no.6) was taken at the arrival port and returned to the Verwey laboratories for analysis. Analysis of sample no.1, effectively the shore tank sample showed that, as expected, the styrene level was below the limit of detection of the method i.e. less than 0.005 mg/kg. Samples 2, 3 and 4 were the manifold samples, whose levels were 0.055, 0.330 and 0.017 mg/kg respectively. These are logical results if one assumes that again, a very small amount of one cargo remained somewhere in the pump/line/manifold system. This resulted in an average styrene level in the tank after loading of 0.005 mg/kg, which is at the limit of detection for the most sensitive laboratory equipment.

Agenda for the CTC # 31 Page 28 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith However, the result of the analysis on the discharge sample was 0.045mg/kg. Although this level is still very low, it indicates that there was an increase in the styrene monomer level in the tank during the voyage. This result is difficult to understand. The consensus was that it may have been due to an inhomogeneity within the tank at initial sampling, or that further styrene had been washed into the cargo during the voyage. To investigate the effectiveness of the wall-wash tests, the solvents which were collected from the tests were also analysed by GCMS. These results (0.075 and 0.040 mg/kg) showed that some styrene monomer had been retained on the surface of the tank walls after washing. However, considering the wall surface to tank volume ratio of the tank, this retained styrene level could not account for the increased levels between the loaded sample and the discharge sample of tank WS8.

There was much discussion within the group as to the cause of the retention of the previous cargo. It was agreed that even for a smooth stainless steel tank, under microscopic examination, the surface would exhibit the peaks and troughs of the microstructure. It is possible that the surface of the tank was rough enough that some cargo was retained within troughs of the surface. It was decided to investigate this possibility using a third voyage and a suitable vessel.

THIRD TRIAL

This trial utilised a discharging and loading cycle on the NCC ASIR. Again the previous cargo was styrene monomer and the subsequent non-reactive cargo was fatty acid methyl ester (FAME). After cleaning, wall-wash tests were carried out on four of the stainless steel tanks. These tests were carried out using acetone and methanol as the solvents. These tests showed that all the tanks were suitable for the loading of high purity chemicals. A further series of wall-wash tests were carried out in these tanks after the tank walls had been cleaned and sprayed with solvents. Following the spraying exercise, the wall-wash tests again showed that the tanks were fit to load high purity chemicals. However, the chemical analysis of the wall-wash solvents showed reduced levels of styrene monomer following the spraying operation. These results indicate that there is a certain level of styrene monomer retained on the walls of the tank after the standard wash procedure, and that this level can be reduced by a solvent spray of the tank walls. Thus, spraying is not as efficient as the washing of the walls which is an inherent part of wall-wash test itself. The report (No. 10657603) of this trial is attached (Annex 5).

Samples taken during the loading operation and on arrival at the voyage destination showed that any contamination of the FAME by the previous cargo was below the limit of delectability of the method (<0.05 mg/kg). It should be noted that the true level could be well below this limit of detection. This result confirmed that the increase in contamination during the voyage of the second trial was not due to contamination of the cargo by any residue from the walls during the voyage. A useful experiment was carried out by deliberately spiking the solvents used for the wall-wash tests. These showed that the limit of detection for previous cargoes in the wall-wash solvent is about 0.5 mg/kg, which is an order of magnitude above the limit of detection using GCMS.

CONCLUSIONS

From the above series of trials, the group concluded that;

 potentially serious contamination from the majority of FOSFA banned previous cargoes can be detected, and therefore prevented, by the use of readily available standard on-board tests;  stainless steel tank surfaces can be cleaned to such a degree that contamination

Agenda for the CTC # 31 Page 29 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith levels caused by any surface retention of certain previous cargoes and may still meet the demands of the food industry; in the cases examined, contamination from residues in the associated pumps and lines was at such a low level that it may be acceptable to the food industry, but is identified as a different risk to the use of wall wash tests.

The group considered that while many years ago, the detectable presence of a contaminant meant that the consignment could be rejected. This is now not the case. As chemical analysis techniques have improved, it is now possible to measure extremely low levels of contamination using sophisticated laboratory equipment. It has long been accepted within various national legislations that certain levels of carcinogenic and toxic materials are inevitable in foodstuffs. This factor should be kept in mind when considering the possible level of contaminations from previous cargoes.

