IMO PSPC – Winners and Losers

Michael Hindmarsh
International Paint

2nd Annual NACE International Marine Coatings Summit

Westin Chosun, Busan
31st October 2008

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Agenda

• IMO MSC.215(82) Performance Standard for Protective Coatings

• The effects of the IMO PSPC
– Shipyards
– Ship owners
– Coatings companies
• TAC‟s
• Site Audits
• Shop primer TAC‟s of competitors products
• Formulation change rules
– Class societies
– Overall

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IMO MSC.215(82) Performance Standard for Protective Coatings

• Introduced after significant losses of ships due to corrosion in ballast

tanks
• Dedicated WBT of all Newbuildings >500 GT and double side-skin spaces
in bulk carriers of 150m in length and above
• Designed to achieve a target coating lifetime of 15 years
• Improved corrosion protection via:
– Improved steelwork, surface preparation and cleanliness prior to
coating
– Improved application control of coating schemes
– Use of pre-qualified anticorrosive schemes only

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IMO MSC.215(82) Performance Standard for Protective Coatings

• Adopted at IMO MSC 82 on 8th December 2006

• Applies to Newbuildings when:
– The building contract was placed on or after 1st July 2008, or
– If no contract, the keel of which are laid on or after 1st January
2009
– The delivery is on or after 1st July 2012
• Tankers and Bulk Carriers immediately due to IACS Common
Structural Rules

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The effects of the adoption of IMO PSPC

• Shipyards
– IMO PSPC developed in period of unprecedented fleet growth.
– NB orderbooks have consistently risen over the past 10 years
– Shipyards are producing record number of vessels.
– New shipbuilding nations are emerging
– Fast delivery of vessels is a key operational driver for
shipyards who want to remain competitive

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The effects of the adoption of IMO PSPC

• Shipyards
– Common global standard for the painting of water ballast tanks
• Steelwork
• Surface preparation
• Application and inspection
• Documentation

– Some yards had very little to do in order to comply

– Productivity will be effected

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The effects of the adoption of IMO PSPC

• Shipyards
– Productivity issues
• The hand preparation
standard debate
• The stripe coating
debate
• The salt level debate
• The maximum film
thickness debate
• The edge preparation
debate

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The effects of the adoption of IMO PSPC

• Ship owners;
– Same coatings (in the main)
– Consistent Newbuilding coating standards worldwide
– Higher asset re-sale value
– Reduction in un-planned maintenance
– Better qualified coating inspectors
– Little opportunity to challenge the standard of the work in any
yard (though they still hold the cash!!)

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The effects of the adoption of IMO PSPC

• Coating companies
– All products for WBT‟s must have a Type Approval Certificate
• Main coating testing
• Shop primer cross-over testing (including competitors)
• Central formulation location audit
• Manufacturing location audit
– Qualified inspectors

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Type Approval Certificates – The Procedure

Demonstration of performance
1. Documented 5 years in-service performance as “good” in
accordance with IMO Resolution A744
2. Use existing Marintek or DNV B1 test reports provided the
formulations now supplied are the same as those tested (verified
by IR finger print and SG measurements).
3. Full test of system in accordance with Annex 1* of MSC.215(82)

• Are all „Approved laboratories‟ able to interpret the test method and
test results in the same consistent way?

• Test laboratory should also have a PR34 (Z17) audit by each class
society!!! Is this being done?

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Type Approval Certificates – The Procedure – As an aside

• After weathering shop primer should be low pressure washed

or other mild method – who decides what other acceptable
methods are?
• How wide and long is the scribe?
• The standard states that the tank is run for 2 weeks full and 1
week empty – Originally DNV always left water in the bottom
during the dry part so that the humidity was high – the CP
panel was raised so that it was out of the water (and the tank
was not rocking)
• What happens if the shop primer shows any white rust or even
red rust?
• Some will be seen – particularly around the U-beam
• How much is allowed and what is the allowable
preparation method?

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Type Approval Certificates – The Procedure – As an aside

• How much water is put into the tank and what angle is the tank
rolled?
• How long do you wait after the test before carrying out the tests
– Is the flexibility of the heated panel measured when it is still
hot or after it has cooled down? The two results would be
different
– Same for the creep testing – We believe that NACE testing
requires that panels are rested for 2 weeks prior to testing.
• How do you measure undercutting from the scribe on shop
primers? We can imagine lots of confusion here.

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Type Approval Certificates – The Procedure

• Type Approval Certificates (TAC‟s) will be

issued by a recognised organisation
(generally class) if the following criteria has
been satisfied
– Documented evidence of performance
– Audit of the supply site (IACS PR34)
– IR fingerprint of all products (including
shop primers)
– SG‟s of all products
– IMO PSPC compliant Technical Data
Sheet
– Money (with each class society
charging a different rate)

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Type Approval Certificates – Approval of manufacturing sites

• Formulating site (or technical control site) AND the manufacturing

site need to be successfully audited by the recognised
organisation (generally class)
• Most class societies will want to issue their own site audits.
– Some class societies are insisting on auditing each site
– Some will audit selected sites and issue blanket approval
– Others will use existing audit reports, but will still want to issue
their own approval
• No class mutual recognition
• Difficulty in getting reports of the actual site audit
• Inconsistent messages from the members of IACS

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Type Approval Certificates – Formulation changes

• How much of the formulation can you change?

