Guidelines for the Application of the Revised MARPOL Annex I Requirements 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

Guidelines for the Application of the Revised MARPOL Annex I Requirements to FPSOs and FSUs

  1 The Marine Environment Protection Committee, at its forty-ninth session (14 to 18 July 2003), recognizing the necessity to provide appropriate guidance for the application of MARPOL Annex I requirements to floating production, storage and offloading facilities (FPSOs) used for the offshore production and storage of oil, and floating storage units (FSUs) used for the offshore storage of produced oil, approved the Guidelines for application of MARPOL Annex I requirements to FPSOs and FSUs. The Guidelines were issued as MEPC/Circ.406 on 10 November 2003.

  2 The Committee, recognizing that similar guidelines would be needed for the revised MARPOL Annex I, agreed to their adaptation to the new layout and numbering system of the revised MARPOL Annex I. Thus these Guidelines are intended to replace the Guidelines issued as MEPC/Circ.406 and it is recommended that contracting Governments give effect to their provisions as soon as the revised MARPOL Annex I enters into force.

  3 The purpose of these Guidelines is to provide for uniform application of the revised MARPOL Annex I adopted by resolution MEPC.117(52) to Floating Production, Storage and Offloading facilities (FPSOs) and Floating Storage Units (FSUs) that are used for the offshore production and storage or for offshore storage of produced oil.

  4 The Marine Environment Protection Committee, at its forty-ninth session (14 to 18 July 2003), noted the complex issues involved in applying the requirements of MARPOL Annex I to FPSOs and FSUs, whose arrangements, functions and operations fall under the over-riding control of coastal States.

  5 In addition, the Committee found that the role of FPSOs and FSUs in operation does not include transport of oil. Accordingly, FPSOs and FSUs are a form of floating platform and do not lie within the definition of oil tanker in regulation 1.5 of the revised MARPOL Annex I. They are therefore subject to the provisions of the revised Annex I that relate to fixed and floating platforms, including regulation 39.

  6 The Committee noted that the environmental hazards associated with the quantities of produced oil stored on board operational FPSOs and FSUs are similar to some of the hazards related to oil tankers and that relevant requirements of the revised MARPOL Annex I in relation to oil tankers could be adapted to address those hazards in an appropriate manner. Based on the above and recognizing that these floating platforms are stationary when operating, the Committee recommends that coastal States, flag States and others associated with the design, construction and operation of FPSOs and FSUs apply the relevant revised MARPOL Annex I regulations referred to in annex 1 to the Guidelines. References contained in annex 1 relate to the revised MARPOL Annex I up to and including the amendments contained in resolution MEPC.117(52).

  7 These guidelines have been prepared with a view to providing the necessary guidance and interpretation information which may be specifically applicable to FPSOs and FSUs, and accordingly represents a single document describing the application of the revised MARPOL Annex I to these floating platforms.

  8 The provisions of these Guidelines are for application to FPSOs and FSUs when located at their operating station. However they also take into account the abnormal and rare circumstances of:

  • .1 voyages for drydocking, repair or maintenance work; or

  • .2 disconnection of the platform in extreme environmental or emergency conditions.

In either case, the FPSO/FSU should not transport oil to a port or terminal except with the specific agreement of the flag and relevant coastal States, obtained on a voyage basis. When undertaking any voyage away from the operating station, for whatever purpose, FPSOs and FSUs will be required to comply with the discharge provisions of the revised MARPOL Annex I for oil tankers.

  9 In order to avoid development of an entire new text from the revised MARPOL Annex I attending to such terminology matters and notwithstanding the basis for these Guidelines outlined above, in any regulation indicated to apply to FPSOs and FSUs by the Guidelines at annex, the following interpretation of terminology should be used:

  • .1 "oil tanker" should be read as "FPSO or FSU";

  • .2 "carry" should be read as "hold";

  • .3 "cargo" should be read as "produced oil and oily mixtures"; and

  • .4 "voyage" should be read to include "operations".

  10 Oil tanker requirements that are extended by the Guidelines to apply to FPSOs/FSUs are identified through the phrase "recommend application" or similar, while "applies" is used for requirements to be implemented irrespective of the contents of this circular.

  11 The requirement for oil tankers to undergo the enhanced survey programme (resolution A.744(18)) was deleted from regulation 13G of MARPOL Annex I by resolution MEPC.95(46) and its provisions have subsequently been solely given effect through chapter XI-I of SOLAS. Since SOLAS does not apply to the vast majority of FPSOs and FSUs, which are permanently moored at their operating stations, the relevant oil tanker requirements of resolution A.744(18) have been included as one of the provisions of the Guidelines in order to ensure a satisfactory standard of structural integrity for FPSOs and FSUs. Reflecting the operational characteristics of FPSOs and FSUs, the Guidelines also make provision for limited departure from A.744(18) in respect of acceptance of in-water surveys under conditions which do not compromise safety and pollution prevention.

  12 In implementing the provisions of these Guidelines, Member Governments are invited to use and recognize the Record of Construction and Equipment for FPSOs and FSUs at annex 2 in place of Forms A and B appended to the revised MARPOL Annex I.

  13 The Committee noted that most operations of FPSOs and FSUs are different from other ships covered by Annex I and, recognizing that the coastal State has jurisdiction over fixed and floating platforms operating in waters under its jurisdiction, Member Governments may find it necessary to depart from the provisions of these Guidelines. Accordingly, the Committee invites Member Governments to advise the Organization of their experience in applying these Guidelines so that it can be taken into account if future amendments to these Guidelines are deemed necessary.

Copyright 2022 Clasifications Register Group Limited, International Maritime Organization, International Labour Organization or Maritime and Coastguard Agency. All rights reserved. Clasifications Register Group Limited, its affiliates and subsidiaries and their respective officers, employees or agents are, individually and collectively, referred to in this clause as 'Clasifications Register'. Clasifications Register assumes no responsibility and shall not be liable to any person for any loss, damage or expense caused by reliance on the information or advice in this document or howsoever provided, unless that person has signed a contract with the relevant Clasifications Register entity for the provision of this information or advice and in that case any responsibility or liability is exclusively on the terms and conditions set out in that contract.