Agenda for the CTC # 31 Page 30 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith Annex 1 - Flow Chart of Scheme

Agenda for the CTC # 31 Page 31 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith Annex 2 – Overview of Banned List Cargoes and Test Availability

Solubility Solubility Solubility ThOD PT COD Miscibility in in in water calc Substance Test test test methanol acetone g/100g (g/g) Acetone cyanohydrin soluble soluble (ACH; alpha- reactive / 2,07 hydroxyisobutyronitrile; soluble 2-methyllactonitrile) Acrylic acid (acroleic reactive soluble Soluble X X 1,33 acid; propenoic acid) Acrylonitrile (ACN; 2- soluble soluble propenenitrile; vinyl 7,3 X X 2,26 cyanide) Adiponitrile (1,4- soluble soluble 4,5 X 2,37 dicyanobutane) Aniline (phenylamine; soluble soluble 3,4 X 2,58 aminobenzene) n-Butylacrylate reactive soluble 0,1 X X 2,25 tert-Butylacrylate reactive soluble X X 2,25 Carbon tetrachloride soluble soluble (CTC; 0,1 0,21 tetrachloromethane; perchloromethane) Cardura E (tradename for a glycidyl esters of versatic 911 acid) Cashew nut shell oil (CNSL; cashew nut shell liquid) Dibutylamine soluble soluble soluble X 2,97 Diethanolamine (DEA; soluble soluble di(2-hydroxyethyl)- soluble X 1,75 amine) Diethylenetriamine soluble soluble soluble X 2,25 Di-isopropylamine soluble soluble soluble X 3,08 Dipropylamine soluble soluble soluble X 3,08 m-Divinylbenzene (DVB; soluble soluble 0,04 3,07 vinylstyrene) Epichlorohydrin (EPI; soluble 6 1,12 Chloropropylene oxide) Epoxy resins (uncured) soluble Ethyl acrylate reactive soluble 2 X X 1,92 *Ethylene dichloride soluble soluble (EDC; 1,2- slightly (X) 0,97 dichloroethane) 2-Ethylhexyl acrylate reactive soluble insoluble X X 2,6 Ethanolamine (MEA; soluble soluble monoethanolamine; colamine; 2- soluble X 1,7 aminoethanol; 2- hydroxyethylamine) Ethylenediamine (1,2- soluble soluble soluble X 2,13 diaminoethane)

Agenda for the CTC # 31 Page 32 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith Furfuryl alcohol (furyl soluble soluble soluble X X 1,79 carbinol) soluble soluble reactive / Glutaraldehyde X 1,92 soluble Hexamethylenediamine soluble (1,6-diaminohexane; 1,6- soluble X 3,3 hexanediamine) Isocyanates

Agenda for the CTC # 31 Page 33 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith Solubility Solubility Solubility ThOD PT COD Miscibility in in in water calc Substance Test test test methanol acetone g/100g (g/g)

Agenda for the CTC # 31 Page 34 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith These include: Toluene di-isocyanate reactive soluble reactive 1,75 (TDI) Polyphenyl reactive soluble polymethylene reactive isocyanate (PAPI) Di-phenyl methane di- reactive soluble reactive 2,11 isocyanate (MDI) Methyl isocyanate reactive soluble reactive 1,26 Lube oil additives Methyl acrylate soluble soluble 6 X X 1,67 Methyl methacrylate soluble soluble 1,5 X X 1,92 monomer Methyl styrene monomer soluble soluble 0,01 X 3,11 (vinyl toluene) alpha-Methyl styrene soluble soluble insoluble X 3,11 monomer (AMS) para-Methyl styrene soluble soluble 0,01 X 3,11 monomer (PMS) Morpholine (tetrahydro- soluble soluble soluble X 2,2 1,4-oxazine) Morpholine ethanol (n- X 2,01 hydroxyethylmorpholine) Nitric acid (aqua fortis; reactive engravers acid; azotic soluble acid) Perchloroethylene (PCE; soluble soluble perc; 0,015 0,39 tetrachloroethylene) Phthalates soluble These include: Di-allyl phthalate (DAP) soluble soluble insoluble X 1,75 Di-iso decyl phthalate soluble soluble insoluble X 2,69 (DIDP) Di-iso nonyl phthalate soluble soluble insoluble X 2,64 (DINP) Di-iso octyl phthalate soluble soluble insoluble X 2,58 (DIOP) Di-octyl phthalate (DOP) soluble soluble insoluble X 2,58 n-Propylamine soluble soluble soluble X 2,84 Propylene oxide (Methyl soluble oxirane; 1,2- 41 2,2 epoxypropane) Pyridine soluble soluble soluble X 1,52 **Styrene monomer soluble soluble (vinylbenzene; 0,03 X 3,07 phenylethylene; cinnamene) Tall oil (tallol; liquid soluble rosin) Tall oil fatty acid Slightly soluble equivalent to ASTM type soluble insoluble III Transformer oils of PCB soluble type

Agenda for the CTC # 31 Page 35 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith Vinyl acetate monomer reactive soluble 2,3 X X 1,67 (VAM) Vinyl chloride monomer soluble soluble (VC; chloroethane; 0,3 1,41 chloroethylene)

Solubility in methanol Soluble indicates that the substance is sufficiently soluble to use methanol as a wall wash medium. Reactive indicates that the substance is (slightly) reactive with methanol, conversion to an other substance is likely. Example1: 2-Ethylhexyl acrylate will be converted to methyl acrylate when sufficient time is available for the reaction. Example 2: Isocyanates will react to form insoluble substances.

