ISTEC Meeting
London
October 2011
Introduction to a new
CHAPTER 8 to MARPOL and
ANNEX 1
IMO Chapter 8 - Implementation
IMO adopted by Resolution MEPC. 186(59) a new
Chapter 8 to Marpol and Annex I, aimed at the
prevention of pollution during Ship-to-Ship Transfer
of oil cargo. Implementation has started on Jan
2011 with full implementation for Jan 2012
Change in STS regulation by Marpol
Implemented through Vessel ISM
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Say what you do
Do what you say
Record it
Thereby enforce accountability
IMO Regulation
Marpol – Chapter 8
Reporting requirement to
appropriate authorities
Vessel Specific STS Plan
Reporting Requirement
• 48 hours Notice to Authorities for
ops within territorial waters or
EEZ.
Details of the Report
Notification to authorities
• Details of the ships
• Time and location of transfer
• Type of STS operation
• Oil type and quantity
• Duration of STS
• Service Provider and/or name of POAC
• Confirmation of vessel having STS Plan
Flag Administrations have “teeth”
They can (and sometimes do) have additional requirements like;
• (Gibraltar) Asking for the STS Plans
• (Denmark) Approving (or Disapproving) the POAC
• (UK) Requiring a vessel inspection pre operation (i.e.;
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Implement the Paris Memorandum)
Impose additional pollution response measures;
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(UK) Tier 2 response
(Panama) Assign pollution officer
(Korea) Response boat with operation
(Spain) Ultimately stop the operation going ahead
Vessel Specific STS Plan
IMO Guidance 6.2.4.2
1.
2.
3.
4.
5.
6.
7.
8.
Step-by-step description of entire operation
Detailed description of mooring operations
Detailed description of cargo / ballast procedures
Titles/Duties/Locations list for all persons involved
Emergency shutdown/communications for emergency breakaway
Oil spill plan
Contingency plan that meets 6.2.9
Cargo and ballast plan
Vessel Specific STS Plan
IMO Guidance 6.2.4.2
1.
2.
3.
4.
5.
The Vessel plan does not on its own full-fill the
requirements of the IMO.
The Service provider must provide a significant amount of
information required by the Vessel Plan for each area.
All this information must be collated on the vessel prior to
the operation starting.
The POAC is responsible to the Coastal State for completing
this task and following the plan.
Due diligence by the ship-owner is not just a paperwork
exercise. There are potentially severe penalties for non
compliance
Contingency plan
1. Risk assessment (As per Sect 1 - 6.3 Manual on Oil Pollution)
2. Mitigation measures and plans
1. Covering all possible emergencies
2. Providing comprehensive response
3. Notification to Authorities
3.
4.
5.
6.
Emergency duties for designated crew
Consideration on standby vessel
SOPEP or VRP integration
Action in the event of a spill
The role of the “POAC”
PERSON IN OVERALL ADVISORY CONTROL
Regulatory Compliance
Technical Guidance
Procedural Delivery
Safety Supervision
POAC
Qualifications;
• International Standard Certificate of Competency
• All STCW and Dangerous Cargo Endorsement up to
date and appropriate
• GMDSS
• Ship Handling Course
• Cargo familiarisation course
• Oil spill Response training
POAC
Experience;
• Tanker loading/unloading
• Thorough knowledge of the transfer area and
surrounding areas
• Conducted a suitable number of operations in
similar circumstances
• Regional Oil-Spill Response capability as part of the
response plan
• Thorough knowledge of the transfer plan
POAC
Responsibility;
• Ensure the plans for both vessel are followed
• Advise both masters
• Ensure contingency plans followed
• Ensure reports to authorities are made
• Brief both vessel crews
• Ensure communications satisfactory
• Ensure safety checks are undertaken
Case Study
Bunker Storage Vessels;
A sea going vessel is acting a floating storage
for months or years.
A bunker tanker fills up her tanks alongside on
a regular basis.
Is this operation affected by the new
regulations?
Case Study
Bunker Storage Vessels;
• This is wrongly considered as bunkering in
some ports. It is Ship-to-Ship.
• Vessels are both over 150 GRT therefor
both need to comply with Marpol.
Potential Issues
• Vessel STS Plans are too big to email.
• Charter Party clauses do not cover new rules.
• Plans not compatible
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Plan WX Criteria not suitable for intended
operations
Vessel criteria (e.g.. open chocks on daughter
vessel)
POAC qualifications
Working hours
Pollution response requirement
Points to Ponder
• Insurance for POAC.
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•
Is the Master Insured to take responsibility for
advising another vessel as per POAC. (e.g.. If
the other vessel has a pollution incident, the
POAC/Master is accountable to the Coastal
State for compliance to the plan).
Acting as the “Pilot” offshore is outside the
protection of the Pilotage act. The POAC
could potentially be held responsible for
damage to the other vessel if the plan is not
followed (quote from Norton Rose. Maritime
lawyers).
Enforcement of STS Regulation
• Records of compliance have to be retained
onboard for three years.
• A non-compliant vessel could be;
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•
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Improperly filling in Oil Record Book
In breach of the ISM Code
In breach of Marpol Regulations
• If the plans are not followed, the POAC may
initially be held accountable for incidents by
the Coastal State.
What do the changes mean?
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Greater power for Coastal State
Increased ship-owner liability
Increased Master/POAC liability
Increased responsibility for STS Service Provider / POAC
Threat to reputation from substandard operations
Additional cost implication
Delays from slow notification
Delays due to non-compatibility of vessels
Loss of trading opportunity from rejected plans
Example Guidance for Implementation
Ship to Ship Transfer Operation Plan
(Design and Audit Checklists)
Lloyds Register website
www.lr.org
ISO Accreditation
• SafeSTS is ISO 9001:2008 accredited for STS
transfers
Contacts
If you would like
further information
please contact us...
Tel: +44 (0) 1379 640021 (UK) or
Tel +65 9818 6203 (Singapore)
Email: operations@safests.com
Website: www.safests.com