14.7. Transport in Bulk According to Annex II of MARPOL and the IBC Code
This section provides information on the requirements for the bulk transport of dangerous goods by sea according to Annex II of the International Convention for the Prevention of Pollution from Ships (MARPOL) and the International Bulk Chemical Code (IBC Code). It covers classification, operational requirements, and environmental considerations for the carriage of noxious liquid substances in bulk.
Important for SDS compliance: Section 14.7 of a Safety Data Sheet must include information on bulk transport requirements when applicable. This information is mandatory under REACH Annex II for substances or mixtures transported in bulk according to IMO instruments.
Understanding MARPOL Annex II and the IBC Code
MARPOL Annex II
MARPOL Annex II regulates the control of pollution by noxious liquid substances carried in bulk. It:
- Sets discharge criteria for the disposal of residues into the sea
- Requires pre-wash procedures for certain high-viscosity or solidifying substances
- Mandates the provision of reception facilities at cargo unloading terminals
- Establishes pollution categories for noxious liquid substances
- Requires ships to carry procedures and arrangements manuals
- Mandates cargo record books for documenting operations
IBC Code
The International Bulk Chemical Code provides an international standard for the safe carriage of dangerous chemicals in bulk by prescribing:
- Design and construction standards for ships
- Equipment requirements to minimize risks to the ship, crew, and environment
- Ship type requirements (Type 1, 2, or 3) based on hazard levels
- Tank type specifications (independent, integral, or gravity)
- Venting requirements for cargo tanks
- Environmental control systems for cargo spaces
Pollution Categories
MARPOL Annex II classifies noxious liquid substances into four categories based on their bioaccumulation, biodegradation, acute or chronic toxicity, and effects on marine resources or human health:
| Category |
Description |
Discharge Requirements |
Environmental Impact |
| X |
Major hazard to marine resources or human health |
Prohibited discharge; tanks must be prewashed and residues delivered to reception facility |
Severe and potentially long-lasting damage to marine ecosystems |
| Y |
Hazard to marine resources or human health |
Limited discharge under strict conditions; quantity and concentration restrictions apply |
Significant but generally recoverable impact on marine life |
| Z |
Minor hazard to marine resources or human health |
Less stringent discharge conditions; dilution and speed requirements apply |
Temporary and localized effects on marine environment |
| OS |
Other Substances (not harmful) |
No special discharge requirements beyond general provisions |
Minimal impact on marine ecosystems |
Note: The pollution category determines the stringency of operational discharge requirements, tank cleaning procedures, and waste handling protocols. It directly impacts the environmental footprint of bulk transport operations.
Bulk Transport Classification
Ship Type Requirements
- Type 1: Maximum preventative measures; for most hazardous products
- Type 2: Significant preventative measures; for moderately hazardous products
- Type 3: Moderate preventative measures; for sufficiently hazardous products
Tank Types
- Independent: Self-supporting, not part of ship's hull
- Integral: Part of ship's hull, influenced by hull stresses
- Gravity: Pressure not exceeding 0.7 bar gauge
- Pressure: Pressure exceeding 0.7 bar gauge
Tank Venting Systems
- Controlled: Pressure/vacuum valves to regulate tank atmosphere
- Open: Unrestricted gas exchange with atmosphere
- Safety: High-velocity vent valves to prevent flame ingress
Environmental Control
- Inerting: Maintaining non-flammable atmosphere
- Padding: Liquid, gas, or vapor layer to protect cargo
- Drying: Removing moisture from tank atmosphere
- Ventilation: Natural or forced air exchange
Case Study: Bulk Chemical Tanker Spill (Baltic Sea, 2001)
A chemical tanker carrying acrylonitrile (Category Y substance) collided with a cargo vessel in the Baltic Sea:
- Incident: Damage to cargo tanks resulted in approximately 200 tons of acrylonitrile spilling into the sea
- Environmental impact: Significant toxicity to marine organisms, with fish kills observed up to 15 km from the spill site
- Response measures: Containment booms, chemical dispersants, and mechanical recovery
- Long-term effects: Bioaccumulation in marine food chain, with detectable levels in seafood for over 8 months
- Lessons learned:
- Importance of double-hull design for chemical tankers
- Need for improved vessel traffic management in congested shipping lanes
- Value of rapid response capabilities for chemical spills
- Critical role of proper classification and labeling for emergency response
This incident led to strengthened regulations for the transport of noxious liquid substances in the Baltic Sea area, including mandatory use of pilots and designated shipping lanes for vessels carrying high-risk cargoes.
