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IMO MEPC 60/19 9 December 2009 Original: ENGLISH
MARINE ENVIRONMENT PROTECTION COMMITTEE 60th session Agenda item 19
WORK PROGRAMME OF THE COMMITTEE AND SUBSIDIARY BODIES Revision of the Guidelines for the Transport and Handling of Limited Amounts of Hazardous and Noxious Liquid Substances in Bulk in Offshore Support Vessels – resolution A.673(16), as amended Submitted by Brazil, Denmark, Norway and IACS SUMMARY Executive summary: This document proposes a new work programme item to be coordinated by the Sub-Committee on Bulk Liquids and Gases (BLG) on review of the Guidelines for the Transport and Handling of Limited Amounts of Hazardous and Noxious Liquid Substances in Bulk in Offshore Support Vessels (resolution A.673(16), as amended). As resolution MSC.235(82) is applicable to offshore supply vessels subject to resolution A.673(16), a review of resolution MSC.235(82) should be included to assure consistency. Other IMO resolutions that impact on offshore support vessels should also be considered. 2, 5 2.1.1, 5.2., 5.2.1, 5.2.3 Clear Guidelines would ease the work of all parties involved in transport and handling of limited amounts of hazardous and noxious substances in bulk in offshore support vessels (126.96.36.199) Paragraph 28 Assembly resolutions (A.673(16), as amended; A.900(21), A.989(25), A.1012(26), A.692(17) and A.863(20)), MSC-MEPC.1/Circ.2, MSC.236(82), MEPC.158(55), MARPOL Annex II, DSC 13/18 and MSC 85/23/4
Strategic direction: High-level action: Planned output:
Action to be taken: Related documents:
Introduction 1 The document is submitted in accordance with the Committee’s Guidelines on organization and working methods, as provided in MSC-MEPC.1/Circ.2.
For reasons of economy, this document is printed in a limited number. Delegates are kindly asked to bring their copies to meetings and not to request additional copies.
regulation 11. in respect of ships other than chemical tankers or liquefied gas carriers certified to carry noxious liquid substances in bulk identified in chapter 17 of the IBC Code.236(82) in order to align with the revisions of the IBC Code and MARPOL Annex II. 8 Since the introduction of resolution A.673(16). etc. similar to the IBC and IGC Code using the Guidelines for the Transport and Handling of Limited Amounts of Hazardous and Noxious Liquid Substances in Bulk in Offshore Support Vessels.MEPC 60/19 -2- 2 The document proposes a new work programme item to be co-ordinated by the Sub-Committee on Bulk Liquids and Gases (BLG Sub-Committee) with a view to developing an Offshore Support Vessel (OSV) Code.673(16). In 2006. as amended. the Administration shall establish appropriate measures based on resolution A.673(16). if the substances the vessel is constructed to carry present only marine pollution hazards. carriage of IMDG Code dangerous goods in portable tanks being discharged directly into the well heads. such as Dynamic Positioning.673(16). a new OSV can hold either a Certificate of Fitness (appendix 2 of resolution A. additional IMO resolutions have been adopted. Guidelines for the Transport and Handling of Limited Amounts of Hazardous and Noxious Liquid Substances in Bulk on Offshore Support Vessels (LHNS Guidelines). 4 In accordance with MARPOL Annex II. it is proposed to include a review of resolution MSC. which impact on the design. the sixteenth session of the Assembly adopted resolution A. back-loading of drill cuttings and waste products.3).673(16)) or. as a base document in order to clarify the provisions so that they reflect well-established industry practices and constitute a common instrument for the design and construction of new OSVs accepted by individual flag States. carriage of flammable products.158(55) and MSC.5. as amended (paragraph 1.673(16). I:\MEPC\60\19. the Guidelines were amended by resolutions MEPC. Identification of compelling need 7 In accordance with resolution A. Annex II). Scope of the proposal 5 The proposal is to develop a Code similar to the IBC and IGC Codes based on the Guidelines for Transport and Handling of Limited Amounts of Hazardous and Noxious Liquid Substances in Bulk on Offshore Support Vessels in order to make the provisions clear and concise so that they reflect well-established industry practices and constitute a common instrument for the design and construction of new OSVs.673(16). resolution A. Since the adoption of resolution A. 6 As resolution MSC. as amended.2.235(82) to assure consistency in the two instruments as well as other IMO resolutions that are applicable.673(16) that covers Offshore Support Vessels and Well stimulation vessels. operation and construction of these vessels. a Certificate for the Carriage of Noxious Liquid Substances in Bulk (appendix 3 of MARPOL.235(82) is applicable to offshore supply vessels subject to resolution A. 3 In 1989.doc . the offshore industry are requiring these vessels to now undertake a great variety of work. This has caused confusion in flag States as to which certificate should be issued and in the industry as to which certificate should be held. in order to ensure that the provisions are such as to minimize the uncontrolled discharge into the sea of such substances.
