STS PLANS - Industry confusion! Action by flag states is required.

All tanker vessels that participate in STS operations have an approved STS Plan, either from the Flag administration or the respective RO. The Plan should be developed on the basis of MEPC 186(59) and include procedures that reflect the Technical Operators policies ?on how STS operations should be conducted? in line with minimum requirements of industry guidelines and MARPOL chapter 8 of ANNEX 1. It has been noticed lately that there is no adequate knowledge to Tanker Operators, with respect to the validity of their vessels? STS plans. As a result, some Tanker Operators fail to comply with the commercial or statutory requirements, with possible consequences on their vessel employment.

The question is simple.

Do you have to revise your STS PLANS according to the latest CS/OCIMF/SIGTTO/CDI ?Ship to Ship Transfer Guide, for Petroleum, Chemicals and Liquefied Gases? First Edition 2013?

The answer is YES, you should have them revised and re-approved by the flag or RO.

COMMERCIAL ISSUES

• In all charter party agreements, STS Operations take place according to the ?Latest STS guidelines?. Therefore such commercial requirement has to be also reflected in the SMS and STS Plans.
• The new VIQ 6 (March 2014 as amended on March 2015) already issued by OCIMF, includes questions 8.84-8.87 for STS associated issues covering oil tankers and respectively for chemical and gas tankers in succeeding sections. The following is mentioned at the new VIQ 6. ?Operations plan shall be developed taking into account the information contained in IMO?s ?Manual on Oil Pollution, Section 1, Prevention and the ICS/OCIMF/SIGTTO/CDI ?Ship to Ship Transfer Guide, for Petroleum, Chemicals and Liquefied Gases? First Edition November 2013.?
• Vetting inspections by oil majors will require to have the new STS guidelines implemented on board your vessels and this is reflected in the SMS through the STS Plan. The content of the latest OCIMF guidelines and FORMS have changed to a great deal, and revision of the STS PLAN is strongly recommended.
• If your vessel has passed a SIRE inspection within 2015, it is expected that your STS PLAN is according to the latest OCIMF guidelines or alternatively, the SIRE Inspector is supposed to have made a comment on this issue.

STATUTORY ISSUES

Currently only two flag administrations have issued Marine Notices associated with the necessity of revision of STS plans. Those are Liberia and Marshall Islands. We consider that other major flag administrations should also issue relevant notices. Although IMO MEPC 186(59) made clear reference to the OCIMF/ICS 2005 edition, it should be noted that the reference was included on a footnote rather on the main content of the resolution.

• LIBERIA administration has issued Marine Notice POL-011 Rev. 05/14 which make reference on the ICS/OCIMF/SIGTTO/CDI ?Ship to Ship Transfer Guide, for Petroleum, Chemicals and Liquefied Gases? First Edition November 2013. Therefore all vessels under the Liberia registry should revise their STS PLANS
• MARSHAL ISLAND administration has similarly issued Marine Notice No. 2-013-10 Rev. 11/14. Therefore all vessels under the Marshal Island registry should revise their STS PLANS after 1st July 2015. Updates shall be carried out by the date of the first annual, intermediate or renewal IOPP survey, following the latest revised version, as applicable. Attention is drawn to the approval letters issued by the ROs. Such approval letters should make reference on ICS/OCIMF/SIGTTO/CDI ?Ship to Ship Transfer Guide, for Petroleum, Chemicals and Liquefied Gases? First Edition November 2013.

When is it necessary to revise the STS Plan and request re-approval from Flag or RO?

The STS Plan should be revised if any of the following cases apply:

• When a new tank vessel is purchased
• When the OCIMF produces an amended version of the latest guidelines. This is a commercial requirement and not statutory. MARPOL makes a reference in the 4th edition of ICS/OCIMF STS guidelines and not in the latest edition/publication. However STS Operations are being performed as per the STS clause as included in the charter party, which normally refers to the latest guidelines.
• When STS policies and procedures are altered and subject to the requirements of the approval letter from the Flag or RO.
• In case the vessel is registered under a new Flag/ Maritime administration. The STS plan does not need re-approval for amendments in appendixes and check lists, if this is not explicitly specified in the approval letter.

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