Annex 1 - Recommended Provisions of the Revised MARPOL Annex I for Application to FPSOs and FSUs
Clasification Society 2024 - Version 9.40
Statutory Documents - IMO Publications and Documents - Guidelines - Guidelines for the Application of the Revised MARPOL Annex I Requirements to Floating Production, Storage and Offloading Facilities (FPSOs) and Floating Storage Units (FSUs)Resolution MEPC.139(53) Amended by Resolution MEPC.142(54) - Guidelines for the Application of the Revised MARPOL Annex I Requirements to FPSOs and FSUs - Annex 1 - Recommended Provisions of the Revised MARPOL Annex I for Application to FPSOs and FSUs

Annex 1 - Recommended Provisions of the Revised MARPOL Annex I for Application to FPSOs and FSUs

Article Subject Basis of Application
     
Art. 2(3)(b)(ii) Def. Discharge In accordance with Reg. 39 and UI 50, produced water, offshore processing drainage and displacement water are not included in the meaning of discharge.
Art. 2(4) Def. Ship FPSOs/FSUs are "fixed or floating platforms" and are therefore included in this definition.
Regulation Subject Basis of Application
     
1.1 to 1.4 Defs. Oil, Crude Oil, Oily mixture, Oil fuel Applies.
1.5 Def. Oil tanker FPSOs/FSUs are adapted primarily for a purpose other than to carry (transport) oil and are therefore excluded from this definition.
1.6 and 1.7 Defs. Crude Oil tanker, Products carrier Not applicable.
1.8 Def. Combi.carrier Not applicable for same reasons as 1.5.
1.9 Def. Major conversion Conversion of an oil tanker or combination carrier to an FPSO/FSU and vice versa should be considered to be a major conversion. Alterations or modifications required for an existing FPSO/FSU to move to another field should not be considered a major conversion.
1.10 and 1.11 Defs. Nearest land, Special area Apply.
1.12 Def. Instantaneous rate of discharge of oil Not applicable to FPSO/FSU at operating station as this definition applies when the ship is under way (refer regs. 34.1.4 and 31.2, 31.3 and 36.6).
1.13 to 1.26 Defs. Various Apply.
1.27 Def. Anniversary date Applies.
1.28.1 and 1.28.2 Defs. Ship age groups Apply.
1.28.3 to 1.28.8 Defs. Oil tanker age groups Not applicable.
1.29 Def. ppm Applies.
2.1 Application Applies.
2.2 and 2.3 Application Not applicable as the scope of application of these Guidelines is for FPSOs and FSUs when located at their normal operational station, including where appropriate temporary disconnection from the riser at the operating station for the minimum period necessary to ensure the safety of the vessel in extreme environmental or emergency conditions.
2.4 Application Not applicable.
2.5 and 2.6 Existing tankers engaged in specific trades Not applicable.
3.1 to 3.3 Exemptions and waivers Any Administration using this clause in relation to FPSOs/FSUs would need to justify such use in relation to the terms of paragraph .1 and in accordance with the requirements of paragraph .3.
3.4 and 3.5 Exemptions and waivers Recommend application in order to sanction the waiver arrangements outlined in 31.2, eg. for operations within special areas (3.5.2.1) in compliance with 3.5.2.3 to 3.5.2.6. Transfer of oily mixtures to offload tankers for discharge ashore is acceptable within this waiver.
4 Exceptions Applies.
5 Equivalents Applies.
6 Surveys and inspections Applies. Notwithstanding whether SOLAS’74 applies to an FPSO/FSU, surveys of FPSOs and FSUs should be conducted to the standard specified for oil tankers in SOLAS’74 regulation 11-2, except for the provisions of 2.2 of Annex B to resolution A.744(18) as amended in relation to dry-dock survey. The coastal and flag States may accept bottom survey of the ship afloat instead of in dry-dock when the conditions are satisfactory and the proper equipment and suitably qualified personnel are available.
7 Issue of certificate IOPP Certificate should be issued unless flag and coastal States have other means of certificating/documenting compliance.
8 Issue of certificate by another Government Applicable.
9 Form of certificate Applicable. When completing the IOPP certificate, FPSOs’/FSUs’ "type of ship" should be shown as "ship other than any of the above" and this entry should be annotated with "FPSO" or "FSU" together with details of operational location. Record of Construction and Equipment for FPSOs and FSUs given at Annex 2 should be used for the IOPP Supplement. Where this is done Form A or Form B required by the Convention need not be provided.
10 Duration of certificate Applicable.
