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International Law and International Organizations
Reference:

Legal Protection of the Marine Environment During the Transportation of Oil Products: International Legal Aspects

Svetskiy Arseniy Vladimirovich

ORCID: 0000-0002-0678-4841

Junior Researcher of the Environmental, Land and Agrarian Law Sector of the Institute of State and Law of the Russian Academy of Sciences

119019, Russia, Moscow, Znamenka str., 10

arseniy1107@gmail.com
Other publications by this author
 

 

DOI:

10.7256/2454-0633.2022.4.39139

EDN:

CEKZZO

Received:

10-11-2022


Published:

30-12-2022


Abstract: The article discusses the risks that arise for the environment during the production and transportation of hydrocarbons. Irreparable damage to the environment is caused as a result of accidents on ships and oil platforms, the consequences of which have been felt for many decades, while the greatest harm is caused by accidents occurring in high latitudes. These include: pollution of the water area following an emergency oil spill, the likelihood of a fire or explosion both on board during transportation and in the port at terminals. Emergency situations may arise as a result of exposure to hard weather conditions, technical malfunctions of the vessel, collision with other vessels, pirate attacks, etc. The article analyzes the provisions of international acts of the greatest interest in the field of protection of the marine environment from hydrocarbon pollution, such as the United Nations Convention on the Law of the Sea (UNCLOS) of 1982, the International Convention for the Prevention of Pollution from Ships (MARPOL 73/78), the International Convention for the Safety of Human Life at Sea (SOLAS 74/88), "International Code for Ships Operating in Polar Waters (Polar Code)". Proposals have been formulated to improve international and national regulation regarding the legal protection of the marine environment from oil pollution. Thus, it seems expedient to minimize the risks of emergency situations to think about combining the relevant provisions of all conventions into a single document, while eliminating gaps in both international regulation and national legislation in the field of marine transportation of hydrocarbons, to pay increased attention to environmental safety issues.


Keywords:

legal regulation, Convention, transportation, liquefied natural gas, marine environment, Northern Sea Route, oil, environmental protection, pollution, oil slick

This article is automatically translated.

Sea transportation of oil and petroleum products today is one of the most relevant methods of transportation of hydrocarbons in the world, respectively, the volume of such transportation is constantly increasing. With the increase in their number and volume, the risk of marine pollution also increases. Oil is a fossil fuel with an extremely long decay, at the same time it instantly covers the surface of the water with a thin layer of film. A ton of oil can cover up to 12 square kilometers. The danger of oil spills for the environment lies in the uniqueness of their physical properties: due to wind, oil spills can drift and change shape, divide into smaller ones and at the same time move considerable distances from the accident site. Various weather changes also affect the movement of oil spills. Such accidents pose a critical danger to birds, as well as organisms living either on the bottom, if an oil spill occurred in coastal waters, or near the surface of the water. In other words, such accidents cause enormous damage to the biosphere, including causing a general disruption of natural processes in ecosystems. Another danger to the marine ecosystem is the violation of heat exchange in the water layers, since the film on the surface prevents the penetration of sunlight.

It is difficult to imagine the modern world without the use of such fossil fuels as oil in various branches of economic activity. However, with an increase in the use of oil and petroleum products, the risk of environmental pollution increases proportionally. Even after a decade, an oil slick can have a negative impact on marine invertebrates, which causes significant damage to the ecosystem of the world ocean. (URL: http://www.npacific.ru/np/sovproblem/oil_sea/vozdeistvie/razliv/public1.htm#:~:text=Published%20data%20 spills%20neft%20requently,and%20%20inflections%20a%20organisms (accessed: 10/27/2022)). In order to minimize the damage caused to the environment from the negative consequences of the use of petroleum products, first of all it is necessary to influence the causes of its occurrence.

The analysis of the relevant risks during the sea transportation of hydrocarbons allows us to identify such as pollution of the water area following an emergency oil spill, probable ignition of fossil fuels, the likelihood of an explosion both on board during transportation and in port at terminals for receiving/shipping reduced natural gas (LNG) or oil terminals. Oil spills can also occur due to various emergency and other unforeseen situations that arise with ships at sea: the impact of adverse weather conditions, technical malfunctions of the vessel, collision with other vessels, pirate attacks, etc.