but also have a significant influence on OSV design and construction. as amended. Many OSVs have a much larger capacity of NLS tanks and this. but unacceptable to another. It is noted that interpretations are being developed by States with different rates of NLS content against different total volumes of mud carried. I:\MEPC\60\19. The provisions in resolution A. This causes difficulties when owners have to confirm their NLS cargoes and categories.10. Subsequently.10 of MARPOL Annex II) on ships other than traditional chemical tankers.673(16) has led to different interpretations and policies: An OSV design may be acceptable to one flag State. e. and because the vessel is fitted with a large number of flange connections in the cargo piping system. The process of applying for waivers/exemptions is very time-consuming and opinions differ as to whether there is a need to issue waivers/exemptions. OSVs. such disparity leads to difficulties when changing flag and in worldwide operation. including resolution MSC 235(82) are not only intended for pollution control. including newbuildings.doc . 12 It should be pointed out that in respect of compliance. OSVs also carry mud. as set by the Guidelines in 1989 is an issue to that needs to be resolved..-3- MEPC 60/19 9 A large amount of waivers and equivalents shows that the actual implementation of resolution A. It is unclear whether these interpretations would be accepted by other States or port State control authorities. 10 There may be a gap in the different tiers of current legislation. and it is still a problem for flag Administrations and/or Recognized Organizations to issue cargo lists as supplements to the Certificate of Fitness. A common approach would benefit flag States. eventually. according to item 3. It should be noted that SOLAS chapter VII. part B: “Construction and equipment of ships carrying dangerous liquid chemicals in bulk” does not address the carriage of Noxious Liquid Substances (NLS as defined in regulation 1.673(16). leads to the carriage of NLS above the limited amount with the approval of the flag State. having regard to the costs to the maritime industry and global legislative and administrative burdens 14 The cost to the maritime industry as well as global legislative and administrative burdens should be minimal as the intent is to establish clarity on the guidelines for OSVs thereby reducing costs. is rather limited and the requirements under section 1. Recognized Organizations and the industry alike.g. and with a flashpoint of more than 60°C. Against the background of the substantially increased capacities and capabilities.1. 13 The list of permitted cargoes in Appendix 1 to resolution A. which is a mixture of various minerals and products that are not a 100% NLS. interpretations of certain elements of the Guidelines have led to the granting of exemptions to a significant number of ships.673(16). It should be noted that one of the arguments for having drafted the Guidelines in the first place is the limitation on quantity. modern OSVs have become larger in size. where OSVs support exploration and production facilities further offshore. the 800 m3 limitation on the total quantity of NLSs carried on board. that permits additional products to be carried is restrictive and many cargoes that the offshore industry wants to carry can only be shipped in portable tanks that will then have to be pumped to the platform. Analysis of the issues involved. A typical exemption would be to waive the segregation requirement because only substances representing a pollution hazard. Identification of analysis of the issues involved 11 Due to the demands of the offshore industry. are carried.2: “Scope” of the Guidelines. Many typical drilling fluids carried by OSVs are not listed.