11 Port State control on operational requirements Applies to FPSO/FSU at its operating station, recognizing that under Art. 2(5) and UNCLOS Arts. 56 and 60, the coastal State exercises sovereign rights for the purposes of exploration and exploitation of their natural resources. However, port State control powers are applicable at other times such as if the FPSO/FSU voyages to a port in another State for maintenance purposes.
12 Tanks for oil residues (sludge) Applicable.
12A Oil fuel tank protection Applies to new purpose built FPSOs and FSUs only excluding the requirements of paragraph 6. However, when undertaking any voyage away from the operating station for whatever purpose, the double bottom oil fuel tanks are to be empty unless they are in compliance with the requirements of paragraph 6.
13 Standard discharge connection Applicable.
14 Oil filtering equipment Applicable subject to applicable provisions of Reg. 15 and 34. For reasons of practicality, the equipment need not be fitted provided the machinery space discharges are disposed of in accordance with options a, b, d or e in relation to regulation 15.2. A waiver may be issued under 14.5.3, where all oily mixtures are discharged either ashore or into production stream.
15A Discharges outside special areas In accordance with Reg. 39 and UI 50, applies only to machinery space discharges and contaminated sea water from operational purposes such as produced oil tank cleaning water, produced oil tank hydrostatic testing water, water from ballasting of produced oil tank to carry out inspection by rafting. Since FPSOs/FSUs and other fixed and floating platforms cannot comply with 15.2.1 when operating on station then these oils and oily mixtures may, with the agreement of the coastal State:
  • a. be sent ashore;
  • b. be incinerated;
  • c. have water separated and discharged if not exceeding 15ppm oil content under 34.2;
  • d. be discharged in accordance with this clause subject to waiver of the en route requirement;
  • e. be added to the production stream; or
  • f. be treated using a combination of these methods.
15B Discharges in special areas Applicable, but FPSOs/FSUs cannot comply with 15.3.1 when operating on station. This requirement should be handled consistent with 15A above. Coastal State may issue dispensation from 15.3.1 where satisfied that this dispensation does not prejudice the environment.
15C and 15D Requirements for ships <400GT and general req. Applies.
16.1, 16.2 and 16.4 Segregation of oil and water ballast and carriage of oil in forepeak tanks Applies. The principles of 16.3 should be extended to all other FPSOs and FSUs.
16.3 " Applies to FPSOs/FSUs which are capable of disconnecting from the riser at the operating station as collision bulkhead requirement is in SOLAS rather than MARPOL. This principle is also relevant to stern collision as per 19.7.
17 Oil Record Book Part I Applies.
18.1 to 18.9 Segregated ballast tanks Recommend application subject to the conditions listed for 18.2 and 18.3.
18.2 " Not applicable, but FPSO/FSU should have sufficient ballast capacity to meet stability and strength requirements in design and operational conditions of loading.
18.3 " Recommend application noting that there should normally be separation between ballast and produced oil (crude) tanks and pumping systems, but temporary cross-connection may be permitted for the duration of transfer operations. In such exceptional cases where sea water is introduced into produced oil tanks for the operational purposes listed above in relation to 15.2, it should be dealt with as provided for under that clause.
18.8.1 to 18.8.4 Requirements for oil tankers with dedicated clean ballast tanks Recommend application similar to 18.1 to 18.9.
18.10.1 Existing oil tankers having special ballast arrangements Recommend application to meet 18.2 and 18.3 as modified by these Guidelines.
18.10.2 " Recommended application consistent with 18.3 and 35.2 as modified by these Guidelines.
18.10.3 " Not applicable.
18.11 SBT for oil tankers >=70,000DWT delivered after 31.12.79 Recommend application subject to the conditions listed for 18.2 and 18.3.
18.12 to 18.15 Protective location of segregated ballast spaces Not applicable. Refer 19.3.1 for corresponding provisions in relation to both new purpose-built FPSOs/FSUs and other non-purpose-built FPSOs/FSUs.
19 Double hull and double bottom requirements for oil tankers delivered on or after 6.07.96 Not applicable, except as detailed below.
