Sustainability of the industry
There is deep concern that the current tanker market rates are consistently below operating costs.

This could threaten the sustainability, even the very survivability, of the oil transportation industry.

This situation, where tanker owners are not even covering their operating costs, cannot be sustained in the longer term.

Standards must be maintained at the highest levels in order to operate in today’s demanding markets, but in continuing to do that, some operators may hit a financial wall.

Greenhouse gases (GHG)
EEDI requirements should apply equally to all new ships on the same applicable effective date.

Compliance with EEDI should focus on improved hull design, propulsion efficiency and energy optimisation.

INTERTANKO believes that a market-based mechanism (MBM) is not justified at this time.

If an MBM should be required, of the current MBM proposals, the GHG Fund seems to be the simplest and most transparent from a shipowner’s point of view.


Best Management Practices (BMP4)

It is crucial that ship operators follow the three main elements of BMP4 for ships going through the GoA and Indian Ocean: register with MSCHOA; report to the UKMTO; employ the appropriate self-protection measures.

Armed guards
It is the responsibility of the international navies to ensure the right of free passage on the high seas including the use of vessel protection detachments (VPDs) on merchant ships.

INTERTANKO does not advocate the arming of ships’ crews.

The use of private armed guards or government armed security forces onboard merchant ships has to be a matter for each individual owner or manager to assess as part of their voyage risk assessment.

If armed guards are to be used, the flag state should be consulted to determine the conditions for authorization and the IMO guidelines for shipowners contained in MSC.1/Circ.1405 and for flag states contained in MSC.1/Circ.1406 should be taken into account.

The decision to deploy a citadel, or not, should take into account all known factors and be risk assessment-based.

If a citadel is to be employed, the industry guidance on the use of citadels should be taken into account. This guidance is available on the MSCHOA web site.