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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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