Solubility in acetone Soluble indicates that the substance is sufficiently soluble to use methanol as a wall wash medium. Solubility in water g/100g A number denotes the solubility of the substance in grams per 100 grams of water. PTT test Potassium Permanganate Time Test (acetone or methanol as solvent for the wall wash). Chemical Oxygen Demand (water as solvent for the wall wash COD test test)

Miscibility test Water miscibility test (acetone as solvent for the wall wash). ThOD Theoretical Oxygen Demand; the amount of oxygen needed to oxidize the substance to water and carbon dioxide, the nitrogen in nitrogen containing compounds is oxidized to N2. Substances with a ThOD > 1 g/g may be detected using the COD test with an estimated detection limit of 5-10 mg/litre wall wash liquid (water).

= The substance may be detected by the marked wall wash X test. (X) = To be confirmed that the substance may be detected by the marked wall wash test.

Agenda for the CTC # 31 Page 36 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith Agenda for the CTC # 31 Page 37 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith Agenda for the CTC # 31 Page 38 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith Agenda for the CTC # 31 Page 39 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith Agenda for the CTC # 31 Page 40 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith CHEMICAL LABORATORY ’’Dr. A. VERWEY’’

32 COOLHAVEN POSTBOX 6003 3002 AA ROTTERDAM

ANALYSTS AND CONSULTING CHEMISTS SAMPLERS AND WEIGHERS BULKOIL-SURVEYORS

TELEPHONE:010-4761055E-MAIL:[email protected]:010-4770336TELEX:22080verwynl

Rotterdam, 18 july 2005

To Whom it may concern

REPORT No. 10520396

The scope of this report is to indicate the levels of contamination with previous cargoes in relation to FOSFA rules.

For the test reported, a FOSFA banned cargo, styrene (monomer), was used. The cargo loaded after cleaning of the styrene tank was a non reactive cargo: Acetone. The cargo was transported in a stainless steel tank, equipped with stainless steel pump and line.

The rest was done onboard of mt BOW CHAIN berthed in Rotterdam, tank WS8 was used for this test. From CP10, only wall wash samples were taken and analyzed since after cleaning this tank was loaded with mixed xylene, this cargo is unsuitable to reliably determine extremely low quantities of styrene monomer with GC/MS methods due to the presence of interfering substances.

Procedure

1) After discharge of the styrene, ships personnel cleaned the tanks according to the procedures mentioned in this report.

2) Tanks were inspected and tested by a representative of Chemical Laboratory dr. A. Verwey Rotterdam. Wall wash samples were taken using acetone and methanol. The acetone and methanol wall washes were analyzed using the Permanganate Time Test (PTT). The permanganate time test is an industry standard to test tanks prior to loading of high purity chemicals. Styrene contamination in acetone or methanol will be detected by this test. A test result of at least two hours is required when testing with acetone and at least 50 minutes when testing with methanol. The methanol wall washes were also tested

Agenda for the CTC # 31 Page 41 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith using a UV (ultra violet) spectroscopic test.

3) During the acetone loading operation at Vopak Botlek samples were taken, by a representative of Chemical Laboratory dr. A. Verwey, from the barge VOPAK KEPLER and on board of the BOW CHAIN at the manifold, at the pump stack and from the first foot of the tank loaded (WS8). On completion of the loading an average sample was taken from the cargo tank.

4) On arrival in Kandla average samples from the acetone and mixed xylene cargo tanks were taken by J.B Boda Surveyors. The cap sealed samples were kept on board and on arrival in Dubai sent to our Rotterdam laboratory.

5) The acetone samples from the barge, pump stack, cargo tanks, the first foot sample and the wall washes were analyzed on Styrene (monomer) content by gas chromatography mass spectrometry (GCMS).

Agenda for the CTC # 31 Page 42 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith -2-

Form. 4002 All orders are executed on our latest conditions filed at the Court of Justice of Rotterdam. Precision data of the test method(’s), when applicable, will be supplied on request. Date 13 July 2005 Chemical Laboratory ’’Dr. A. Verwey’’ Report no.: 10520396

Tank cleaning procedures

According to the chief officer of the mt BOW CHAIN the following cleaning methods were used:

WS8: -2 hrs. cold river water (density 1.004). -1 hr. hot river water (density 1.004) at 75°C. -Fresh water rinsing. -1 hr. recirculation of fresh water and metal brightener at ambient

temperature via pump stack. -1 hr. river water. -20 min. fresh water.