Over the past decades, the number of accidents at sea related to the extraction and transportation of hydrocarbons has decreased. However, the horrific consequences of the largest spills have not yet been completely eliminated. As an example, we can cite the consequences of oil pollution in the Gulf of Mexico as a result of the accident on the Deepwater Horizon oil production platform, which occurred in the spring of 2010 and caused enormous damage to the marine environment and marine and coastal ecosystems. The fire and explosion occurred as a result of a number of reasons, such as the human factor, technical problems, imperfection of the platform design. In addition, significant damage was caused to the economy of the district. Approximately 650 thousand tons of oil appeared on the surface of the sea for almost 90 days.  The oil slick spread on the surface of the sea with an area of about 75 thousand square kilometers (URL: https://www.britannica.com/event/Deepwater-Horizon-oil-spill (accessed: 10/25/2022)). The emergency situation that happened on the coast of Louisiana has become a new extremely alarming signal for the entire world community.

The disaster on the Deepwater Horizon platform clearly showed the possible risks of oil drilling in one of the most culturally and environmentally significant places in the world. Even ten years later, the consequences of the accident are visible, despite the 69 billion US dollars spent on liquidation. Scientists from the University of South Florida claim that the fish in the bay is still contaminated with hydrocarbons. The surface area of the spill itself, according to recent studies, turned out to be larger than originally thought – the pollution reaches the southernmost point of Florida. However, oil production in the Gulf of Mexico continues, although, according to members of a specially created commission under the US government to study the disaster, the state has not fulfilled all their recommendations to reduce the risk of such accidents in the future, and if drilling continues at a greater depth or at a greater distance from the coast, the risk of a new disaster may become more likely. We should not forget about the impact of the accident on the health of the population of coastal areas. 7 years after the oil spill, a study of the consequences of the accident was published, in particular on the impact on public health. Several thousand workers continue to suffer from respiratory diseases caused by the use of the drug Corexit, which was sprayed over the gulf to dissolve oil spills. It was found that workers exposed to Corexit developed cough, shortness of breath, tightness in the chest, irritation of the eyes, nose, throat and lungs (URL: https://bellona.ru/2020/05/04/spustya-desyat-let-posle-vzryva-na-neftyanoj-platforme-deepwater-horizon-risk-novyh-avarij-ne-umenshilsya / (accessed: 01.11.2022)).

Another major accident after the disaster in the Gulf of Mexico, which occurred in this case during the transportation of hydrocarbons, is the collision in January 2018 of the Panamanian tanker SANCHI, carrying about 136 thousand tons of gas condensate, with a Hong Kong bulk carrier, resulting in a tanker fire. To eliminate the accident in the South China Sea, the coast guard services of three countries - China, South Korea and Japan – were involved. However, large forces and means quickly pulled to the scene of the accident could not take effective measures to respond to such a situation. Practice has shown that there are no sufficiently effective technologies in the world to eliminate the consequences of such accidents. The consequences of the accident have not been completely eliminated so far – the sunken ship is at a depth of 115 m, and oil products continue to flow from the holes on the side (URL: https://nangs.org/news/ecology/razliv-nefti-10-krupnejshikh-katastrof-v-istorii (accessed: 29.10.2022)). This example is also an illustration of the fact that, especially in the absence of technologies necessary for the elimination of such accidents, it is necessary to develop at the international level a system of the most stringent legal regulations in all spheres of public relations related to the extraction and transportation of hydrocarbons. The elimination and prevention of oil spills in the sea is a complex task, the solution of which largely depends on the natural characteristics of each particular water area.

To increase the effectiveness of preventing accidents during the transportation of hydrocarbons by sea, it is necessary to improve the regulatory framework at the international level, as well as strict compliance with existing environmental requirements for the transportation and production of both oil and LNG.

