DEVELOPMENT OF MANDATORY IMO PERFORMANCE STANDARDS FOR

PROTECTIVE COATINGS ON SHIPS

AN OVERVIEW1
by
Heike Hoppe
Senior Technical Officer
Maritime safety Division
International Maritime Organization

History
1
As early as 1991 the IMO membership expressed concern at the continuing loss,
sometimes without a trace, of ships carrying solid bulk cargoes and the heavy loss of life caused
by such accidents. Recognizing that the nature of cargo and ballast operations can subject the
structure of bulk carriers to more severe patterns of bending and shear forces and to significant
wear and being aware of the dangers posed by some solid bulk cargoes through their high density
and propensity to shift, the IMO Assembly requested the Maritime Safety Committee (MSC) to
develop requirements for the design, construction, operation, maintenance and survey of bulk
carriers and specific precautionary measures with respect to type of cargoes.
2
Work on the subject continued over the next few years and culminated in the convening,
of a Conference of SOLAS2 Contracting Governments in 1997 (1997 SOLAS Conference) which
adopted a new SOLAS chapter XII on Additional safety measures for bulk carriers, which
entered into force on 1 July 1999.
3
The Conference invited the MSC to continue consideration of further specific aspects of
bulk carrier safety.
Consequently, MSC 75 in May 2002 approved a long list of
recommendations for decision-making which was derived from the results of a number of Formal
Safety Assessment (FSA) studies conducted by various Member States of IMO. One of the items
on that list was Improved coating: Controls and/or performance standards for protective
coatings, in relation to compatibility with cargoes.
4
Premature failure of protective coating systems is often found in ballast tanks of ships in
service and as a consequence will lead to rapid corrosion of unprotected steel. Following coating
breakdown it is extremely difficult, if not impossible, to repair or reinstate the coating to
newbuilding standard. It is therefore of the utmost importance that coatings be correctly applied
at the newbuilding stage. The Committee felt that the best way to achieve this would be the
development of mandatory performance standards, including a minimum target life, for ballast
tank coatings.3

Views expressed in this paper are those of the author and should not be construed as necessarily reflecting the
views of IMO or its Secretariat.
International Convention for the Safety of Life at Sea, 1974
EMSA Report of the High Level Panel of Experts on Double Hull Tankers, 2005

/var/www/apps/conversion/tmp/scratch_5/262524438.doc

2
5
MSC 76 in December 2002 noted that SOLAS regulation II-1/3-2 made the coating of
dedicated seawater ballast tanks mandatory for oil tankers and bulk carriers, with reference to the
Guidelines for the selection, application and maintenance of corrosion prevention systems of
such tanks (resolution A.798(19)). The Committee agreed that by extending that requirement to
cargo holds serious problems could be introduced, bearing in mind that cargoes can react
distinctly to different coatings. Therefore, MSC 76 agreed that new ships should only be
required to have their dedicated seawater ballast tanks and void spaces within double hull spaces
coated according to current SOLAS requirements for ballast spaces and that the coating of cargo
holds should be addressed by class and the shipowner. Notwithstanding the aforementioned
Guidelines, the Committee considered that there was a need for international performance
standards for coatings and requested its Sub-Committee on Ship Design and Equipment (DE) to
develop such standards.
Development of performance standards for protective coatings
DE 46/47
6
The DE Sub-Committee, after preliminarily considering the item at DE 46 in March
2003, commenced work on the matter at DE 47 in March 2004. In the absence of concrete
proposals and noting that IACS4 and the industry were developing guidelines for coatings in
ballast tanks and that further standards for coatings in double-side skin spaces of bulk carriers
could be developed if requested, DE 47 agreed that the development of the proposed IMO
performance standards for protective coatings should only be undertaken when industry
standards, or an advanced draft thereof, were available. IACS and the industry were invited to
consider developing draft performance standards for protective coatings in double-side skin
spaces of bulk carriers, and to inform DE 48 accordingly.
MSC 79
7
In the meantime, MSC 79 in December 2004 adopted revisions to SOLAS chapter XII
which entered into force on 1 July 2006. Regulation 6.3 5 of the revised chapter now refers to
performance standards for protective coatings to be adopted by the Organization. In this
connection, MSC 79 agreed that the performance standards, when finalized, should be made
mandatory by suitably modifying the relevant SOLAS regulations.
DE 48
8
Consequently, serious work started in 2005 at DE 48, where a first draft of a performance
standard for protective coatings of double-side skin spaces of bulk carriers and of ballast tanks,
submitted by a group of industry organizations6, was available, together with various submissions
by Member States commenting on the draft provisions. Following an intensive debate, the SubCommittee took a number of decisions as follows:
.1

