Introduction to new CHAPTER 8 to MARPOL and ANNEX 1

Presented by Captain Bob Gilchrist SafeSTS

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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 Full implementation 1st April 2012

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Change in STS regulation by Marpol implemented through Vessel ISM

Say what you do Do what you say Record it Enforce accountability

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IMO Regulation Marpol Chapter 8

Reporting requirement to appropriate authorities

Vessel specific STS Plan

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Reporting Requirement
48 hours Notice to Authorities for Ops within territorial waters or EEZ of a party to the convention

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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
Confirmation of vessel having STS Plan Service provider and/or name of POAC

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Vessel Specific STS Plan IMO Guidance 6.2.4.2

1. Step-by-step description of entire operation

2. Detailed description of mooring operations

3. Detailed description of cargo / ballast procedures 4. Titles / duties / locations list for all persons involved 5. Emergency shutdown / communications for emergency breakaway

6. Oil spill plan

7. Contingency plan that meets 6.2.9 8. Cargo and ballast plan

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Contingency plan
1. Risk assessment (as per Sec: 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. Emergency duties for designated crew

4. Consideration on standby vessel 5. SOPEP or VRP integration 6. Action in the event of a spill

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Vessel Specific STS Plan IMO Guidance 6.2.4.2

1. The Vessel plan does not on its own full-fill the requirements of the IMO

2. The Service Provider must provide a significant amount of information required by the Vessel Plan for each area
3. All this information must be collated on the vessel prior to the operation starting. 4. The Joint Plan of Operations needs to be compiled 5. The POAC is responsible to the Coastal State for completing this task and following the plan

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Joint Plan of Operations

A combination of documents and checklists providing a system that ensures the operation is carried out safely. A documented record retained by the vessel showing compliance to vessels STS Plan.

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Joint Plan of Operations

Local Area Information and Risk Assessment

Qualifications of the POAC provided

Certificates of equipment supplied Area Specific Operations Manual Mooring/Unmooring Plans

Emergency Response/ Contingency Plan

Fender rigging diagram Tanker Loading/Discharge plans (MSDS) STS and Tanker Safety Checklists

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POAC At least the following Qualifications

Appropriate Management level International Standard Certificate of Competency All STCW and Dangerous Cargo Endorsements up to date and appropriate for the ship GMDSS Cargo familiarisation course Attendance at a Suitable Ship handling course Oil spill response training

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POAC Experience
Tanker loading/unloading

Thorough knowledge of the transfer plan

Thorough knowledge of the transfer area and surrounding areas Conducted a suitable number of operations in similar circumstances Oil spill response techniques and equipment familiarisation

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POAC Responsibility
Ensure the plans are followed on both vessels

Advise both masters

Brief both vessel crews Ensure communications satisfactory Ensure safety checks are undertaken

Ensure the provisions of the contingency plans followed in the event of a spill
Ensure all required reports to authorities are made

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Pre-Marpol Responsibilities
Coastal Authorities and Flag state

Vessel masters

Vessel Crew

STS Superintendent

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Post-Marpol Responsibilities
Coastal Authorities and Flag state

POAC?

Vessel masters (2 ships)

Vessel Crew

STS Superintendent

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Responsibilities
Coastal Authorities and Flag State
Designated by The Administration

POAC
Authority to Stop the Op. or amend the plan Responsible for the Ship/Ship Interface

Named in notification to Coastal State

Professionally Qualified

Vessel Master
Responsible for his own vessel

Experience of local area and resources unique to the STS operation.

Clearly Defined Responsibilities' on both vessels

Vessel Crew

STS Superintendent

Knowledge or ownership of the STS equipment

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Experienced Master Mariner 21 years at Sea up to the Rank of Master on Tankers of all types 12 years as Mooring Master Qualified On-Scene Commander for Oil Spill Response As Mooring Master you do not sign on the vessel. 2008 MCA did not renew DCE or GMDSS basis no official Sea-Time 28 Days Sea-time as deck officer to renew DCE Questions; 1 Is he Qualified under Marpol, can he act as POAC? 2 This guys name is Capt Bob Gilchrist..what do I do? 1 Ignore it, its not me that will carry the contingent Liability 2 Dont Ignore it and effectively reduce operational personnel 3 Admit to client and allow ship-owners to note a nonconformance to ISM

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Enforcement of STS Regulation

Records of compliance have to be retained onboard for three years

A non-compliant vessel could be;

Not keeping proper records Improperly filling in Oil Record Book In breach of the ISM Code

In breach of Marpol Regulations

If the plans are not followed, in addition to the vessels responsibilities, the POAC may individually be held accountable by the Coastal State for an incident

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Considerations
Charter Party Clauses

Insurance for POAC

Is the Master Insured to take responsibility for professionally advising another vessel in the role of POAC.
(e.g.. If the other vessel has a pollution incident, the POAC/Master may initially be accountable to the Coastal State)

Acting as the Pilot the STS Superintendent/Master/POAC is outside the protection of the Pilotage act. He can be held responsible for damage to the other vessel
(quote from Norton Rose, Maritime lawyers)

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What do the changes mean?

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

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Thank you for your attention Please feel free to ask questions
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
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