Liquefied natural gas, consisting mostly of methane, in comparison with oil and other types of fossil fuels, has a number of significant advantages both in environmental, energy and commercial terms: the convenience of selling large volumes, a longer period of use of equipment for extraction and transportation, and most importantly – a much lower level of danger for the environment. This is due to significantly smaller emissions of carbon dioxide, sulfur oxides and nitrogen oxides when using it. The negative impact of LNG is primarily due to the consequences of methane emissions into the atmosphere during its extraction and transportation. To compare the consequences of accidental oil spills with the consequences of the release of natural gas into the environment, we can cite the situation of 2022 with the destruction due to sabotage of three strands of the Nord Stream and Nord Stream – 2 gas pipelines, which was accompanied by a massive release of gas into the environment.  The existing risk of a gas explosion under the influence of any external factors can be minimized by blocking the area around the accident site for a distance of about nine kilometers. Methane leakage itself, in comparison with an oil spill, does not have such critical negative consequences for the marine environment, since it is lighter than air, therefore, evaporates in the atmosphere. The negative effect for the environment in this case is mainly associated with the probability of a negative impact on the climate of methane emissions, which have a much greater greenhouse effect compared to carbon dioxide.

In the scientific and analytical literature, there is a tendency to replace pipeline gas with liquefied gas in the long term (until 2040). At the same time, over the past decades, there has been a transition from long-term contracts for the chartering of LNG tankers to short- or medium-term contracts [1, p. 296]. The growth in the volume of traffic dictates the need to impose increasingly stringent requirements on modern ships carrying LNG in terms of ensuring the safety of the transportation itself, as well as reducing harmful methane emissions. According to the findings of the report of the Intergovernmental Panel on Climate Change (IPCC), the oil and gas sector is one of the five main sources of anthropogenic methane emissions into the atmosphere (URL: https://www.ipcc.ch/site/assets/uploads/2018/03/WGIIIAR 5_SPM_TS_Volume_ru-1.pdf (accessed: 29.10.2022)). During the sea transportation of liquefied natural gas in cargo tanks, this type of fuel evaporates to form steam gas, which can be used as ship fuel if there is special equipment and a dual-fuel engine type on the ship. The excess of such greenhouse gas is either re-liquefied or burned in a special device. Referring to the calculations, it can be concluded that the emissions of pollutants into the atmosphere from the combustion of gas are significantly less (sulfur oxides and solid particles – by 100%, and nitrogen oxide – by slightly less than 90%) than from the combustion of petroleum types of marine fuel. According to the requirements contained in the International Convention for the Prevention of Pollution from Ships (MARPOL) (English International Convention for the Prevention of Pollution from Ships, MARPOL 73/78), all LNG tankers must comply with international environmental requirements for the content of harmful emissions in the exhaust gases of ships [3, p. 20].

It is worth noting Annex VI of MARPOL, which contains rules for the prevention of air pollution from ships. Over the past decade, there have been important additions in this aspect.

Firstly, in the autumn of 2016, the Marine Environment Protection Committee of the International Maritime Organization (IMO) decided to introduce a new requirement for marine vessels. It consisted in the fact that the ship's fuel contained no more than 0.5% sulfur by weight. The introduction of the following technologies helped to achieve the result:

· exhaust gas recirculation (EGR – Exhaust Gas Recirculation system);

· use of LNG as marine fuel;

· selective catalytic reduction of nitric oxide with ammonia.

In addition, in the spring of 2018, a mandatory Global System for collecting fuel Consumption Data began to work. As a result of the measures taken, the total amount of sulfur nitrogen (NOx) emissions decreased by 10% [2, p. 18-20]. One of the main principles of the functioning of the Global Fuel Consumption Data Collection System is, first of all, the confidentiality of the data submitted to it. Amendments to Annex VI of MARPOL also affect the Baltic region, while it should be noted that this section of the world ocean is considered one of the most vulnerable in terms of maintaining a favorable state of the marine environment due to a number of factors. This is due at least to the fact that about 10% of the total global cargo turnover runs through it (URL: https://cyberleninka.ru/article/n/strategiya-zaschity-baltiyskogo-morya-tekuschee-sostoyanie-i-perspektivy/viewer (accessed: 28.10.2022))

In order to prevent a rapid increase in costs and to search for possible options for meeting the requirements of the convention at the lowest cost, many companies have considered the possibility and expediency of using ship scrubbers, which are special mechanical devices designed to control and purify gas from solid and gaseous impurities. In addition, when using them, more intensive mixing of the purified gas with the liquid is possible. This method makes it possible to remove dust, smoke, mist and aerosols of almost any size from the gas [6, p. 21].

