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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 duringShip-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 RegulationMarpol 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 operations3. 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 plans1. 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 informationrequired 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 taskand 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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POACAt 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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POACExperience

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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POACResponsibility

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

Vessel masters

STS Superintendent

Coastal Authorities and Flag state

Vessel Crew


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Post-Marpol Responsibilities

Vessel masters (2 ships)

STS Superintendent

Coastal Authorities and Flag state

Vessel Crew

POAC?


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Responsibilities

POACAuthority to Stop the Op. or amend the plan

Responsible for the Ship/Ship Interface

STS Superintendent

Coastal Authorities and Flag State

Vessel Crew

Vessel Master

Responsible for his own vessel

Designated by The

Administration

Experience of local

area and resources

unique to the STS

operation.

Professionally

Qualified

Named in

notification to

Coastal State

Clearly Defined

Responsibilities' on

both vessels

Knowledge or

ownership of the

STS equipment


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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

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

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 Liability2 Dont Ignore it and effectively reduce operational personnel

3 Admit to client and allow ship-owners to note a non-

conformance 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 outsidethe 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: [email protected]

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