OPA90 insists upon all tankers entering their territorial waters being double hulled. This was in reaction to several serious oil spills but in particular the “Exxon Valdez” which grounded in Prince William Sound, Alaska and spilt many thousands of tonnes of crude oil, resulting in colossal clean-up costs. OPA90 also demands that ships trading with the USA to have Certificates of Financial Responsibility (COFRs) which ensure that any ship causing pollution will have the financial capability to pay the clean-up costs. Nine years later, the 24 year old Maltese flagged “Erika”, on a voyage from Rotterdam to Leghorn in Italy, broke in two in a storm off the coast of France dumping about 14,000 of her 37,000 tonne cargo of heavy fuel oil. Heavy fuel oil can be an even worse pollutant than crude oil because the former is extremely sticky and hard to clean up. Much of the spilt oil reached the coast of Brittany causing massive pollution, not only to pleasure beaches but more especially to shellfish stocks which were a major source of local income. This casualty caused a widespread international reaction with blame being aimed in turn at the shipowners (a one-ship company), the French charterers (TotalFina), the flag state (Malta), the ship’s classification society (Registro Italiana), even the International Association of Classification Societies (IACS) whose purpose in life is to monitor those classification societies who are their members. In the end the role of “class” was held by many to be most culpable. There was also, of course, considerable concern expressed as to whether Port State Control was as effective as it should be and this particularly exercised the minds of the European Union. The EU started talking in terms of copying the USA and introducing anti-pollution regulations unilaterally. In the event the members of the IMO took up the challenge and agreed to introduce a revised Regulation 13G of Annex I of the Marine Pollution Convention (MARPOL). The Marpol convention had already introduced rules concerning ships having segregated ballast tanks (SBTs). Previously, tankers when needing stability on the ballast run, would simply flood some of the cargo tanks. This meant that when the ballast water was discharged it would take with it considerable quantities of oil residues. SBTs ensure that ballast tanks never contain oil, only water, so that there is little or no pollution when ballast water is discharged prior to loading.