In 2020, the International Convention for the Prevention of Pollution from Ships (MARPOL) adopted stricter rules governing the sulfur content in marine fuel. Thus, the sulfur (SOx) content in marine fuel has been reduced from 3.5% to 0.5% since 2020, and in emission control areas (ECA): the Baltic and North Seas, the English Channel, the coast of North America and the Caribbean Sea) this indicator has been set at 0.1 %. This contributed to the massive transition to dual-fuel engines. Among fossil fuels, there are only three main options that meet the requirements for the ESA zones: fuel/distillate with a low sulfur content, heavy diesel fuel with an installed filter and LNG, since liquefied gas vessels reduce emissions of nitrogen oxides by 85-90%, and sulfur oxides by more than 99% (URL: https://wiki 5.ru/wiki/Marine_LNG_Engine / (accessed: 02.11.2022)). Working on LNG provides certain opportunities. One of these possibilities is to work on engines with two types of fuel, where the engine can be switched to liquefied gas when entering the ESA and to diesel fuel outside such zones.

In addition to MARPOL, there are currently a number of international agreements created over the past decades and ratified by many countries that regulate both the global issue of marine pollution with oil and petroleum products, and aspects aimed at improving the situation in local areas of the world ocean.

One of the fundamental documents regulating human activities at sea is the 1982 United Nations Convention on the Law of the Sea (UNCLOS), signed by more than 160 States. This international agreement regulates the procedure for the sovereign and joint use of maritime space in international relations. It establishes the division of the maritime space into internal waters, territorial sea, adjacent zone, exclusive economic zone, etc. According to the provisions of the Convention, States should cooperate among themselves to ensure long-term and stable activities related to the use of fish resources inside and outside their exclusive economic zone. Also, in accordance with the norms of the Convention, coastal States have the right to control the conduct of marine scientific research, as well as take actions to prevent possible pollution of the marine space.

The definition of "marine pollution" refers to the anthropogenic nature of substances and energy entering the marine environment that cause or create a danger of causing damage to the marine environment, marine bioresources and ecosystems, human health, as well as create obstacles to legitimate activities at sea, lead to a decrease in the quality of sea water and reduce recreational functions (Paragraph 4 of Article 1 of the Convention). A list of requirements for the prevention of marine pollution in certain situations is contained in a number of articles of the Convention. Thus, the States bordering the straits have the right to adopt regulations regulating transit passage through them, including with regard to ensuring control over pollution with petroleum products and other toxic substances (paragraph b of Article 42), as well as to ensure cooperation with transit countries in matters of pollution prevention (paragraph b of Article 43). The laying of underwater cables and pipelines on the continental shelf is allowed only if the right of the coastal State to exercise reasonable control over pollution as a result of this type of activity is ensured (Article 79). The requirements for the protection of the marine environment in the implementation of various types of activities are enshrined in Article 145 of the Convention, and Article 194 contains a list of measures to prevent, reduce and control marine pollution. Article 195 of the Convention establishes requirements to prevent the transfer of damage or danger of pollution from one area to another and the transformation of one type of pollution into another. The norms of the Convention contain provisions concerning the subjects and addressees of notification of potential or already caused damage (Article 198) and on the procedure for eliminating pollution and its consequences by joint efforts of competent international organizations and States (Article 199).

The ratio of international norms and national legislation to be adopted by the States parties to the Convention in the field of prevention, reduction and control of marine pollution in specific situations is regulated by the norms of Section 5 of the Convention (Articles 207-212).  

