Annex 1 - Recommended Provisions of MARPOL and Annex I for Application to FPSOs and FSUs
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Statutory Documents - IMO Publications and Documents - Circulars - Marine Environment Protection Committee - MEPC/Circular.406 – Guidelines for Application of MARPOL Annex I Requirements to FPSOs and FSUs – (10 November 2003)1 - Annex - Guidelines for Application of MARPOL Annex I Requirements to FPSOs And FSUs - Annex 1 - Recommended Provisions of MARPOL and Annex I for Application to FPSOs and FSUs

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

Article Subject Basis of Application
     
Art. 2(3)(b)(ii) Def. Discharge In accordance with Reg. 21 and UI 10.1, 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)-(3) Defs. Oil, Oily mixture, Oil fuel Applies
1(4) 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(5) Def. Combination carrier Not applicable for same reasons as 1(4).
1(6)-(7) Defs. New ship, Existing ship Applies
1(8) 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(9)-(10) Defs. Nearest land, Special area Applies
1(11) 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. 9(1)(a)(iv) and 15(3)(a)) .
1(12)-(25) Defs. (Various) Applies.
1(26)-(27) Defs. New oil tanker, Existing oil tanker Not applicable
1(28) Def. Crude oil Applies
1(29)-(30) Defs. Crude oil tanker, Product carrier Not applicable
1(31) Def. Anniversary date Applies
2(1) Application Applicable
2(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) “ Any Administration using this clause in relation to FPSOs/FSUs would need to justify such use in relation to the terms of clause (a) and in accordance with the requirements of clause (c).
3(1)-(2) Equivalents Applies
4(1)-(4) Surveys & 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 drydock when the conditions are satisfactory and the proper equipment and suitably qualified personnel are available.
5(1)-(3) Issue of certificate IOPP Certificate should be issued unless flag and coastal States have other means of certificating/documenting compliance
6(1)-(4) Issue of certificate by another Government Applicable
7 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
8 Duration of certificate Applicable
8A 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.
9(1)(a) Control of discharge of oil Recommended application whenever the FPSO/FSU is not at its operating station.
9(1)(b) “ In accordance with Reg. 21 and UI 10.1, 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 9(1)(b)(ii) 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 9(4);
  • d. be discharged in accordance with this clause subject to waiver of the en route requirement;
  • e.be added to the production stream; or
  • be treated using a combination of these methods
9(2)-(7) “ Applies
10(1)-(2) Methods for the prevention of oil pollution from ships while operating in special areas Applies
10(3) Methods for the prevention of oil pollution from ships while operating in special areas Applicable, but FPSOs/FSUs cannot comply with (3)(b)(iii) when operating on station. This requirement should be handled consistent with 9(1)(b) above. Coastal State may issue dispensation from (3)(b)(iii) where satisfied that this dispensation does not prejudice the environment.
10(4)-(6) “ Applies
10(7)-(8) “ FPSOs/FSUs should not be considered as offshore terminals and should not receive dirty ballast or slops from offload tankers
11 Exceptions Applies
12(1)-(5) Reception facilities FPSOs/FSUs should not be considered as offshore terminals and should not receive dirty ballast or slops from offload tankers
13(1)-(11) Segregated ballast tanks, dedicated clean ballast tanks and crude oil washing Recommend application subject to the conditions listed for 13(2) and (3).
13(2) “ Not applicable, but FPSO/FSU should have sufficient ballast capacity to meet stability and strength requirements in design and operational conditions of loading
13(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 9(1)(b), it should be dealt with as provided for under that clause.
13A(1)-(4) Requirements for oil tankers with dedicated clean ballast tanks Recommend application similar to 13(1)-(11)
13B(1)-(2) Requirements for crude oil washing COW system should be fitted unless produced oil characteristics are not suitable for COW
13B(3) “ For safety reasons, inert gas must be fitted in conjunction with any COW system
13B(4) “ Recommended application to any produced oil tanks used for water ballast as water ballast is subject to different discharge requirements than produced water.
13B(5) “ COW O&E Manual is to be provided for any COW system fitted
13C Existing tankers engaged in specific trades Not applicable
13D(1) Existing oil tankers having special ballast arrangements Recommend application to meet 13(2) and 13(3) as modified by these Guidelines
13D(2) “ Recommended application consistent with 13(3) and 13B(4) as modified by these Guidelines.
13D(3) “ Not applicable.
13E(1)-(4) Protective location of segregated ballast spaces Not applicable. Refer 13F(3)(a) for corresponding provisions in relation to both new purpose-built FPSOs/FSUs and other nonpurpose- built FPSOs/FSUs.
13F(1)-(9) Prevention of oil pollution in the event of collision Not applicable, except as detailed below
13 F(3)(a) & (f) Prevention of oil pollution in the event of collision 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)
13F(5) “ Applicable to the extent that the Guidelines referred to can be used to demonstrate equivalency with 13F(3)(a) and (f) as modified above.
13F(8) “ 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.
13F(9) “ Recommend application to new construction purpose built FPSOs/FSUs and other FPSOs/FSUs which may be modified to meet this regulation.
13G (1)-(8) (as amended by Res.MEPC.95(46)) Prevention of oil pollution in the event of collision or stranding - Measures for existing tankers Not applicable.
14(1)-(3) Segregation of oil and water ballast and carriage of oil in forepeak tanks Applies
14(4) “ 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 13 F(8).
14(5) “ Applies with regard to extending the principles of 14(4) to all other FPSOs/FSUs
15(1)-(2) Retention of oil on board Applies
15(3) (Oily discharge monitoring equipment) Applies only to tank cleanings and contaminated sea water (refer Art 2(3)(b)(ii), Reg 21 and UI 10.1) and should be read in light of Reg.9. Not required where all oily mixtures are discharged to shore.
15(4) “ Recommend application if FPSO/FSU is less than 150gt.
15(5) “ Recommend application in order to sanction the waiver arrangements outlined in 15(3), eg. for operations within special areas (15(5)(b)(ii)(1)) in compliance with 15(5)(b)(ii)(3) to (6). Transfer of oily mixtures to offload tankers for discharge ashore is acceptable within this waiver.
15(6)-(7) “ Not applicable.
16 Oil discharge monitoring and control system and oil filtering equipment Applicable subject to applicable provisions of Reg. 9. 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 9(1)(b). A waiver may be issued under 16(3)(a), where all oily mixtures are discharged either ashore or into production stream.
17 Tanks for oil residues (sludge) Applicable
18(1) Pumping, piping and discharge arrangements of oil tankers Applies, except that manifold is to be provided in at least one position on the FPSO/FSU.
18(2) “ Not applicable for FPSOs.
18(3)-(6) “ Recommend application, particularly for management of contaminated sea as per reg.13(3).
19 Standard discharge connection Applicable.
20(1)-(7) Oil record book Part I to be applied. 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.
21 Special requirements for fixed or floating platforms Applies subject to UI 10.1.
22(1)-(2) 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.
23(1)-(5) Hypothetical outflow of oil Recommend application for side damages only in accordance with 22 above.
24(1)-(6) Limitation of size and arrangement of cargo tanks Recommend application based on 22 and 23 above.
25(1)-(5) Subdivision and stability Recommend application only in respect of side damage in accordance with 22 above.
25A Intact Stability Recommend application
26(1)-(3) SOPEP Applies. However, contingency plan in accordance with requirements of OPRC Art 3(2) may be accepted under UI 12.2.1 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.
Parent topic: Annex - Guidelines for Application of MARPOL Annex I Requirements to FPSOs And FSUs
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