19.3.1 and 19.3.6 " Recommend application to new purpose-built FPSOs/FSUs so as to provide protection against relatively low-energy collision. (NOTE: Appropriate measures should also be taken for other FPSOs/FSUs to address this collision hazard).
19.5 " Applicable to the extent that the Guidelines referred to can be used to demonstrate equivalency with 19.3.1 and 19.3.6 as modified above.
19.7 " Recommend application to new construction purpose built FPSOs/FSUs and other FPSOs/FSUs which are arranged with a fore peak or collision bulkhead. Similarly, oil should not be held in integral tanks located at the stern in FPSOs/FSUs which may offload to a tanker moored astern or alongside of the FPSO/FSU.
19.8 " Recommend application to new construction purpose built FPSOs/FSUs and other FPSOs/FSUs which may be modified to meet this regulation.
20 (as amended by resolution MEPC.111(50)) Double hull and double bottom requirements for oil tankers delivered before 6.07.96 Not applicable.
21 Prevention of pollution from oil tankers carrying heavy grade oil as cargo Not applicable.
22 Pump-room bottom protection Not applicable.
23 Accidental oil outflow performance Not applicable.
24 Damage assumptions Recommend application with regard to side damage only. It is recommended that protective measures, such as fendering, be used to minimize side impact damage such as that which might be experienced during offloading and supply vessel berthing operations. Such protection, however, should not be considered to reduce the minimum transverse extent of side penetration damage.
25 Hypothetical outflow of oil Recommend application for side damages only in accordance with 24 above.
26 Limitation of size and arrangement of cargo tanks Recommend application based on 24 and 25 above.
27 Intact stability Recommend application.
28.1 to 28.5 Subdivision and damage stability Recommend application only in respect of side damage in accordance with 24 above.
28.6 Damage assumptions for oil tankers >=20,000DWT delivered on or after 6.07.96 Not applicable.
29 Slop tanks Applies.
30.1 Pumping, piping and discharge arrangement Applies, except that manifold is to be provided in at least one position on the FPSO/FSU.
30.2 " Not applicable for FPSOs.
30.3 to 30.7 " Recommend application, particularly for management of contaminated sea as per Reg.18.3.
31 Oil discharge monitoring and control system Applies only to tank cleanings and contaminated sea water (refer Art. 2(3)(b)(ii), Reg. 39 and UI 50) and should be read in light of Reg. 34. Not required where all oily mixtures are discharged to shore.
32 Oil/water interface detector Applies only to tank cleanings and contaminated sea water (refer Art. 2(3)(b)(ii), Reg. 39 and UI 50) and should be read in light of Reg. 34. Not required where all oily mixtures are discharged to shore.
33 Crude oil washing requirements COW system should be fitted unless produced oil characteristics are not suitable for COW.
34 Control of discharge of oil Applicable as detailed below.
34.1 Discharges outside special areas Recommended application whenever the FPSO/FSU is not at its operating station.
34.2 " Applies.
34.3 to 34.5 Discharges in special areas Applies.
34.6 Oil tankers <150GT Recommend application if FPSO/FSU is less than 150GT.
34.7 to 34.9 General requirements Applies.
35 Crude oil washing operations Recommended application to any produced oil tanks used for water ballast as water ballast is subject to different discharge requirements than produced water. COW O&E Manual is to be provided for any COW system fitted.
36 Oil Record Book Part II Part II should be applied in principle as part of oil production management system when on station, noting that this function must be complied with on voyage.
37.1 - 37.3 SOPEP Applies in respect of SOPEP. However, contingency plan in accordance with requirements of OPRC Art 3(2) may be accepted under UI 48 as meeting this requirement. In such cases a separate SOPEP in accordance with the MARPOL format is not required. This acceptance of the contingency plan does not apply to a disconnectable FPSO/FSU unless that plan remains applicable when the FPSO/FSU is not connected to the riser.
37.4 Access to stability and residual strength calculation programmes Applicable
38 Reception facilities FPSOs/FSUs should not be considered as offshore terminals and should not receive dirty ballast or slops from offload tankers.
39 Special requirements for fixed or floating platforms Applies subject to UI 50.

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