Presentation on theme: "ISTEC Meeting London October 2011 Introduction to a new"— Presentation transcript:
1 ISTEC MeetingLondonOctober 2011Introduction to a newCHAPTER 8 to MARPOL andANNEX 1
2 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
3 Change in STS regulation by Marpol Implemented through Vessel ISM Say what you doDo what you sayRecord itThereby enforce accountability
4 IMO Regulation Marpol – Chapter 8 Reporting requirement to appropriate authoritiesVessel Specific STS Plan
5 Reporting Requirement 48 hours Notice to Authorities for ops within territorial waters or EEZ.
6 Details of the Report Notification to authorities Details of the ships Time and location of transferType of STS operationOil type and quantityDuration of STSService Provider and/or name of POACConfirmation of vessel having STS Plan
7 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.; Implement the Paris Memorandum)Impose additional pollution response measures;(UK) Tier 2 response(Panama) Assign pollution officer(Korea) Response boat with operation(Spain) Ultimately stop the operation going ahead
8 Vessel Specific STS Plan IMO Guidance 18.104.22.168 Step-by-step description of entire operationDetailed description of mooring operationsDetailed description of cargo / ballast proceduresTitles/Duties/Locations list for all persons involvedEmergency shutdown/communications for emergency breakawayOil spill planContingency plan that meets 6.2.9Cargo and ballast plan
9 Vessel Specific STS Plan IMO Guidance 22.214.171.124 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
10 Contingency planRisk assessment (As per Sect Manual on Oil Pollution)Mitigation measures and plansCovering all possible emergenciesProviding comprehensive responseNotification to AuthoritiesEmergency duties for designated crewConsideration on standby vesselSOPEP or VRP integrationAction in the event of a spill
11 The role of the “POAC” PERSON IN OVERALL ADVISORY CONTROL Regulatory ComplianceTechnical GuidanceProcedural DeliverySafety Supervision
12 POAC Qualifications; International Standard Certificate of Competency All STCW and Dangerous Cargo Endorsement up to date and appropriateGMDSSShip Handling CourseCargo familiarisation courseOil spill Response training
13 POAC Experience; Tanker loading/unloading Thorough knowledge of the transfer area and surrounding areasConducted a suitable number of operations in similar circumstancesRegional Oil-Spill Response capability as part of the response planThorough knowledge of the transfer plan
14 POAC Responsibility; Ensure the plans for both vessel are followed Advise both mastersEnsure contingency plans followedEnsure reports to authorities are madeBrief both vessel crewsEnsure communications satisfactoryEnsure safety checks are undertaken
15 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?
16 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.
17 Potential Issues Vessel STS Plans are too big to email. Charter Party clauses do not cover new rules.Plans not compatiblePlan WX Criteria not suitable for intended operationsVessel criteria (e.g.. open chocks on daughter vessel)POAC qualificationsWorking hoursPollution response requirement
18 Points to Ponder Insurance for POAC. 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).
19 Enforcement of STS Regulation Records of compliance have to be retained onboard for three years.A non-compliant vessel could be;Improperly filling in Oil Record BookIn breach of the ISM CodeIn breach of Marpol RegulationsIf the plans are not followed, the POAC may initially be held accountable for incidents by the Coastal State.
20 What do the changes mean? Greater power for Coastal StateIncreased ship-owner liabilityIncreased Master/POAC liabilityIncreased responsibility for STS Service Provider / POACThreat to reputation from substandard operationsAdditional cost implicationDelays from slow notificationDelays due to non-compatibility of vesselsLoss of trading opportunity from rejected plans
21 Example Guidance for Implementation Ship to Ship Transfer Operation Plan (Design and Audit Checklists)Lloyds Register website
22 SafeSTS is ISO 9001:2008 accredited for STS transfers ISO AccreditationSafeSTS is ISO 9001:2008 accredited for STS transfers
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