CONTENTS

1 Introduction

2 Prevention of and Reaction to Marine Oil Spills under MARPOL

2.1 Introduction
2.2 Prevention and preparedness: during normal operations
2.3 Bunkering
2.4 Preparedness: The MARPOL SOPEP
2.5 Testing the ship’s response – part one
2.6 Testing the ship’s response – part two

3 Further resources

4 Appendices
4.1 Prevention of oil spills during routine operations
4.2 Guidelines for a Structure of an Integrated System of Contingency Planning for
Shipboard Emergencies
4.3 UK P&I Club. Circular 7/15:
Oil Spill Response Organization Contract Requirements – Uruguay

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1 INTRODUCTION

Oil, in its various forms, is a substance which all ships rely on. It is not only integral in
running a ship but also one of the major commodities they transport. Our industry and
indeed the world simply could not survive without it. However, when oil finds its way into the
environment as the result of a spill, it can lead to loss of life and significant damage to the
marine environment, as well as having a significant and potentially devastating effect on
individuals, companies and communities.

Most oil spills have an identifiable and highly visible cause. Although typically small, their
costs can run from millions of dollars right up to billions of dollars for very large incidents.
What is more, a spill of any size can quickly become a very high profile incident and involve
permanent damage to a company’s reputation.

2 PREVENTION OF AND REACTION TO MARINE OIL SPILLS UNDER

MARPOL

2.1 Introduction

Over the last fifty years, there have been a number of high profile oil spills and the names of
many of the vessels and companies involved are well known, even among the general
public. However, those years have also seen continuing efforts to reduce both the number of
incidents of marine oil pollution, and the overall amount of oil lost. Legislation, covering
everything from the way vessels are designed and built to the way they are operated, has
been an important part of the ongoing success of these efforts.

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Throughout the world, one piece of legislation which has played a key role in this success is
the International Convention for the Prevention of Pollution from Ships, more commonly
known as ‘MARPOL’.

Under MARPOL, any individual, including all seafarers and company employees, or any
organisation, can face a criminal prosecution for their actions, or their failure to act, in relation
to instances of oil pollution. Its primary purpose is to prevent oil pollution and make sure that
any spill is promptly and properly responded to.

In this section we will be looking in detail at the three major topics which MARPOL exists both
to promote and to regulate, namely the prevention of, preparedness for, and response to
marine oil spills.

2.2 Prevention and preparedness: during normal operations

Under MARPOL, any discharge of oil is prohibited with only very minor exceptions, and
everything possible must be done to avoid a spill. How can this be achieved?

Oil spills can occur on any type of vessel, not just tankers. Prevention of oil spills involves
everyone on board playing their part by working safely, sticking to proper procedures, and
being on the lookout for any problems. It means being alert to all the potential causes of
spills, including poor navigation, inadequate voyage planning, stress and fatigue. It means
being vigilant during cargo operations or bunkering and it means sticking to the procedures
set out in the ship’s Safety Management System (SMS).

Under MARPOL, all ships over 400 gross tonnes and oil tankers over 150 gross tonnes
must have a Shipboard Oil Pollution Emergency Plan, commonly known as a ‘SOPEP’.
On tankers, which have to deal not only with oil but also hazardous and noxious
substances, there is an equivalent to the SOPEP known as a Shipboard Marine Pollution
Emergency Plan, SMPEP, which covers these substances as well as oil.

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In general, the SOPEP will govern any response to oil and bunker spills, except in US
waters, where it would be the ship’s Vessel Response Plan.

Large Spills: When looking at the frequency and quantities of oil spilt, it should be noted
that a few very large spills are responsible for a high percentage of oil spilt. For example,
in more recent decades the following can be seen:

• In the 1990s there were 358 spills of 7 tonnes and over, resulting in 1,133,000 tonnes
of oil lost; 73% of this amount was spilt in just 10 incidents.

• In the 2000s there were 179 spills of 7 tonnes and over, resulting in 208,000 tonnes of
oil lost; 55% of this amount was spilt in just 4 incidents.

• In the five year period 2010-2014 there have been 35 spills of 7 tonnes and over,
resulting in 26,000 tonnes of oil lost; 90% of this amount was spilt in just 9 incidents.

Over the last two and a half decades, the average number of spills greater than 7 tonnes
has progressively reduced by half. In terms of the volume of oil spilt, the figures for a
particular year may be severely distorted by a single large incident.

Spills of 7 tonnes and over per decade showing the influence of a relatively small number
of comparatively large spills on the overall figure

ITOPF: http://www.itopf.com/knowledge-resources/data-statistics/statistics/

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Causes of Large Oil Spills: In the period 1970 to 2014, 50% of large spills occurred while
the vessels were underway in open water. During this type of operation, 59% were caused
by collisions and groundings. These same causes accounted for an even higher
percentage of incidents when the vessel was underway in inland or restricted waters,
being linked to some 99% of spills.