4
5

the coating performance standards should apply to all ballast and void spaces on
all types of ships (this constitutes an expansion of the scope, originally

International Association of Classification Societies

Double-side skin spaces and dedicated seawater ballast tanks arranged in bulk carriers of 150 m in length and
upwards constructed on or after 1 July 2006 shall be coated in accordance with the requirements of regulation
II-1/3-2 and also based on the Performance standards for coatings to be adopted by the Organization.
DE 48/12 (BIMCO, IACS, ICS, INTERCARGO, INTERTANKO) - Draft performance standards for protective
coatings

/var/www/apps/conversion/tmp/scratch_5/262524438.doc

3
performance standards for dedicated sweater ballast tanks of all ships and doubleside skin spaces of bulk carriers were to be developed);
.2

the target coating life should be 15 years;

.3

a Coating Technical File should be included as a requirement; and

.4

verification and inspection aspects and requirements for steel primers needed to be
clarified.

9
A correspondence group under the co-ordination of China was established to progress the
work intersessionally and instructed to further develop the draft performance standards for
protective coatings, on the basis of the documents submitted and taking into accounts comments
and proposals made during the discussion.
MSC 80
10
MSC 80 in May 2005 agreed to the expansion of the scope of the item as suggested by
DE 48 (see paragraph 8.1 above) and further instructed the Sub-Committee and its
correspondence group to consider incorporating in the performance standards methods and a
scheme of verification and survey for protective coatings; to take into account that performance
standards for protective coating systems for seawater ballast tanks should be different from those
for void spaces into which seawater normally does not enter; and to consider developing
consequential amendments to SOLAS, as appropriate.
DE 49
11
DE 49 in February 2006 agreed to complete the draft standards for dedicated seawater
ballast tanks for all types of ships and for double-side skin spaces of bulk carriers first and to
develop requirements for protective coatings for all void spaces separately at a later stage.
12
After extremely difficult and very controversial discussions, DE 49 agreed to a draft
Performance standard for protective coatings of dedicated seawater ballast tanks on all new ships
and of double-side skin spaces of bulk carriers for submission to MSC 81 for approval and
appropriate further action. The draft text still contained a number of square brackets concerning
issues where the Sub-Committee could no reach agreement.
13
Realizing that the revised SOLAS regulation XII/6.3 would enter into force on 1 July
2006 and recognizing the need to implement the Performance standard from that day for
dedicated seawater ballast tanks and double-side spaces of new bulk carriers of 150 m in length
and upwards, DE 49 also agreed to a draft MSC circular concerning the early application of the
Performance standard for submission to MSC 81 for approval.
MSC 81
14
MSC 81 in May 2006 had 14 submissions commenting on the draft Performance
Standards, a very high number for MSC meetings and an indication that discussions would again
be difficult. Therefore, after taking some principal decisions with respect to the application
provisions (basing the date of application on the date of contract, a first for SOLAS regulations),
the Committee established a group of experts and instructed it to finalize the mandatory
Performance standard for protective coatings and the related draft amendments to SOLAS
regulations II-1/3-2 and XII/6.
/var/www/apps/conversion/tmp/scratch_5/262524438.doc

