A complex set of rules

e safe transport of oils and fats is governed by the regulations of both international and national organisations, as well as industry bodies, and include the proper cleaning of tanks Keith Nuthall

The transport of edible oils and fats by sea is not just big business – it has become increasingly regulated under internati onal conventi on and controlled by industry standards, with a view to improving effi ciencies and reducing the risk of polluti on and contaminati on.

According to US-based Research & Markets’ September report, the global market for fats and oils is projected to generate revenues of US$236.7bn in this year, growing at a compound annual growth rate (CAGR) of 3.8% by 2026 to reach US$285.2bn that year.

In its 2020 trade bulleti n, the United Nati ons Conference on Trade & Development (UNCTAD) esti mates that the value of internati onally traded oils and fats was around US$100bn in 2019.

The successful bulk transport of oils and fats can therefore yield major revenues.

However, getti ng it right, within the law and according to good industrial practi ce is not easy. And this work is becoming more demanding.

For instance, under an Internati onal Mariti me Organisati on (IMO) 2020 regulati on regulati ng its MARPOL Internati onal Conventi on for the Preventi on of Polluti on from Ships, sulphur in ships’ fuel oil has been capped at a maximum of 0.5%. Any changes to MARPOL must be followed closely by the oils and fats shipping sector, given that since 2007, the industry has been brought under IMO regulati on.

Most oils and fats can be carried by IMO classifi ed types 1 and 2 double hull tankers and type 3 single hull tankers, (with the excepti on of palm oil, which can only be carried on single hull vessels if special measures are made to protect this cargo), according to a note from marine insurer Mariti me Mutual.

A spokesperson for the London-based IMO told OFI: “Global vegetable oil producti on amounted to around 209.14M tonnes in 2020/21 and much of that is transported by ship, including in bulk. The safe transport of such oils is paramount for IMO. IMO has adopted a comprehensive body of regulati ons from constructi on to training of seafarers to address the safe transport of all goods by sea.”

She also highlighted 2019 updates (in force since 1 January 2021) to its Internati onal Code for the Constructi on and Equipment of Ships carrying Dangerous Chemicals in Bulk (IBC), which included revised chapters 17 (a summary of minimum safety requirements, such as for venti ng vapours from tanks); 18

Photo: Koole Terminals

A complex set of rules

(a list of products to which the code does not apply – although vegetable oils generally are covered); 19 (the index of products carried in bulk); and 21 (criteria for assigning carriage requirements for products subject to the IBC Code, such as technical rules limiti ng water contaminati on and temperature controls). Code changes aff ecti ng the constructi on and equipment of ships carrying dangerous chemicals in bulk were also adopted.

Discharge of residues

Mariti me Mutual also warned that oils and fats shippers need to follow IMO MARPOL rules on carrying vegetable oils by sea regarding the operati onal discharge of residues into the sea.

This has recently been amended by IMO Resoluti on MEPC.315(74), covering north western and western European seas, including the Balti c and Norwegian Seas. Here, shippers must pre-wash vegetable and palm oil cargo tanks aft er discharging cargo at ports and discharging tank washings onshore. Elsewhere, shippers can conti nue discharging these washings into the sea, as per MARPOL Annex II, which limits volumes, and insists discharges are made underwater, with ships moving at a minimum speed of seven

The transport of oils and fats by sea has become increasingly regulated to improve effi ciencies and reduce the risk of polluti on and contaminati on

knots, at least 12 nauti cal miles from land, and in water depths exceeding 25 metres.

Another set of internati onal rules that edible oils shippers need to follow is the Recommended Internati onal Code of Practi ce for the Storage and Transport of Edible Fats and Oils in Bulk, developed by Codex Alimentarius, the global food regulator. This includes rules on tank constructi on, insisti ng that tanks are made from inert materials such as stainless steel. It also gives guidance on the need to install temperature sensors and control devices to prevent overheati ng of oils and fats in tanks and associated lines. These check minimum and maximum loading and discharge temperatures, which vary according to the cargo type. Codex rules are generally writt en into nati onal regulati ons, notably because they can be cited in disputes at the World Trade Organisati on (WTO) regarding food trading rules.

The Codex committ ee on fats and oils conti nues to refi ne the organisati on’s code of practi ce for the storage and transport of edible oils and fats in bulk. In its planned October meeti ng, for instance, Peru is pressing for a rule that tankers cannot carry edible oils and fats unless operators certi fy that they have not carried leaded liquids in their three previous deliveries.

Tank container standards

Meanwhile, industry standards usually insist that tankers are built to, and operated, under Internati onal Organizati on for Standardizati on (ISO) standards, which were recently updated in 2019.

The key document here is ISO 1496-3:2019 on ‘Freight containers – specifi cati on and testi ng – Part 3: Tank containers for liquids, gases and pressurised dry bulk’.

It sets out the basic specifi cati ons and testi ng requirements for ISO series 1 tank containers loading and unloading liquids by gravity or pressure discharge, moved by road, rail and sea, including interchange between these modes.

These internati onal regulati ons and guidance are welded into industry contract models so that shippers follow good practi ce and comply with the rules, keeping them updated.

Industry contracts

FOSFA Internati onal (the Federati on of Oils, Seeds and Fats Associati ons) is a key player here, with its ‘Carriage of Oils and Fats’ protocols and contract documents. This includes qualifi cati ons of shippers, heati ng instructi ons, banned previous cargoes (that could contaminate oils and fats), and a certi fi cate of compliance, cleanliness and suitability of a ship’s tank, among other controls and guidance.

