SHIP-TO-SHIP OPERATIONS. Do they take place according to OCIMF guidelines?

Ship-to-Ship transfer operations are governed by the MARPOL chapter 8 of ANNEX I, latest OCIMF guidelines and IMO manual on oil pollution, section I, prevention chapter 6. These are the references that prescribe the requirements for procedures towards ensuring safety in all aspects, from the vessel nomination and clearance until the completion of the operation. Implementation of the regulations and guidelines take place through Tanker Operators ISM, TMSA procedures, as prescribed in their Safety Management System.

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IMPLEMENTATION OF POLICIES

ISM procedures and TMSA assessment actions contain the necessary tools for implementing the regulations for the ?proper and detailed planning?¹ as well as the post evaluation. Risk assessment procedures should include apart from operational hazards, other risks, associated with the involvement of third parties, such as the Service Provider who provides the POAC and STS Equipment. STS records should be retained for 3 years, as a statutory requirement. Hence, the assessment of such records provides an extra level of valuable information for STS operations. POAC² screening is included as a procedure at the IMO Manual on oil Pollution and the STS Equipment should be according to ISO 17357:2002. Furthermore, the number and type of fenders as well as rigging pattern, should take place according to OCIMF guidelines.

The quality assurance of third parties is of paramount importance. For this reason OCIMF guidelines provide the ability to the ?users? (i.e. the Master and his Tanker Operator) to exercise their due diligence with respect to the quality of the services of the Service Provider.

The Master should not proceed with the STS Operation, unless he is confident that the operation has been properly planned and that the Service Provider has presented a comprehensive JOINT STS plan which has received the Master?s consent.

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THE ROLE OF THE MASTER

For all ship to ship transfer operations each Master is responsible at all times for the safety on his own ship, including her crew, cargo and equipment. Each Master must not allow the safety on his ship to be compromised through the actions of others, such as the Service provider and the POAC. Both Masters must ensure that the procedures recommended by latest OCIMF guidelines are followed as a contractual commitment³ and assurance towards safety.

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COMPLACENCY AND IT'S EFFECT

Complacency is a factor that can not be neglected during STS Operations. Familiarity of seafarers,with the operation, is not always the main root cause for complacency. The most important root cause is considered to be the existence of the service provider and POAC. The presence of an expert relieves the Master and crew and provides a level of assurance that the job will take place with professionalism and according to OCIMF guidelines. However, this is not always the case! Not all Service Providers provide the same level of assurance. As a consequence, if something goes wrong the Master and crew will have the responsibility for not having exercised their due diligence, as they ought to!

In various incident investigations, complacency has been recognized as the "root cause". The source of this information is available to those interested.

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PROPOSED PRACTICES

STS Operations require proper planning, which starts from the nomination of the participating vessel, and progress with the technical advice to the Master, from his principals. The following procedures are proposed to be followed:

1. During vessel nomination, the Tanker Operator should consider the clearance with respect to vessel suitability, STS location and past STS Company Records etc. The tanker operator should act with due care at this stage and justify his clearance on the basis of established policies.
2. Prior commencement of each STS Operation, the Tanker Operator should confirm that the nominated POAC is qualified according to IMO regulations and that he has sufficient experience in same size and type of vessels.
3. The Tanker operator should request the certificates of fenders and hoses in order to confirm that those are manufactured and maintained according to ISO 17357:2002.
4. The Service provider should present to the Master a JOINT PLAN for the operation. The Plan should include the nominated size and type of fenders, suggested Mooring Plan etc.
5. The Master should confirm that the fenders are according to OCIMF fender selection guidelines. Should those are different; this should be discussed and further clarified with the provider.
6. The STS Operation should be completed according to the approved STS PLAN.
7. After completion, records should be returned to the Tanker Operator and be assessed for future reference for the clearance phase and proper planning.

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onlineSTS.net Team.