Japan justifies its submission as an initiative to avoid further accidental pollution. It is stated that if Diamond Grace had had a double hull, it would not have caused such an oil spill.

INTERTANKO is very much concerned about the consequences of any pollution accident, but it is also of a great concern that the recommended action is again detracting attention from the real cause of each of these accidents.

IMO has decided, and tanker owners are committed, to replace the existing fleet of single hull ships with a new generation of double hull tankers. However, this is the second line of defence which can only limit the consequences of an accident. The real causes of the accidents mentioned by Japan were not related to the design of these tankers. While Nakhodka was an old tanker, the other two were new tankers.

The real reasons for the accidents mentioned can be outlined as follows:

The Nakhodka was a poor tanker structurally

The Sea Empress grounding was due to pilot error, and

The Diamond Grace appears, from reports to date, to have been due to a combination of pilot error and inadequate traffic control/traffic separation arrangements.

Safety of navigation should be of major concern to governments but they, yet again, are focusing on the design. This is probably because tanker design is easier to explain, it does not cost governments much money to modify and finally, it seems to be politically correct.