FOSFA advises its members of changes to its rules generally via circulars, which cover other issues such as allowable tank coati ngs, pressure testi ng, reporti ng responsibiliti es, and more. Internati onial oils and fats associati on (AOCS) stresses that 85% of the world’s oils and fats trade use FOSFA contracts, with the standard forms boosti ng understanding and clarity in communicati ons between parti es. “This allows the parti es to discuss and agree on the important features such as quality, quanti ty, price, and shipment/delivery dates,” said a note from AOCS (once the American Oil Chemists’ Society).

Nati onal regulators may also impose additi onal safety requirements. A good example is the USA, which insists that companies that move large volumes of oils and fats over water must develop a ‘facility response plan’ and follow a ‘spill preventi on, control and countermeasure’ regulati on, in case there is an accident that causes a major leak. This includes conti ngencies for dealing with “a worstcase discharge of animal fats and vegetable oils”.

The rules are administered by the US Environmental Protecti on Agency (EPA), which stressed in a report: “Scienti fi c research and experience with actual spills have shown that spills of animal fats and vegetable oils kill or injure wildlife and produce other undesirable eff ects. Wildlife that becomes coated with animal fats or vegetable oils could die of hypothermia, dehydrati on and diarrhoea, or starvati on.”

In additi on, regional laws are of relevance, such as those passed by the European Union (EU). These allow the u

Photo: Adobe Stock

Industry regulations cover the bulk transport of oils and fats in tank containers

u bulk transport of oils and fats into the EU, under the EU general food law, regulation 178/2002, and regulation (EC)852/2004 on the hygiene of foodstuffs, both of which are currently under review.

A key consideration, and a regulation that is constantly assessed by the European Food Safety Authority (EFSA), is the requirement that previous cargos in bulk tanks before an oils and fats shipment are included on a positive list.

If these items are not listed, the next use of a tank shipped to and from the EU cannot be for edible oils and fats.

Recent changes to this legislation include 2019 guidance from EFSA that calcium lignosulfonate was insufficiently safe to consumers to be an authorised previous cargo, but that methyl acetate, and ethyl tert-butyl ether (ETBE) were safe enough for inclusion on this list (a decision made in 2017).

FEDIOL, the EU vegetable oil and protein meal industry association, aids the industry by publishing a code of minimum requirements and recommendations for bulk transport in road tankers/ISO containers of edible oils and fats for direct food use.

This includes guidance on heating, off- and onloading, pumps, HACCP-systems and more. FEDIOL has been active in delivering more detailed guidance, for instance on crushing and processing oilseed-based feed for animals, including their handling in tanks, with specific advice depending on the type of seeds.

Of course, these major industry bodies are not the only organisations offering practical guidance on how best to transport edible oils and fats in bulk.

The transport information service from the German Insurance Association, for instance, provides specialist information from German marine underwriters on handling 190 specific products, with the aim of reducing accidents and losses, and hence claims on insurance policies. These products include a wide range of oils and fats, such as butter, cottonseed oil, hempseed oil, soya oil, olive oil and more.

Regarding rapeseed oil, for example, the service advises that the oil does not need heating, as its solidification point is relatively low. But if it solidifies in tanks, rapeseed oil cannot be liquefied again even by forced heating. Near heating coils, the oil melts, scorches, discolours and becomes rancid.

In addition, the international TIC Council, which represents the Testing, Inspection and Certification (TIC) industry, releases detailed guidance through its agricultural and vegetable oils committee. It has released a 2020 version of its directory of expertise expected to be understood by an agricultural superintendent for oils and fats transports, including how best to make calculations about liquid density and volumes, heating, shore tank gauging, sampling, contamination and more.

Cargo tank cleanliness

One major consideration for any shipper of oils and fats is ensuring that tanks are properly cleaned before they receive a mass cargo of edible liquids, to avoid tainting by contaminants.

Maritime Mutual stresses that shippers follow two interrelated set of standards on cargo tank cleanliness standards and tank cleaning procedures. The FOSFA Code of Practice for Superintendents (CPS) manual lays down the tank inspection process and tank fitness and cleanliness requirements which must be followed by such officials, as mandated by FOSFA contracts.

These rules are within the FOSFA CPS Part 1, Oils and Fats, Section 5.2, Ships Tank – Fitness and Cleanliness. This incudes advice such as the following: “Check visually so far as accessible to ensure that no internal fittings of copper or copper alloy, which are not allowed. Report on condition of tank coating. Report on residues, loose scale, hardened product adhesion to cross-members, etc. Where chemical cleaning has taken place, it is essential to check for residual chemicals. Report on any unusual foreign odour and identify if possible.”

Regional advisors also offer guidance, such as the European Federation of Tank Cleaning Organisations (EFTCO), which has released multi-lingual versions of its codes which are designed to ensure postpumping cleaning is at the highest level, recognising “tank cleaning is an essential part of the supply chain”. The group regularly updates its guidance, issuing in 2019 an EFTCO Cleaning Document (ECD), enabling shippers to detail every single tank cleaning.

A blog for maritime recruitment service MySeaTime outlines the difficulties in ensuring tanks are sufficiently clean before and after shipping oils and fats. It stresses that using good cleaning software is helpful in securing product-specific advice, for instance, after offloading vegetable oils, with methods varying according to the product category.

Keeping empty tanks moist ahead of cleaning helps, as does using higher water temperatures and increased spray force. Utilising IMO-authorised cleaning chemicals at appropriate densities can also be useful: “While high pressure and higher temperatures will do most of the job, cleaning to wall wash standard would still most likely require the use of chemical re-circulation in the tanks,” said the blog.

Ultimately, transporting oils and fats in bulk is a specialist business that rewards expertise. The Port of Rotterdam, in the Netherlands, is a good example. The port has specialised storage and handling facilities for edible oils and fats with a capacity of 1.2M m3, and has expanded and improved in recent years to allow larger tankers to load and unload, including ship-to-ship transfers. ● Keith Nuthall is the editor and director of International News Services Ltd, UK