CP10:-Freshwaterrinsing-UsedasStyreneslobtank- 2hrs.coldriverwater(density1.004)-2hrs.hotriverwater(density1.004)at75°C

Tank inspection in Rotterdam

Tanks WS8 and CP10 of mt BOW CHAIN were inspected and wall wash samples taken on April 12th 2005 starting 14.00 hrs, at Shell Nederland B.V. Pernis.

The tanks mentioned were visually clean and odour free. Wall wash samples were taken from a total of 1 m2 on all 4 bulkheads using acetone and methanol.

Results of the acetone wall wash tests:

Potassium Permanganate Time test @ 25°C

WS8 more than 3 hrs CP10 more than 3 hrs

Results of the methanol wall wash tests:

Agenda for the CTC # 31 Page 43 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith Potassium Permanganate UV test Time test @ 15°C

WS8 100 minutes Passed CP10 120 minutes Passed

Conclusion of the inspection: The inspected tanks are fit to load cargoes of high purity.

Overview of the acetone samples taken

1) 14.04.2005 23.00 hrs Composite barge Vopak Botlek VOPAK KEPLER before loading

2) 15.04.2005 Manifold sample Vopak Botlek

WS8 3) 15.04.2005 Pumpstack WS8 Vopak Botlek 4) 15.04.2005 First foot WS8 Vopak Botlek 5) 15.04.2005 Average WS8 Vopak Botlek

After loading 6) 14.05.2005 WS8 Discharging Kandla, India

Samples 1, 2, 3, 4 and 5 were taken by a representative of Chemical Laboratory dr. A. Verwey.

Sample 6 was taken by J.B Boda Surveyors.

Form. 0004 Date 13 July 2005 Chemical Laboratory ’’Dr. A. Verwey’’ Report no.: 10520396

Analyses results of the acetone samples

Styrene monomer content

(GCMS) (mg/kg) 1) less than 0.005 2) 0.055 3) 0.330 4) 0.017 5) 0.005 6) 0.045

Analyses results of the acetone wall wash samples

Styrene monomer content

(GCMS) (mg/kg) WS8 0.075 CP10 0.040

Chemical Laboratory Dr A. Verwey

M.H. de Heer

Form. 0004 CHEMICAL LABORATORY ''Dr. A. VERWEY''

32 COOLHAVEN Rotterdam, 29 May 2006 POSTBOX 6003 3002 AA ROTTERDAM

ANALYSTS AND CONSULTING CHEMISTS To Whom it may concern SAMPLERS AND WEIGHERS BULKOIL-SURVEYORS

TELEPHONE: 010 - 476 10 55 E- MAIL: [email protected] TELEFAX: 010 - 477 03 36 TELEX: 22080 verwy nl

REPORT No. 10657603

Agenda for the CTC # 31 Page 45 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith The scope of this report is to indicate the levels of contamination of stainless steel tanks after cleaning and the subsequent levels of contamination of cargoes loaded in relation to FOSFA rules.

For the test reported, a FOSFA banned cargo, styrene (monomer), was used. The cargo loaded after cleaning of the styrene tanks were Methyl Esters and Bio Diesel. The cargo was transported in a stainless steel tank, equipped with stainless steel pump and line.

The test was done onboard of mt NCC ASIR, Tanks 3P, 3S, 10P and 10S were empty from styrene monomer. These tanks were cleaned by the vessels crew. After the cleaning procedures the tanks were wall washed by an appointed surveyor. The same surveyor took loading samples of the Methyl Esters and Bio Diesel.

Procedure

1) After discharge of the styrene, ships personnel cleaned the tanks according to the procedures mentioned in this report.

2) Tanks were inspected and wall washed by a representative of BSI Inspectorate Pasadena. Wall wash samples were taken using acetone and methanol. A total of about 1 m2 of tank surface from all four bulkheads was sampled for each wall wash test. The total volume of the wall wash sample was 250 ml. Two designated areas were, as a trial cleaning operation, sprayed with methanol and the other area with Methyl Ethyl Ketone (MEK). After that operation, wall wash samples were taken again from those areas. The sealed samples were delivered to our Rotterdam laboratory.

3) During the loading operation at Vopak Deerpark samples were taken from the cargoes loaded. Sampling was done by a representative of BSI Inspectorate. The sealed cargo samples were delivered to our Rotterdam laboratory.

4) On arrival in Rotterdam, a sample was taken from the ships tank by a representative of chemical laboratory Dr. A. Verwey.