• Why do you need to change formulations anyway?
– RM like for like substitutions (RM supplier stops supply)
– Unable to source exact local RM‟s
– Incremental improvement in performance for yard or owner
– Regulations such as REACH in Europe.
• Need to agree
1. Changes that can be made without notifying recognised
organisation
2. Changes that can be made where Recognised Organisation
(RO) is informed but no re-test is required
3. Changes that when made require a full re-test

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Type Approval Certificates – Formulation changes

• Currently, an IPPIC formulation change rule (agreed by coatings

companies) has been proposed.
– The proposal is with IACS Expert Group for consideration
– Our understanding is that all IACS members with the
exception of one are agreeing to the formulation change rules.
– Potential stalemate for IACS.
– We may have to agree formulation change rules on a case-
by-case basis with individual class societies
– A unified message from IACS would have been a great
benefit.

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Type Approval Certificates – Shop primer validation

• IMO PSPC allows for application of epoxy anticorrosive system

over a competitors zinc silicate shop primer;
– The shop primer must have been through a full test
(Marintek/DNV) as part of a full anticorrosive system
– The epoxy anticorrosive must have been through a full test
(Marintek/DNV) over a zinc silicate shop primer
– The full system (that is required in this case) has passed a
„cross-over‟ test

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Type Approval Certificates – Shop primer validation

• Epoxy anticorrosive supplier needs to source relevant test samples

of competitors shop primer
• Determine whether the shop primer has been through a full test,
and preferable get access to the test report (from who??)
• Carry out a cross over test (including IR spectrum of the tested
shop primer)
• Some Class societies have refused to issue a TAC for an epoxy
system over a competitors shop primer until they have seen the
shop primer full test report
– How is that going to happen?
– Shipyard using the shop primer should supply full test
report to anyone who wants it.

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Type Approval Certificates – Shop primer validation

• What happens if the shop primer manufacturer changes the shop

primer formulation?
– The shop primer manufacturer would know about the change
before any other paint manufacturer
– Would therefore be able to get full approval of the shop primer
– AND approval with all their epoxy anticorrosives, even before
the change was made public
• Who is responsible for informing other paint companies that a shop
primer formulation change has been made?
– Shipyard
– Trade coater/Steel plate supplier
– Shop primer manufacturer
– Trade Associations
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Type Approval Certificates – Shop primer validation

• CEPE has agreed to produce a list of „approved‟ IMO PSPC shop

primers.
• List is on the CEPE website

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Type Approval Certificates – Shop primer validation

• Whilst a list of shop primers was published, CEPE has not

indicated how a shop primer change would be notified, to allow all
paint companies to carry out the 6 month [8 month in total] cross-
over test

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Approval of Inspector Training

• The IMO PSPC calls for paint inspector to be qualified;

• Cost of NACE Level 2 - $4,000 (for both level 1 and 2)

• Cost of FROSIO inspector Level III - $4,000/person

• The recognised organisation (generally class) can approve an

equivalent qualification. There is no IACS mutual recognition of this

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Approval of Inspector Training

• Some class societies are happy to consider „equivalent‟ qualifications

– LR famously qualified KACE very early.
– This qualification was originally seen as an IACS qualification
• Others however, are developing their own „qualifications‟
– Revenue earning.
• At the moment, approval of „equivalent‟ qualifications has to be given by
each individual class societies (those that will) even though NACE and
FROSIO is accepted by everyone.

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The effects of the adoption of IMO PSPC

• Class societies
– IACS members as „Recognised Organisations‟ have a big
responsibility
• They ultimately decide what is acceptable and what is not
• They ultimately decide the interpretation of the standard
• They ultimately decide what is „equivalent‟ and what is not
• They ultimately have authority to approve coating systems
• They ultimately have responsibility to approve laboratories
• They ultimately have responsibility to approve paint
manufacturers facilities
• They are also in a competitive environment and are not
independent

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The effects of the adoption of IMO PSPC

• Class societies
– IACS members as „Recognised Organisations‟ have a big
responsibility
– Inundated with Z17 (PR34) manufacturing sites audits (not all
class societies have procedures in place for doing this)
– Inundated with requests for Type Approval Certificates for
every combination of epoxy system and shop primer including
all possible competitors shop primers
• Huge delays in getting reports and TAC‟s
• Inconsistent requests from class (e.g. IR spectra)
– Opportunity to offer services
• Training courses

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The effects of the adoption of IMO PSPC

• Overall
– We must not forget that IMO PSPC was implemented to save
lives (SOLAS regulation)
– The condition of water ballast tanks coated in accordance with
the IMO PSPC should last for 15years and longer with minimal
routine maintenance
– Vessels should maintain a higher asset value
– Reduction in the requirement for „special‟ surveys due to water
ballast tank condition

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Is 15 years lifetime is achievable

• How can we be sure that the test in the IMO PSPC that lasts 6
months can predict the condition of a coating in 15 years?
• We can‟t………
• However, the test adopted was the only recognised industry test at
the time and has been developed over many years
• Are there coatings out there that we know will have a 15 year
lifetime?
• Proof that careful selection and sensible application of a good
quality coating can achieve the desired result…………………

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9 years and counting

9 years in service

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 10 years and counting

10 years in service

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13 years and counting

13 years in service

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So who are the winners and who are the losers?

• Winners
– Seafarers
– Owners
– Class societies

• Losers
– Shipyards
– Coating companies
– Class societies

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Summary

• The adoption of the IMO PSPC is a good thing for the marine
shipping industry
• All interested parties are working hard to ensure that
implementation occurs smoothly
• There are still issues to be resolved
• There still needs to be dialogue
• Mutual recognition by IACS members would help everyone
• And finally, we must not lose sight of why this standard was
introduced and what it is trying to achieve.

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IMO PSPC – Winners and Losers

Michael Hindmarsh
International Paint

2nd Annual NACE International Marine Coatings Summit

Westin Chosun, Busan
31st October 2008

For internal use only, contains confidential and proprietary information. Not to be circulated outside Akzo Nobel