When analyzing the state of legal regulation of maritime safety at the international level, it is necessary to pay attention to the provisions of the International Convention for the Safety of Human Life at Sea SOLAS (English – SOLAS, International Convention for the Safety of Life at Sea). This document can be called one of the most important in the field of ensuring the safety of a ship making an international flight. The text of the document includes 14 chapters. The main purpose of this convention is to establish minimum standards that meet the safety requirements for the construction, equipment and operation of ships. Thus, the seventh chapter of the SOLAS Convention contains rules for the transport of dangerous goods.

The safety of sea transportation of oil and LNG largely depends on climatic conditions, and its legal regulation requires taking into account the peculiarities of the regions of the planet in which it is carried out. This is especially relevant for regions located in high latitudes with the most severe climate. 

In the Arctic, in comparison with other areas of the world ocean, due to the climatic features of the region, it is much more difficult to eliminate the consequences of a spill of petroleum products at sea. This is due to the temperature factor, strong winds, ice drift, as well as the lack of natural light due to the short daylight hours. In temperate climates, oil emulsification takes place relatively quickly due to bacteria living in the aquatic environment. In the Arctic, oil does not decompose in the manner described above. For decades, oil trapped in the Arctic marine environment will pose a serious danger to marine flora and fauna. It should be noted that the main international norms on cargo transportation – the Hague-Visby Rules, as well as the Hamburg Rules, do not contain separate provisions on cargo transportation in polar waters [6, pp. 42-45].

Prior to the entry into force of the Polar Code, international documents in the field of navigation in general, as well as the transportation of hydrocarbons specifically in high latitudes, were legal acts developed by the International Maritime Organization (IMO), namely: MARPOL and SOLAS. The new document in this area was supposed to reflect all the details related to the transportation of the category of dangerous goods in polar waters. "International Code for Ships Operating in Polar Waters" (Polar Code) (Resolution N MSC.385(94) of the International Maritime Organization "International Code for Ships Operating in Polar Waters (Polar Code)", entered into force, including for Russia, January 1, 2017 // Official internet portal of legal information http://www.pravo.gov.ru , December 26, 2017) is an international document that regulates not the transportation itself, but specific features of the geography of transportation of hydrocarbon raw materials in high latitudes. The Polar Code (PC) contains a new classification of vessels allowed into polar waters, depending on the conditions in which their operation is possible. The introduction of the Polar Code lists possible risks that lead to an increased probability of an accident with an LNG leak or a spill of oil and petroleum products. These risks may be associated primarily with ice, which affect the design of the vessel, its mechanisms, the stability of the vessel, as well as the ability to perform other tasks. Other possible sources of the risk of an accident include the following: icing of the upper structures, long periods of dark or light time of day, as well as critically low temperatures. They also include the lack of experience of the ship's crew in polar conditions, remoteness and lack of complete hydrographic data, lack of equipment. Paragraph 3 of this document notes the increased sensitivity of the environment to harmful substances, as well as the difference in risk levels, which vary depending on factors such as: geographical location, time of year, etc. Despite the creation of special vessels for the transportation of bulk cargoes in polar waters, as well as the adoption of the latest relevant international legal documents, the issue of ensuring the environmental safety of Arctic waters has not yet been adequately resolved. At the moment, there are still no documents in which all problematic issues arising during the transportation of hydrocarbon raw materials through polar waters have been fully resolved. Although with the adoption of the Polar Code, a big step was taken in ensuring the safety of the Arctic environment, but to this day unresolved issues remain. Thus, there is still a discrepancy between the classification of ice-class vessels in the Polar Code and the classification of Russian vessels in the Rules of Navigation in the waters of the Northern Sea Route. The requirements of the Polar Code have an impact on various stages of the ship's life cycle: design, construction and operation. Each vessel operating in polar waters must have a Certificate of a polar navigation vessel and a list of equipment and supplies attached to it, as well as a "Manual for operation in Polar Waters". The rules enshrined in the Polar Code at the time of its entry into force were set out in more detail, and also contained stricter requirements for vessels in comparison with similar norms contained in the legislation of the Russian Federation. It should be noted that the requirements imposed on ships by the Polar Code are different for ships built before and after its entry into force.