Form. 4002 All orders are executed on our latest conditions filed at the Court of Justice of Rotterdam. Precision data of the test method(‘s), when applicable will be supplied on request. Date 29 May 2006 Chemical Laboratory ''Dr. A. Verwey'' Report: 10657603 Page 2

5) The acetone and methanol wall washes were analysed using the Permanganate Time Test (PTT). The permanganate time test is an industry standard to test tanks prior to loading of high purity chemicals. Styrene contamination in acetone or methanol will be detected by this test. A test result of at least two hours is required when testing with acetone and at least 50 minutes when testing with methanol. The methanol wall washes were also tested using an UV (ultra violet) spectroscopic test. The acetone wall washes were analysed on styrene monomer content using a GC/MS method.

6) The cargo samples were analysed on Styrene content using a GC/MS headspace method.

Tank cleaning procedures

According to the ship owner the following tank cleaning procedures were used:

Tank 2P: 2 hours cold sea water; 1 hour hot sea water @ 70°C; Fresh water and ventilate. Tank 3P: 2 hours cold sea water; 1 hour circulation with 2-5% Enviromate 2000 in fresh water @ 50 – 70°C; 2 hours warm sea water; Fresh water and ventilate. Tank 2 hours cold sea water; 10P: 1 hour circulation with Lead Clean / Hydrocarbon Remover in Fresh water @ 40 – 50 °C; 2 hours warm sea water; Fresh water and ventilate. Tank 2 hours cold sea water; 10S: 1 hour circulation with 2% KT-Solv in fresh water @ 50 – 70°C; 2 hours warm sea water; Fresh water and ventilate.

All cargo lines, stripping lines, drop lines, vent lines etc. were thoroughly cleaned.

Wall wash sampling

The cleaned cargo tanks were wall washed while the vessel was at Westway Terminal, Houston Texas. Wall wash samples were taken as described in the “procedure” paragraph under 2.

Form. 0004 Date 29 May 2006 Chemical Laboratory ''Dr. A. Verwey'' Report: 10657603 Page 3

Wall wash samples and results.

Tank Wall Description Seal Tag PPT UV Styrene Wash no. no. test test content Solvent (min) (mg/l) 0076 04322 Blank Acetone >145 0,0003 3 6 0018 04323 10P Acetone >145 0,045 1 0

Agenda for the CTC # 31 Page 48 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith 0097 04323 10P Acetone After MEK spray >145 0,009 2 4 After MeOH 0023 04324 10P Acetone >145 0,005 spray 0 1 0056 04322 10S Acetone >145 0,052 6 9 0082 04323 10S Acetone After MEK spray >145 0,011 4 3 After MeOH 0057 04324 10S Acetone >145 0,020 spray 8 0 0019 04322 2P Acetone >145 0,150 1 7 0089 04323 2P Acetone After MEK spray >145 0,007 8 1 After MeOH 0020 04323 2P Acetone >145 0,012 spray 7 5 0022 04322 3P Acetone >145 0,125 7 8 0018 04323 3P Acetone After MEK spray >145 0,010 6 2 After MeOH 0018 04323 3P Acetone >145 0,007 spray 3 6

0062 04322 Blank Methano 65 Passed 7 5 l Methano 0068 04324 10P 95 Passed l 1 5 Methano 0042 04325 10P After MEK spray 65 Passed l 1 3 Methano After MeOH 0070 04324 10P 65 Passed l spray 0 9 Methano 0069 04324 10S 80 Passed l 1 4 Methano 0075 04325 10S After MEK spray 65 Passed l 3 2 Methano After MeOH 0019 04324 10S 95 Passed l spray 0 8 Methano 0066 04324 2P 95 Passed l 8 2 Methano 0078 04325 2P After MEK spray 80 Passed l 0 0 Methano After MeOH 0026 04324 2P 65 Passed l spray 4 6 Methano 0084 04324 3P 95 Passed l 4 3 Methano 0067 04325 3P After MEK spray 65 Passed l 6 1 Methano After MeOH 0071 04324 3P 80 Passed l spray 8 7

MEK = Methyl Ethyl Ketone MeOH = Methanol PPT = Potasium Permanganate Time

Loading samples

Samples taken at Vopak Deerpark TX Date 2/15/06 Inspector JH Vessel NCC ASIR

Agenda for the CTC # 31 Page 49 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith Location taken Cargo Seal No Tag No Styrene content (mg/kg) Dockline Bio Diesel 317791 659202 ND < 0,05 Manifold Methyl Esters 317539 659204 ND < 0,05 Pumpstack 3P Methyl Esters 317602 659206 ND < 0,05 1st Foot 3P Methyl Esters 317032 659208 ND < 0,05 Vessel Final 3P Methyl Esters 317344 659210 ND < 0,05 Pumpstack 3S Methyl Esters 317216 659417 ND < 0,05 1st Foot 3S Methyl Esters 317805 659425 ND < 0,05 Vessel Final 3S Methyl Esters 317097 659413 ND < 0,05 Pumpstack 10S Bio Diesel 317377 659420 ND < 0,05 1st Foot 10S Bio Diesel 317276 659426 ND < 0,05 Vessel Final 10S Bio Diesel 317156 659422 ND < 0,05