4
15
After long hours of intensive discussions, with very active participation of the
representatives of shipyards and shipowners, the Committee finally approved the draft
Performance standard for protective coatings for dedicated seawater ballast tanks in all types of
ships and of double-side skin spaces of bulk carriers and the related draft amendments to SOLAS
regulations II-1/3-2 and XII/6 and to the form of SOLAS safety certificates, introducing the date
of contract in the text of the certificates, for consideration at MSC 82 with a view to adoption.
16
MSC 81 also approved MSC.1/Circ.1198 on Application of SOLAS regulation XII/6.3 on
corrosion prevention of double-side skin spaces and dedicated seawater ballast tanks of bulk
carriers and application of the performance standard for protective coatings for dedicated
seawater ballast tanks in all new ships and double-side skin spaces of bulk carriers, resolving that
SOLAS Contracting Governments may apply in advance the draft SOLAS amendments together
with the Performance standard, pending the entry into force of the SOLAS amendments.
17
Given its adoption at MSC 82 in December 2006, the Performance Standard will enter
into force for ships of not less than 500 gross tonnage for which the building contract is placed on
or after 1 July 2008.
Performance standard for protective coatings for dedicated seawater ballast tanks in all
types of ships and of double-side skin spaces of bulk carriers
18
Corrosion prevention of seawater ballast tanks is currently prescribed by SOLAS
regulation II-1/3-2, making it mandatory for all dedicated seawater ballast tanks to have a
corrosion prevention system. Non-mandatory guidelines7 developed in 1995 advise on selection,
application and maintenance of the system. The proposed draft amendments to SOLAS
regulations II-1/3-2 and XII/6 (see paragraph 15) approved at MSC 81 will make the newly
developed Performance Standard mandatory.
Application
19
The Standard provides technical requirements for protective coatings in dedicated
seawater ballast tanks of all types of ships of not less than 500 gross tonnage and double-side
skin spaces arranged in bulk carriers of 150 m in length and upward. In a first for the SOLAS
Convention, the application dates have been based on the date of contract, as has been customary
for many years in the sister convention, MARPOL8. They will apply to ships:
.1

for which the building contract is placed on or after 1 July 2008, or

.2

in the absence of a building contract, the keels of which are laid or which are at a
similar stage of construction on or after 1 January 2009, or

.3

the delivery of which is on or after 1 July 2012.

General principles
20
Inspection of surface preparation and coating processes shall be agreed between the
shipowner, the shipyard and the coating manufacturer and presented to the Administration or its
7

Resolution A.798(19) Guidelines for the selection, application and maintenance of corrosion prevention
systems of dedicated seawater ballast tanks
International Convention for the Prevention of Pollution from Ships, 1973, as modified by the Protocol of 1978
relating thereto

/var/www/apps/conversion/tmp/scratch_5/262524438.doc

5
recognized organization9 for review. Clear evidence of these inspections shall be reported and be
included in the Coating Technical File (CTF) which documents the specification of the coating
system applied to the seawater ballast tanks and double-side skin spaces, record of the shipyards
and shipowners coating work, detailed criteria for coating selection, job specifications,
inspection, maintenance and repair. Guidelines for maintenance and repair of coating systems
will be developed by the DE Sub-Committee (see paragraph 26).
Coating standard
21
The Standard mandates a target useful coating life of 15 years, which is considered to be
the time period, from initial application, over which the coating system is intended to remain in
GOOD10 condition. Basic coating requirements are set out as follows:
.1

Design of the coating system

selection of the coating system
coating type
coating pre-qualification test
job specification
nominal total dry film thickness (NDFT)

.2

Primary surface preparation

blasting and profile
water soluble salt limit equivalent to NaCl
shop primer

.3

Secondary surface preparation

steel condition
surface treatment
surface treatment after erection
profile requirements
dust
water soluble salt limit equivalent to NaCl after blasting/grinding