The adoption of a unified classification could be one of the ways to improve the provisions of international treaties on the transportation of oil and petroleum products by sea in polar waters, taking into account the need to effectively solve the problems of ensuring environmental safety in polar waters, as well as the difficulties associated with the elimination of the consequences of accidents that have already occurred.

There are questions about bunkering ships, as well as other issues affecting the problems of environmental protection from negative impacts. Modern legislation does not adequately regulate all aspects of ensuring environmental safety, in particular in the offshore production and transportation of such a category of particularly dangerous goods as hydrocarbons.

As mentioned earlier, appropriate Arctic-class vessels are required for the sea transportation of bulk cargoes, and in most cases the passage of such vessels is impossible without icebreaking escort. Based on considerations related to the need to develop and adopt legal acts regulating a wider range of issues of safe transportation of goods in the Arctic region, various communities and forums have been created by interested States.

To date, it can be concluded that the legal requirements for the organization of sea transportation of hydrocarbons in the Arctic region do not cover the full range of necessary tasks. That is why, taking into account the intensification of cargo transportation in general, and in particular such dangerous goods as hydrocarbons, along the Northern Sea Route, it seems necessary to combine the efforts of interested countries to develop a legal act that would regulate the environmental safety of the region at the international level.

The problem of pollution of the World Ocean with petroleum products is quite acute today and requires an integrated approach to its solution.  There is still a lack of systematization of the results of observations on the toxicity of pollutants, the duration and consequences of their effects on the physico-chemical properties of seawater. In particular, with such an observation, it is necessary to determine the source of contamination, its physico-chemical and mechanical properties, spatial distribution, depth of penetration. It seems necessary to stimulate investment in the development of technologies for the elimination of oil spills, as well as ensuring their availability to the entire world community. And legal regulation plays an important role in this process. Perhaps, in order to minimize the risks of emergency situations, it is necessary to think about combining the provisions of all conventions into a single document, about eliminating gaps both in international regulation and in the national legislation of countries engaged in sea transportation of hydrocarbons, paying increased attention to environmental safety issues.

Unfortunately, the clash of geopolitical and economic interests of various states, including in the Arctic, leads to an aggravation of conflicts between them, and competition for access to resources is often decisive in the formation of public policy in many countries [7, p. 128]. The current political situation in the world significantly complicates the interaction between states, including in the field of improving agreements regulating the sea cargo transportation of oil and petroleum products.

Along with ensuring the safety of the environment, we must not forget about the protection of human life. Despite the fact that the above-mentioned "International Convention for the Safety of Human Life at Sea" is in force today, in practice, it is necessary to regulate actions when responding to various emergency situations on oil production platforms and on ships carrying bulk cargo.

 