ND = Not detectable

-4- Form. 0004

Agenda for the CTC # 31 Page 50 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith Date 29 May 2006 Chemical Laboratory ''Dr. A. Verwey'' Report: 10657603 Page 4

Arrival sample

Vessel Arrival 10P Product: Methyl Esters Sampling Date: 8th March 2006 Vessel: NCC Asir Berth: Vopak Vlaardingen

The sample was taken by a representative of chemical laboratory Dr. A. Verwey.

Styrene content: ND < 0,05 mg/kg.

The other cargo tanks, subject of this tests, loaded with methylesters and biodiesel were already discharged by the time our surveyor boarded the vessel.

Detection limit of the field tests

Solvent Description Potasium UV test Permanganat e time test (min) Blan Methano 1 mg/kg 55 Not k l styrene added Passed Blan Acetone 1 mg/kg 130 k styrene added Blank 65 Passed 0.1 mg/kg Methano styrene added l Blank Acetone 0.1 mg/kg >145 styrene added

Addition of 1 mg/kg (ppm w/w) styrene to the solvents used as wall wash solvent during these tests lowers the Potasium Permanganate Time (PPT) test with 10 (for methanol) and 15 min. or more (for acetone). The UV test shows a distinct absorption band caused by styrene. Lower concentrations of styrene will not be detected using the PPT test or the UV test.

Chemical Laboratory Dr. A. Verwey

M.H. de Heer Form. 0004

Agenda for the CTC # 31 Page 51 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith Appendix 6 INTERTANKO Bottle neck Group report “ Rules Regulations Guidance & Consistency” Task Group Inter-Industry Working Group

12th October 2005 Our Ref.: HS-1699922/1150001

RRGC Minutes #2

Venue Stolt-Nielsen Transportation Group B.V. Westerlaan 5, Haven Nº 190 3016 CK Rotterdam The Netherlands

Started 10:00 Completed at 15:30

Agenda for the CTC # 31 Page 52 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith INTERTANKO’s Anti-Trust/Competition law Compliance Statement

The meeting was conducted under INTERTANKO’s Anti-Trust/Competition Guidelines.

INTERTANKO is firmly committed to maintaining a fair and competitive environment in The world tanker trade, and to adhering to all applicable laws which regulate INTERTANKO’s and its members’ activities in this market. These laws include the anti trust and competition laws, which the US, the European Union and many nations of the World have adopted to preserve the free enterprise system, promote competition and Protect the public from monopolistic and other restrictive trade practices. This meeting will be conducted in compliance with these laws and in accordance with INTERTANKO’s Anti a trust/competition law guidelines.

Attendance List to “Part A” of the meeting:

Company First Name Last Name Attending OCIMF Mark Fortnum Yes Odfjell Seachem Svend Foyn-Bruun Yes Stolt Nielsen Scott Moffitt Yes Iino Kaiun Kaisha Ltd Michihisa Moriya Yes Det Norske Veritas AS Otto Nyquist Yes Brostrom Tankers AS Jean-Loup Thuillier Yes Odfjell Seachem Toralf Sorenes Yes Broere Shipping BV Roel Vermeulen Yes Stolt Nielsen Lars Modin Yes Stolt Nielsen Bill Millar Yes INTERTANKO Howard Snaith Yes

Apologies received from: Luciano Casella - Amit Jain – Unix Lines Tim Knowles IIWG Chairman John Murray - ICS Janet Strode-IPTA Jos Verlinden –CEFIC Bjarne Augestad - Seatrans

Terms of reference for the RRGC Group:

The Task Group will review each of the issues put to them by the IIWG and identify solutions to each item. These will be put to the IIWG for review at subsequent meetings.

Introduction.

The RRGC group Chairman (Lars Modin) gave a verbal overview to the group regarding the reasons for work within this group been on hold up until now and the various recent discussions with regards to the agenda for today’s meetings.

