Technical Circular No: 108/2020

Subject: Amendments to the IBC/BCH Code & MARPOL 73/78 Annex II entering into force on 1 January 2021

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1. The International Maritime Organization (IMO) has adopted amendments to the IBC Code (MSC. 460(101) & MEPC.318 (74)), BCH Code (MSC.463 (101) & MEPC.319 (74)) and amendments to MARPOL 73/78 Annex II vide MEPC.315 (74) which will enter into force on 1 January 2021. All ships carrying dangerous chemicals and/or noxious liquid substances in bulk will need to satisfy the revised requirements prior to the date of entry into force of the amendments.

2. Salient points of the amendments are as follows;

i. Amendments to MARPOL 73/78 Annex II:

a. Prewash requirements for persistent floating products:

Amendments to MARPOL Annex II imposing prewash requirements in the port of unloading for certain high-viscosity or low-melting-point persistent floating products have been adopted.

For persistent floaters with a viscosity equal to or greater than 50 mPas at 20℃ and/or with a melting point equal to or greater than 0℃ (substances that are identified by '16.2.7' in column 'o' of chapter 17 of the IBC Code), a prewash procedure is to be applied in certain areas (e.g. North West European waters). The residue/water mixture generated during the prewash is to be discharged to a reception facility at the port of unloading until the tank is empty.

These new requirements will be applicable, for example, to the following products: Fish oil, Olive oil, Palm oil, Paraffin wax highly-refined, Rice bran oil, sunflower seed oil, etc. Refer Attachment 1 for the list of the identified persistent floating products.

b. Revision of the standard format of P&A Manual:

The standard format of the P&A (Procedures and Arrangements) manual has been revised to incorporate prewash procedures and instructions on how to deal with tank washings for persistent floating products.

Accordingly, the P&A Manual corresponding to the revised standard format needs to be approved and provided on board by the date of entry into force of the amendment.

ii. Amendments to IBC Code, BCH Code:

Revision of carriage requirements (for products listed under Chapter 17 & 18):

Due to the revision of criteria for assigning appropriate carriage requirements for products, the carriage requirements for all products have been reassessed, and most of them have been revised. Further new products have been listed under Chapter 17 and few products have been shifted from Chapter 18 to Chapter 17.

These amendments modifies the carriage requirements for some products (e.g. some products currently categorized as non-toxic cargoes will become toxic cargoes). As a result, the range of products a ship is certified to carry will differ before and after 1 January 2021.

Few significant revised carriage requirement is provided below for reference.

a) A controlled venting arrangement is now required in place of open vents for products such as Undecyl alcohol, Urea/Ammonium phosphate solution, Vinyl neodecanoate, Xylenol, etc.

b) Inerting of cargo tank is now required for products such as Ammonium sulphide solution (45% or less), Motor fuel anti-knock compounds (containing lead alkyls), etc.

c) Temperature class requirement of electrical equipment is enhanced from Class T1 to Class T3 for products such as Butyl methacrylate, Turpentine, etc.

d) Closed gauging arrangements is now required instead of restricted gauging arrangements for products such as Adiponitrile, Alkanes (C6-C9), etc. 

e) Closed gauging arrangements is now required instead of restricted gauging arrangements for products such as Adiponitrile, Alkanes (C6-C9), etc. 

f) The installation of Hydrogen sulphide (H2S) detection equipment has been added as special requirements for the carriage of products such as –

■ Sodium hydrosulphide/Ammonium sulphide solution

■ Sodium hydrosulphide solution (45% or less)

■ Offshore contaminated bulk liquid S (o) 

g) Alcohol-resistant foam or multi-purpose foam fire extinguishing medium is now required for products such as Alkylated (C4-C9) hindered phenols, Alkyl (C8-C10) polyglucoside solution (65% or less), etc.

h) Requirement of – ‘separate piping system, not to be stowed adjacent to oil fuel tanks and to have tank vent systems separate from tanks containing non-toxic products’ is now extended for few more products such as Diethylbenzene, Diethylaminoethanol, 1, 2-Dichloropropane, etc.

i) The pollution hazard category is increased from Category Z to Category Y for few products such as Benzene sulphonyl chloride, Calcium hydroxide slurry, etc.

j) New provision -16.2.7 has been added in accordance with the amendments of MARPOL 73/78 Annex II, for clarifying the subjected persistent floating products.

For summary of minimum requirements, Refer attached Resolution- MSC. 460(101).

3. The amendments apply to new and existing ships that have IBC/ BCH Code Certificates of Fitness or Noxious Liquid Substances Certificates.

4. For some products, only operational changes may be sufficient to comply with the new carriage requirements, while, for some products, important modifications to the ship’s structure/ equipment may be necessary to carry such products after 1 January 2021. Alternatively, Owners may opt not to carry such products.

5. Accordingly, a new Certificate of Fitness based on the amendments, as required, will need to be issued prior to the entry into force date of the amendments.

6. When a product is loaded prior to 1 January 2021, and unloaded after this date, the relevant provisions of the IBC/BCH Code at the time of loading are applicable until the product has been unloaded.

7. For further guidance on above and to request the new certificate of fitness and regarding the approval of revised P&A manual, IRS HO may be contacted.

8. Ship owners/ managers and masters of ships engaged in the carriage of dangerous chemicals and/or noxious liquid substances in bulk are advised to be guided by above and ensure timely implementation of the revised requirements.


  1. List of persistent floating products

  2. 460(101)

  3. 463(101)

  4. 315 (74) – Amendments to MARPOL Annex II

  5. 318(74) – 2019 Amendments to the IBC Code

  6. 319(74) – 2019 Amendments to the BCH Code


This Technical Circular and the material contained in it is provided only for the purpose of supplying current information to the reader and not as an advice to be relied upon by any person. While we have taken utmost care to be as factual as possible, readers/ users are advised to verify the exact text and content of the Regulation from the original source/ issuing Authority.

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