.4

Miscellaneous
ventilation
environmental conditions
testing of coating
repair

Coating inspection and verification

22
Coating inspectors shall inspect surface preparation and coating application during the
coating process by carrying out, as a minimum, inspections of primary surface preparation,
thickness, block assembly and erection to ensure compliance with the Standard. Results from the
inspection shall be recorded by the inspector and shall be included in the CTF. A problem is the
9

10

An organization authorized by the Administration to act on its behalf, in accordance with SOLAS regulation
XI-1/1.
GOOD condition is the condition with minor spot rusting as defined in resolution A.744(18) Guidelines on
the Enhanced Programme of Inspections during Surveys of Bulk Carriers and Oil Tankers.

/var/www/apps/conversion/tmp/scratch_5/262524438.doc

6
apparent lack of qualified coating inspectors, a matter that will be considered at the next MSC
meeting in December 2006.
23
Prior to reviewing the CTF, Administrations or recognized organizations shall check the
Technical Data Sheet and Statement of Compliance or Type Approval Certificate and the
qualifications of the inspector and monitor implementation of the coating inspection
requirements.
Alternative systems
24
All systems that are not epoxy based are defined as alternative systems. The acceptance
of alternative systems is subject to documented evidence that they ensure a corrosion prevention
performance at least equivalent to that indicated in the Standard and reach a target useful life of
15 years in either actual field exposure for 5 years with final coating condition not less than
GOOD or laboratory testing. Relevant laboratory tests are to be conducted in accordance with
test procedures given in annex 1 of the Standard.
Further work on protective coatings
25
A DE correspondence group under the co-ordination of China is currently considering the
development of a draft performance standard for protective coatings of void spaces of all types of
ships. In particular the group has been asked to identify and define to which void spaces the
Performance standard developed should apply, considering as a priority tankers and bulk carriers,
and to which a different standard could apply and to develop a draft standard for such spaces for
tankers and bulk carriers. As a general definition, the Sub-Committee agreed that a void space
should be considered to be a space in a ship that is designed to be dry and completely empty at all
times and is not used to carry cargo or ballast water. The outcome of the groups discussions will
be considered at DE 50 in March 2007.
26
The considerations at MSC 81 when approving the draft Performance standard, resulted
in the DE Sub-Committee being tasked with two additional items relating to coatings, i.e. the
development of guidelines for maintenance and repair of protective coatings and the development
of requirements and standards for corrosion protection of permanent means of access
arrangements that are not part of structural strength elements. Work on these two issues will start
at DE 50 in March 2007.
27
Also currently under development is a Performance standard for cargo tank coatings of
oil tankers in order to avoid premature breakdown of cargo tank coating systems, prepared under
the lead of the European Maritime Safety Agency (EMSA) in the context of the work of the High
Level Panel of Experts on Double Hull Tankers. It is expected that a relevant proposal will be
submitted to MSC 82 for the consideration of the Committee.
28
In the long run, all the above is expected to lead to mandatory coating provisions in
SOLAS which will in the future cover all internal spaces in new ships, resulting in strong, longlasting coatings with low maintenance needs. And although this means that owners will have to
pay more for newbuildings, in return they will get ships with better coatings, thus reducing
maintenance costs and improving safety at sea.
***

/var/www/apps/conversion/tmp/scratch_5/262524438.doc

7
ANNEX
ILLUSTRATIONS11

11

Source: EMSA Report of the High Level Panel of Experts on Double Hull Tankers, 2005

/var/www/apps/conversion/tmp/scratch_5/262524438.doc

/var/www/apps/conversion/tmp/scratch_5/262524438.doc

/var/www/apps/conversion/tmp/scratch_5/262524438.doc

10

/var/www/apps/conversion/tmp/scratch_5/262524438.doc

11

_______________

/var/www/apps/conversion/tmp/scratch_5/262524438.doc