Regarding today’s agenda the Chairman explained that although agenda was approved by the IIWG Chairman prior to its circulation, there had been some considerable discussion by some other members of the IIWG regarding what the remit of this group was, and what this group

Agenda for the CTC # 31 Page 53 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith could discuss at today’s meeting. A proposal was therefore put forward by the RRGC chairman to this group that we discuss agenda items 1, 5, and 8, as “Part A” of today’s meeting, (i.e. items which the whole IIWG has agreed the RRGC group can discuss), should then time permit within today’s meeting then the RRGC group agreed it would discuss as Part “B” of today’s meeting agenda items 2, 3,4,6,7 as approved by the IIWG Chairman. The Part “B” discussions today would be passed to the IIWG for their information and action as they may feel necessary or not.

Part A

Agenda Item 1. The RRGC group asked if it was possible to be given a copy of the full Data analysis report to assist them in today’s discussions, because the RRGC group was of the view that this was an important document to assist them directionally in their discussions and focus – it was explained that the data analysis report was not yet finalised and still undergoing final drafting, but also importantly that the IIWG has not issued a remit to the RRGC to circulate the whole Data analysis report to the RRGC Group, only an extract from it . Wishing to avoid any conflicts within the IIWG regarding this aspect, it was therefore agreed that guidance should be sought from the IIWG Chairman (Tim Knowles). Phone contact was attempted with the IIWG chairman on the main and mobile contacts but he was unfortunately on vacation and not available. Unable to seek advice one way or the other the RRGC group therefore agreed to “not” circulate the draft Data Analysis report at this time, it was agreed however that the data analysis spreadsheet could be handed out at today’s meeting on the basis that this was returned at the end of today’s proceedings – the RRGC Chairman also reminded the RRGC group of the strict confidentiality guidelines that the IIWG was operating under which also applied to the group. The RRGC Chairman then verbally introduced the data analysis spreadsheet report.

At the request of the RRGC Group chairman, Svend Foyn-Bruun gave the RRGC a power point presentation outlining items which do create complexities and confusions within SOLAS and the IBC/BCH Code and areas of inconsistency.

Following the presentation, the RRGC was asked for its views regarding the presentation and their views pertaining to the question of complexity of the SOLAS, IBC/BCH codes/regulations etc.

Proposed actions to the IIWG arising from this item.

 Tank Cleaning/Gas Free/Inert Flow Plans The RRGC group proposed to the IIWG that it would be beneficial for each company to produce a flow plan, covering the whole operation of tank cleaning, inerting and gas freeing aimed at simplifying the various complexities for tank cleaning, gas freeing and venting. The flow plan although generic in its format should be ship specific based upon the date the ship was built, verifying within it the inerting and gas freeing requirements on a ship specific basis. DNV (representing IACS) produced for the group an overview of existing inert gas requirements for oil tankers and Chemical tankers and tank venting and gas free requirements, see Annex 1. The group agreed that this document highlighted very well the complexities of the inerting and gas freeing requirements that exist. The concept therefore is that the ship specific flow plan would start with the year the ship was built and then follow on to indicate the

Agenda for the CTC # 31 Page 54 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith inerting, tank cleaning and venting requirements as appropriate, taking into account the various grandfather clauses which exist within SOLAS and the IBC/BCH Code.

 Cargo Inert List The RRGC proposes to the IIWG that within the IBC code the inert gas column within Chapter 17 (column “h”) could be expanded to include additional cargoes that might require inert gas, as a cargo specific aspect, as opposed to ship specific aspect from the safety aspect for low flash products. The RRGC group recommends to the IIWG that this concept be given further consideration and perhaps consider which additional cargoes should be included and what the parameters for inert gas might be.

 Fixed/portable gas free/venting arrangements. Reference: IBC Code 8.5 Reference: SOLAS II-2 Reg16.3.2

The IBC Code section 8.5, identifies requirements for venting arrangements for gas freeing cargo tanks used for cargoes other that those for which open venting is permitted, either through the outlets described in the IBC code 8.3.3 or 8.3.4 or, through outlets at least 2m above the cargo tank deck with a vertical efflux of at least 30 m/s or, via outlets at least 2m above the cargo tank deck with a vertical efflux velocity of at least 20 m/s protected by flame screens, to reduce the flammable concentration at the outlets to 30% of the LFL or in the case of toxic cargoes the vapour concentration does not present a significant hazard, thereafter gas freeing may be permitted at deck level.

However, the RRGC noted that not all vessels are fitted with “fixed” arrangements to meet the requirements within the above noted references; ships without fixed arrangements are outfitted with portable venting arrangements which the RRGC group considered to be both inefficient and cumbersome to use in practice. The RRGC concluded that despite the requirements (IBC code 8.5 and SOLAS Chapter II-2 regulation 16 3.2) - in practice it was not uncommon for cargo tank venting to take place at deck level in the case (where ships were outfitted with “portable” venting arrangements), because it was quicker and easier than using the potable venting equipment.

