How IMO OSV Chemical Code affects US offshore supply vessels
As the IMO’s 2021 to the IBC Code (MEPC.318(74) and MSC.460(101)) are entering into force on 1st January, offshore supply vessels that intend to carry NLS on international voyages after that date will be required to meet the carriage requirements listed in the OSV Chemical Code or approved equivalents, USCG advised through a new information bulletin (MSIB 24-20).
For offshore supply vessels (OSVs), the 2021 IBC Code amendments will be implemented through IMO resolution A.1122(30) and the updated Code for the Transport and Handling of Hazardous and Noxious Liquid Substances in Bulk of Offshore Supply Vessels (the OSV Chemical Code).
The OSV Chemical Code provides the design and construction standards for an OSV to carry any of the products listed in the IBC Code. These new amendments will affect most of the carriage requirements for the products listed in ENG Policy Letter 03-12.
Therefore, OSVs that intend to carry NLS on international voyages after 1 January 2021 will be required to meet the carriage requirements listed in the OSV Chemical Code or approved equivalents.
Furthermore, the carriage requirements of the provisionally assessed tradename mixtures listed in the MEPC.2/Circular may change, as the IMO is currently reevaluating many of these products.
For example, under the 2021 IBC Code, both methyl alcohol (methanol) and toluene will be considered toxic. Therefore, any tradename product that contains either of these two products will also likely be considered toxic. Products that must be carried on a type 2 ship will not be authorized for carriage onboard a type 3 ship.
OSV operators that intend to carry products listed in the IBC Code or MEPC.2/Circular in bulk on international voyages are highly encouraged to contact CG-ENG at their earliest convenience. A member of my staff will evaluate your particular circumstances and determine if any alterations to your vessel are necessary.
OSV operators that intend to carry noxious liquid substances (NLS) on domestic routes only must meet the requirements of either 46 CFR 125.120 (for vessels less than 6,000 GT) or 46 CFR 125.125 (for vessels of at least 6,000 GT).
Per ENG Policy Letter 03-12, an OSV is authorized to carry the 30 products listed in Appendix I of the policy, while those vessels covered by 46 CFR 125.125 may, in addition, carry non-toxic products suitable for a type-3 ship as defined by the IBC Code. The carriage of any product requiring a type 2 ship for an OSV on a domestic route is not currently authorized.
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