It is envisaged that the issue would be coordinated by the Sub-Committee on Bulk Liquids and Gases at BLG 16 (2011) and to the Sub-Committee on Ship Design and Equipment as appropriate. if deemed necessary and after the Committee’s decision. 20 A work programme item for a proposal for the development of a new OCSV Code covering Offshore Construction Support Vessels has been established on the agenda of the DE Sub-Committee. It is expected that several sessions will be needed to properly deal with this issue. As the safe carriage of NLSs by OSVs would have a significant influence on the design of OSVs.989(25) “Strategic Plan for the Organization (for the six year period 2008-2013)”. it is not envisaged to contain anything about the safe carriage of NLSs by OSVs.MEPC 60/19 Benefits accruing from the proposal -4- 15 The aim of the proposal is to update the legislation on the carriage of NLSs on OSVs reflecting current industry practices to avoid confusion and potential disputes. 23 Considering resolution A.1 SD5 – developing and maintaining a comprehensive framework for safe. Priority and target completion date 21 The co-sponsors are of the opinion that this issue should be given high priority. efficient and environmentally sound shipping (especially “ensuring that all I:\MEPC\60\19. But the proposed development of legislation on the carriage of NLSs by OSVs can be dealt with separately at first and subsequently be inserted as part of the proposed OCSV Code. the proposed OCSV Code would also have to include provisions on the safe carriage of NLSs. 17 Recognized Organizations will benefit by carrying out statutory services without being hindered by a lack of clarity and by issuing certificates using a harmonized approach on behalf of flag Administrations. 19 The owner and ship’s crew will benefit from operating a ship within clear operational limitations and working safely on board. Scope of IMO’s objectives and how the proposed item is related to the scope of the Organization’s Strategic Plan and the High-level Action Plan 22 Noting resolution A. it is very common to have multi-purpose OSVs carrying NLSs and operated with functions referred to in MSC/85/23/4. applications for waivers/exemptions and certificate formats. ship designers and shipyards will benefit from improved specifications and requirements to build or modify OSVs in compliance with all requirements. to the extent feasible.doc . at the moment. secure. As regards the design and operation of OSVs. the sponsors believe that the following Strategic Directions (SDs) are addressed in this proposal: . 16 Flag Administrations will benefit from the burden of facing large numbers of enquiries on interpretations. But. by ship types. the sponsors consider this proposal consistent with the objectives of “ensuring the effective uniform implementation of existing IMO standards and regulations relating to maritime safety and environmental protection”.900(21) “Objectives of the Organization in the 2000s”. with particular emphasis on passenger ships” and “avoiding excessive regulation”. “addressing safety and environmental policy issues. 18 With clear legislation.
if necessary. __________ I:\MEPC\60\19. 24 Finally. The following High-level Actions (HLAs) have been identified as particularly relevant in the context of this proposal: . the sponsors have reviewed resolution A. the harmonization is not with other international instruments but with a mandatory IMO instrument and a number of industry standards. see above. including those concerned with large concentrations of people”). However. Estimation of the number of sessions needed to complete the work 27 The work is estimated to need two to three sessions by the BLG Sub-Committee and two sessions by DE Sub-Committee for completion. other relevant Sub-Committees.-5- MEPC 60/19 systems related to enhancing the safety of human life at sea are adequate. Do adequate industry standards exist? 25 No industry standards have been identified.5 – harmonize IMO instruments with other relevant international instruments.673(16) and MSC 235(82)) on both new construction vessels and existing vessels. to revise the Guidelines for the Transport and Handling of Limited Amounts of Hazardous and Noxious Liquid Substances in Bulk in Offshore Support Vessels (resolution A. Do the benefits justify the proposed action? 26 Yes. a number of flag States have issued interpretations and schemes for the implementation of resolutions A. as amended) with a view to developing a Code similar to the IBC or IGC Code. as necessary – noting that.1 HLA 1. in this instance.673(16).1012(26) “High-level Action Plan of the Organization and priorities for the 2010-2011 biennium”. Action requested of the Committee 28 The Committee is invited to agree to establish a new work programme and agenda item for the BLG Sub-Committee and later for the DE Sub-Committee and.doc .3.
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