On 1 July 2016 a new regime for gas carrier construction was ushered in.

From 1 July 2016

The amended IGC Code applies to all gas carriers the keels of which have been laid or which
are at a similar stage of construction where construction identifiable with the gas carrier
begins and assembly of the gas carrier has commenced, comprising at least 50 tonnes or 1%
of the estimated mass of all structural material, whichever is less, on or after 1 July 2016.

Existing gas carriers constructed prior to 1 July 2016 but after 1 July 19861 still need to
comply with the old IGC Code (on which see below) and will be required to have complied
with certain elements of the new IGC Code by 1 July 2021.

Why amend the IGC Code? Although amended lightly more recently, the last major
overhaul of the IGC Code was in 1993 (what has become the IGC Code first became
mandatory on 1 July 1986), so it has been some while since any major revisions have been
adopted. Indeed to call the new IGC Code an ‘amendment’ is something of a misnomer – the
whole Code has been overhauled, from top to bottom, such that it is, in several respects,
entirely new. The fact that a major revision to the IGC Code has taken some while to even be
considered, let alone come into force, is testament to the foresight of the draftsmen of the GC
Code and the Existing Ship Code that went before it.

The technology used in the construction, and operation of, gas carriers has of course
advanced considerably since the 1993 IGC Code and the fleet has grown rapidly, and
operators have gained much experience, however, one thing that has not changed is the
impeccable safety record. The new IGC Code tackles several issues that the old IGC Code
did not cover, and seeks to ensure that that impeccable safety record remains as intact as
possible, and paves the way for future development of the technology in use on gas carriers
covered by the new IGC Code. Further below we consider some of the key areas of the 1993
IGC Code that have been revised in the new IGC Code.

What is the remit of the new IGC Code? As with the 1993 Code, the new IGC Code
applies to any ships regardless of their size, including those of less than 500 gross tonnage,
engaged in the carriage of liquefied gases having a vapour pressure exceeding 0.28 MPa2
absolute at a temperature of 37.8°C and other products specified in the Code when carried in
bulk. But there are some grey areas where the applicability of the Code may not be clear.

Conversions The new IGC Code applies to any vessel converted to be a gas carrier on or after
1 July 2016, irrespective of the vessel’s date of construction.

LNG/LPG FPSOs The preamble to the new IGC Code explains that FPSOs designed to
handle gases in bulk do not fall under the IGC Code. However, it suggests that designers of
such units may wish to consider using the IGC Code to the extent that it “provides the most
appropriate risk mitigation measures for the operations the unit is to perform”.

FSRU The new IGC Code applies to FSRU intended to operate at a fixed location in re-gas
and gas discharge mode3, but only in so far as the provisions of the Code are applicable to the
proposed arrangements. In addition, the Code requires that Flag States / Port States establish
additional requirements for such FSRU based on the principles of the Code, as well as
recognised standards that address specific risks (examples of which are provided in the Code)
not envisaged by the Code.

LNG bunker barges Outside of the conventional LNG market, there has been some confusion
as to whether an LNG bunker barge needs to comply with the IGC Code or its new stable
mate, the International Code of Safety for Ships using Gases or other Low flashpoint Fuels
(known as the IGF Code, which will enter into force on 1 January 2017). Any bunker barge
that carries a liquefied gas in bulk will be subject to the IGC Code4, and it is only in relation
to the vessel being bunkered that the IGF Code will be applicable – the remit of the IGC
Code (both new and old) stops at the delivery flange.

Some key revisions made in the new IGC Code

Use of gas cargoes other than LNG as fuel The old IGC Code did not permit anything other
than methane vapour / boil off gas being burnt in gas carriers’ main propulsion plant,
however, the new IGC Code expressly permits, subject to acceptance by Flag State and
provided that the same level of safety as for LNG is ensured, the use of other non-toxic gas
cargoes as fuel. This is a positive development for the LPG and ethane carrier industry, and
will allow greater flexibility for such operators.

Following in the footsteps of 4-stroke diesel engines, in recent years 2-stroke diesel engine
technology has advanced sufficiently for gas also to be used reliably in such engines in the
alternative to fuel oil. The new IGC Code recognises that, and includes specific requirements
for gas-fired internal combustion engines. Under the old IGC Code, special provisions for
gas-fuelled internal combustion engines are to be considered by Flag State in each case.

In terms of supply of gas as fuel, the new IGC Code introduces specific requirements for high
pressure systems. This is intended to permit wider use of engines that require high pressure
gas injection systems, such as ME-GI engines.

Filling limits The old IGC Code permits a maximum of 98% level fill but provides that an
owner may seek permission of their Flag State to exceed that limit. No doubt in response to
increasing numbers of requests from owners to Flag States to permit increased filling limits,
the new IGC Code sets out the criteria to be satisfied to increase the filling limit beyond the
base limit of 98%, up to an absolute maximum of 99.5%. Although an absolute maximum is
now set down, the new IGC Code provisions should give gas carrier operators greater
flexibility to build gas carriers with increased filling limits without needing to seek approval
from their Flag States.

New containment systems The new IGC Code paves the way for novel configurations of
containment systems to be introduced. This is done by setting out functional requirements
and safety principles for containment systems and leaves behind much of the old IGC Code’s
approach to containment system design, which some criticised for being overly rigid.

In addition to the matters mentioned above, the new IGC Code introduces, amongst other
things, revised requirements for gas carriers’ construction, including as to welds and non-
metallic to metallic joints. It also revises the ship survival capability requirements, amends
the permitted locations of cargo tanks and protective distances between tanks and side shell
plating, as well as requiring existing ships to be fitted with stability instruments, all with a
view to retaining the impeccable safety record of the industry.
Conclusion The new IGC Code has been a long time in the making, and is the product of a
considerable number of interested parties’ input, all with myriad interests. It remains to be
seen how the IGC Code will develop further – the IMO is certainly aware that the Code
cannot remain static, and that further amendments will almost certainly be required as
technology and experience advance. Indeed, some IMO member states are understood to be
pushing for certain elements of the new Code to be revised already. For now, however, the
amendments seem to be welcomed by many in the industry but, until the new IGC Code is
actually applied it is unclear whether all the amendments will have the desired effect.