1 The purpose of these Guidelines is to provide
for uniform application of MARPOL Annex I 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.
2 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.
3 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 MARPOL regulation I/1(4). They are therefore subject
to the provisions of Annex I that relate
to fixed and floating platforms, including regulation 21.
4 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 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 MARPOL Annex I regulations
referred to in annex 1 to the Guidelines. References contained in
annex 1 relate to MARPOL Annex I up
to and including the amendments contained in resolution MEPC.95(46).
5 This circular has 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 MARPOL Annex I to these floating platforms.
6 The provisions of this circular 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:
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.1 voyages for drydocking, repair or maintenance
work; or
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.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 MARPOL Annex I for oil tankers.
7 In order to avoid development of an entire new
text from 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:
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.1 “oil tanker” should be read as
“FPSO or FSU”;
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.2 “carry” should be read as “hold”;
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.3 “cargo” should be read as “produced
oil and oily mixtures”; and
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.4 “voyage” should be read to include
“operations”.
8 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.
9 The requirement for oil tankers to undergo the
enhanced survey programme (resolution A.744(18)) was deleted from regulation I/13G of MARPOL 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.
10 It is recommended that contracting Governments
give effect to the provisions of this Circular to FPSOs and FSUs as
soon as practicable, but not later than two years after date of approval
of this circular for construction or conversion contracts placed on
or after that date. In the absence of a building or conversion contract,
the keel laying date for purpose-built new-construction FPSOs and
FSUs or the commencement date of a ship's conversion should be used.
FPSOs and FSUs contracted, built or converted prior to that date need
not be upgraded in accordance with the provisions of the circular.
11 In implementing the provisions of this circular,
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 Annex I of the Convention.
12 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
this Circular. Accordingly, the Committee invites Member Governments
to advise the Organization of their experience in applying this Circular
so that it can be taken into account if future amendments to this
Circular are deemed necessary.