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REVIEW of the article on the topic "Legal protection of the marine environment during the transportation of oil and petroleum products: international legal aspects". The subject of the study. The article proposed for review is devoted to the international legal aspects of the legal protection of "... the marine environment during the transportation of oil and petroleum products ...". The author has chosen a special subject of research: the proposed issues are investigated from the point of view of international law, while the author notes that "The danger of oil spills to the environment lies in the uniqueness of their physical properties: due to wind, oil spills can drift and change shape, divide into smaller ones and at the same time move considerable distances from the accident site". The International Convention for the Prevention of Pollution from Ships (MARPOL), decisions of the Marine Environment Protection Committee of the International Maritime Organization (IMO), "a number of international agreements created over the past decades and ratified by many countries that regulate both the global issue of marine pollution with oil and petroleum products, and aspects aimed at improving the situation in the local areas of the world ocean", relevant to the purpose of the study. A certain amount of scientific literature on the stated issues is also studied and summarized, analysis and discussion with the opposing authors are present. At the same time, the author notes that "Another danger to the marine ecosystem is a violation of heat exchange in the water layers, since the film on the surface prevents the penetration of sunlight." Research methodology. The purpose of the study is determined by the title and content of the work: "... with an increase in the use of oil and petroleum products, the risk of environmental pollution increases proportionally", "In order to increase the effectiveness of preventing accidents during the transportation of hydrocarbons by sea, it is necessary to improve the regulatory framework at the international level, as well as strict compliance with existing environmental requirements for transportation and production of both oil so is LNG." They can be designated as the consideration and resolution of certain problematic aspects related to the above-mentioned issues and the use of certain experience. Based on the set goals and objectives, the author has chosen a certain methodological basis for the study. The author uses a set of general scientific, special legal methods of cognition. In particular, the methods of analysis and synthesis made it possible to generalize some approaches to the proposed topic and partially influenced the author's conclusions. The most important role was played by special legal methods. In particular, the author used a formal legal method, which allowed for the analysis and interpretation of the norms of current international law. In particular, the following conclusions are drawn: "... the issue of ensuring the environmental safety of Arctic waters has not yet been adequately resolved. At the moment, there are still no documents that would fully resolve all problematic issues arising in the process of transporting hydrocarbons through polar waters," etc. Thus, the methodology chosen by the author is to a certain extent adequate to the purpose of the article, allows us to study many aspects of the topic. The relevance of the stated issues is beyond doubt. This topic is one of the most important in the world and in Russia, from a legal point of view, the work proposed by the author can be considered relevant, namely, he notes "... taking into account the intensification of cargo transportation in general, and in particular such dangerous goods as hydrocarbons, along the Northern Sea Route, it seems necessary to combine the efforts of interested countries to develop a legal an act that would regulate the environmental safety of the region at the international level." And in fact, an analysis of the works of opponents and international acts should follow here, and it follows (albeit to a limited extent) and the author shows the ability to master the material. Thus, scientific research in the proposed field is only to be welcomed. Scientific novelty. The scientific novelty of the proposed article raises some doubts. It is not expressed in the specific scientific conclusions of the author. Among them, for example, is the following: "Perhaps, in order to minimize the risks of emergency situations, it is necessary to think about combining the provisions of all conventions into a single document, about eliminating gaps both in international regulation and in the national legislation of countries engaged in marine transportation of hydrocarbons, paying increased attention to environmental safety issues." As can be seen, these and other "theoretical" conclusions cannot be used in further scientific research, because they are declarative and general. Thus, the materials of the article as presented may be of interest to the scientific community only from the point of view of describing and analyzing various international documents without specific scientific conclusions. Style, structure, content. The subject of the article corresponds to the specialization of the journal "International Law and International Organizations", as it is devoted to international legal aspects of the legal protection of "... the marine environment during the transportation of oil and petroleum products ...". The article contains an analysis of the opponents' scientific works, so the author notes that a question has already been raised that is relatively close to this topic and the author uses their materials, discusses with opponents. The content of the article corresponds to the title, since the author considered the stated problems and achieved the goal of his research. The quality of the presentation of the study and its results should be recognized as improved. The subject, tasks, and methodology directly follow from the text of the article, but the specific results of the legal research and scientific novelty are not revealed. The design of the work does not fully comply with the formal requirements for this kind of work. No significant violations of these requirements were found, except for the lack of literature in the volume required by the publisher (at least 12 works), and many inactive links in the article. Bibliography. The quality of the literature presented and used should be assessed. However, it would be correct to use additional literature, since the presence of scientific legal literature in greater numbers shows the validity of the author's conclusions. The works of the above authors correspond to the research topic, have a sign of sufficiency, and contribute to the disclosure of some aspects of the topic. Appeal to opponents. The author has analyzed the current state of the problem under study. The author describes the opponents' different points of view on the problem, argues for a more correct position in his opinion, relying in some cases on the work of opponents, and offers solutions to certain common problems. Conclusions, the interest of the readership. The conclusions are logical, not quite specific: "The adoption of a unified classification could be one of the ways to improve the provisions of international treaties on the transportation of oil and petroleum products by sea in polar waters, taking into account the need to effectively solve the problems of ensuring environmental safety in polar waters, as well as the difficulties associated with eliminating the consequences of accidents that have already occurred", "Along While ensuring the safety of the environment, we must not forget about the protection of human life." The article in this form may be of interest to the readership in terms of the systematic positions of the author in relation to the issues stated in the article, which should be typical for legal research. Based on the above, summing up all the positive and negative sides of the article, I recommend "publishing" taking into account the comments (especially the bibliography).