Operational Requirements
The IBC Code specifies operational requirements for ships carrying noxious liquid substances in bulk:
Temperature Control
- Required for substances that may polymerize, decompose, or become unstable
- Heating/cooling systems must be independent of other ship systems
- Temperature monitoring and alarm systems required
- Emergency cooling capabilities may be necessary
Special Handling
- Procedures for loading, unloading, and tank cleaning
- Requirements for prewash operations for high-viscosity substances
- Ventilation procedures for volatile cargoes
- Specific requirements for water-reactive materials
Vapor Detection
- Fixed or portable systems depending on cargo toxicity
- Continuous monitoring for highly toxic substances
- Alarm systems with audible and visual signals
- Regular calibration and maintenance requirements
Gauging Requirements
- Open: Direct access to cargo through opening
- Restricted: Limited release through small opening
- Closed: No exposure to cargo (e.g., radar, ultrasonic)
- Indirect: Secondary means (e.g., flow meters)
Environmental Protection Measures
Discharge Control
- Strict limitations on where, when, and how cargo residues can be discharged
- Prohibition of discharges in Special Areas designated by IMO
- Minimum distance from shore requirements (usually 12 nautical miles)
- Depth and ship speed requirements during discharge operations
Residue Management
- Mandatory prewash procedures for high-risk substances
- Requirements for efficient stripping systems
- Delivery of residues to port reception facilities
- Documentation of all residue handling in Cargo Record Book
Emission Control
- Vapor emission control systems for volatile organic compounds
- Closed loading systems to prevent atmospheric releases
- Vapor return lines to shore facilities during loading
- Vapor processing systems on some modern vessels
Spill Prevention
- Double-hull requirements for chemical tankers
- Segregated ballast tanks to prevent cargo contamination
- Overflow control systems with alarms and automatic shutdowns
- Emergency shutdown systems for loading/unloading operations
Safety Requirements
Emergency Equipment
- Chemical protective equipment for crew
- Respiratory protection appropriate for carried substances
- Decontamination showers and eyewash stations
- Specialized firefighting equipment for chemical fires
- Spill control equipment suitable for carried cargoes
Fire Protection
- Fixed fire-extinguishing systems appropriate for cargo types
- Fire detection systems in cargo areas
- Specialized firefighting media for chemical fires
- Isolation capabilities for cargo areas
- Emergency cooling for cargo tanks
Personnel Protection
- Specialized training requirements for crew
- Medical first aid equipment specific to carried cargoes
- Decontamination procedures and equipment
- Emergency escape breathing devices
- Toxic vapor detection equipment
Compatibility
- Segregation requirements for incompatible cargoes
- Dedicated piping systems for reactive substances
- Tank coating compatibility considerations
- Cleaning procedures between incompatible cargoes
- Documentation of cargo compatibility assessments
Example SDS Entry for Section 14.7
14.7 Transport in bulk according to Annex II of MARPOL and the IBC Code
- Product name: Acrylic acid (as per IBC Code Chapter 17)
- Pollution category: Y
- Ship type: 2
- Tank type: Integral gravity
- Tank venting: Controlled
- Environmental control: No
- Temperature control required: Yes (< 25°C)
- Special emergency equipment: Yes
For substances not transported in bulk:
14.7 Transport in bulk according to Annex II of MARPOL and the IBC Code
Not applicable - product is not transported in bulk.
Environmental Responsibility: Proper implementation of MARPOL Annex II and IBC Code requirements is essential for protecting marine ecosystems. Noxious liquid substances transported in bulk represent a significant potential threat to marine environments if not properly managed. Compliance with these international regulations helps prevent pollution incidents and ensures sustainable use of ocean resources.
Important: Bulk transport operations must comply with MARPOL Annex II and the IBC Code requirements. Consult current regulations and guidelines for complete requirements. The IBC Code is regularly updated, and the most recent version should always be consulted for accurate information.