The RRGC therefore proposes to the IIWG that the requirements within sections 8.5 of the IBC code SOLAS Chapter II-2 regulation 16 3.2 be further addressed regarding inconsistencies with regard to fixed and portable venting arrangements for gas freeing.

Agenda Item 5

 Provision of information to ships crews regarding static electricity, “Safety in Chemical Tankers” (ICS). The RRGC held the view that the booklet was basically aimed at crew members as apposed to ships officers, and that the existing information within this booklet did need to be enhanced with regard to static, but also that the booklet as a whole would benefit from updating. However, the RRGC also believed that the section within the ICS Chemical tanker safety guide gives a good overview in this respect.  The RRGC would also recommend the Human Element Group should consider the inclusion if static within its review when considering appropriate STW training.

Agenda Item 8

Agenda for the CTC # 31 Page 55 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith  As ISGOTT is waiting for publication, pending final agreement with regards to the tank cleaning aspect, the RRGC group held the view that the RRGC group could not discuss inconsistencies within ISGOTT at this time.

 With regards to the ICS Chemical Tanker Safety Guide – the RRGC group held the view that in view of the pending ISGOTT 5th edition it was thus not possible to conclude on inconsistencies between ISGOTT and the ICS Chemical Tanker Safety Guide.

 A discussion was held regarding guidance contained within the ICS CTSG (Chemical Tanker safety Guide), particularly relating to chemical spraying – however the RRGC group agreed that the mandate from the IIWG regarding Agenda Item 8 related only to “inconsistencies” and thus a discussion of chemical spraying under this agenda item at this time was outside the mandate given to the RRGC.

As the discussion on agenda Items 1, 5 and 8 were now completed; the OCIMF representative left the meeting at this stage and stated he could not participate within the discussions regarding agenda items 2,3,4,6 & 7.based upon instructions from his principals.

Part B

Those participating in this section of the meeting are listed as follows:

Attendees to Part B

Company First Name Last Name Attending Odfjell Seachem Svend Foyn-Bruun Yes Stolt Nielsen Transportation Group Scott Moffitt Yes Iino Kaiun Kaisha Ltd Michihisa Moriya Yes Det Norske Veritas AS Otto Nyquist Yes Brostrom Tankers AS Jean-Loup Thuillier Yes Odfjell Seachem Toralf Sorenes Yes Broere Shipping BV Roel Vermeulen Yes Stolt Nielsen Transportation Group Lars Modin Yes Stolt Nielsen Transportation Group Bill Millar Yes INTERTANKO Howard Snaith Yes

Agenda Item 2.

 The RRGC group was in agreement that the monitoring of a cargo tank atmosphere during tank cleaning was difficult with today’s technology and thus a conflict did exist between the requirements to monitor the tank atmosphere, and the difficulty to be able to easily monitor it during the washing period.

Agenda Item 3 & 4  The RRGC group took note that these two items as they are under discussion within other groups within the IIWG

Agenda for the CTC # 31 Page 56 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith Agenda Item 6  The RRGC group suggests that perhaps the dangers associated with the use of “non- approved” equipment inside cargo tanks, (for example unofficial tank stripping equipment), could be contained within the revised ICS “Safety in Chemical Tanker Booklet” revision and asks the IIWG to consider this suggestion.

Agenda Item 7  The RRGC was of the opinion that the various wall wash test (WWT) standards which exist for several high quality big movers (Annex II) products vary considerably from port to port and are believed to be excessively high in comparison to the product loaded. One type of test proposed as an alternative to the WWT that could be undertaken in place of the WWT, (where necessary) is a test that uses the wash water from the cargo tank – known as the COD test. The RRGC group proposes to the IIWG that the COD test could be assessed as a potential alternative (where required) to the WWT, the COD test which would also reduce the number of tank entry requirements to take the WWT.

 A further suggestion from the RRGC group to the IIWG to simplify this problem would be the creation of an industry standard for tank cleanliness, different levels of cleanliness could be described as “A” “B” “C” etc depending upon the level of cleanliness required, Suitable realistic standards could be developed possibly by CEFIC for example that could meet the required standards depending upon the type of cleanliness required. The RRGC offers this suggestion for further consideration to the IIWG

Agenda for the CTC # 31 Page 57 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith Annex 1 Summary of Chemical & Oil Tanker Tank Venting & Gas Freeing Regulations (SOLAS/IBC/BCH)

Agenda for the CTC # 31 Page 58 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith Agenda for the CTC # 31 Page 59 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith Agenda for the CTC # 31 Page 60 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith Agenda for the CTC # 31 Page 61 of 61 To be held in London 17th October 2007 Issue No. 1 Our Ref.: HS-22713/1400000 Approved by: H.N.Snaith