Incidence of spills greater than 700 tonnes, by operation at time of incident and primary
cause of spill, 1970-2014.

ITOPF: http://www.itopf.com/knowledge-resources/data-statistics/statistics/

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2.3 Bunkering

Although spills are often linked to collision and grounding incidents, most occur during
bunkering and, on tankers, during routine cargo operations as well. Whether bunkering, or
transferring cargo, the risk of spills can be reduced with good planning and proper
procedures. Minimising any spill will depend on a rapid response from the deck watch and
good communications.

The first step in bunkering is a written plan. Follow the procedures and checklists in your
ship's manuals. Treat bunkering like a cargo operation - everyone involved must be briefed
and have access to the plan.

Bear in mind that there are a number of factors that can affect the safety and success of the
operation. For instance, the prevailing weather and sea conditions can have an impact -
heavy rain or snow could mean that even a small spill could quickly go overboard. Also,
activities like cargo operations or tank transfers could cause a sudden and possibly
disastrous change in the ship’s trim.

• The piping system must be correctly lined up and all bunker system valves and
connections that are not required must be closed and lashed.

• Someone on the ship side of the operation should make sure that the barge or shore
personnel have checked that the hoses are in good condition.

• All scuppers must be plugged, including drain holes in drip trays, which must be placed
below all connections and air vents.

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• Vents must be opened to allow displaced air to escape.

• Absorbent materials, which have been approved for use on the ship, must be on hand in
sufficient quantities and ready for use. The same goes for portable pumps. If any of these
items are already on deck to safeguard cargo operations, they must not be moved, unless
whoever is running the cargo operation has agreed to this.

• Hand pumps can be used to remove water from small amounts of spilled oil.

Before bunkering begins, the ship's staff and the bunker barge staff must meet and discuss
the bunkering plan. They will need to agree and understand the units of measurement and
rates of flow, as well as procedures for both emergency shutting down and topping off, and
communications.

The checklist must be discussed and signed off only when all items have been completed.

• Once everything is agreed and the ship has checked the bunker tanks, connections can
be made and checked. When everything is secure, bunkering can begin.

• The Officer in Charge gives the order to commence once s/he is certain that all the valves
to the designated tanks are open. The transfer must start at a low flow rate.

• Keeping a vigilant watch on deck is essential. Make regular checks of all pipework and air
vents for oil leaks.

• Transfer rates will need to be carefully monitored, and kept to the figures set out in the
plan. This will safeguard against any over-pressurisation of the tanks.

Most bunkering spills are caused, or made worse, by a failure in communications. That is
why it is so important to maintain good communications between the ship and the bunker
operators. It should be continuous, preferably by visual, voice and radio contact. Everyone
must stay alert and be ready to stop the procedure immediately if there is any sign of a leak.
If something does go wrong, the quicker the pressure is reduced, the smaller any spill will be.

• Plenty of ullage space must be left in the tanks for draining the hoses.
• If there is rain while transfer operations are under way, there will need to be extra
monitoring of the deck containment system.
• With the scuppers plugged, the deck can quickly fill with water, forcing any spillage over
the side of the vessel.
• If a bunker spill does happen, or if it seems likely that one will occur, the ship’s SOPEP
will come into action and, depending on the circumstances, possibly the terminal's
response plan as well. Every effort must be made to contain the oil on the ship.
• The plan will list specific tasks for a number of people, but in a real incident, others who
can be spared should be ready to help.
• Once topping off is complete, the disconnection procedure can begin.

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• Before they are disconnected, all hoses must be drained - large hoses can contain
several tonnes of oil.
• As soon as the hose is disconnected, all system connections must be blank flanged, and
all fuel lines and tank filling valves securely closed.
• Final ullaging should be done to confirm exactly how much has been received and that
there is enough space left in the tanks for expansion.

Good planning, thorough checking of equipment and keeping to the correct procedures will
reduce the chance of an operational spill in both bunkering and cargo operations.

2.4 Preparedness: The MARPOL SOPEP

The ship’s SOPEP is all about being prepared for the possibility of an oil pollution incident,
and the ship’s response if such an incident should occur. It is worth noting that a SOPEP
forms part of the ship’s Safety Management System (SMS) and is not just an optional
addition to it.

To help Administrations and ship owners meet SOPEP requirements, IMO has produced
Guidelines for the Development of Shipboard Marine Pollution Emergency Plans,
2010 Edition (this includes Guidelines for the Development of Shipboard Oil Pollution
Emergency Plans (SOPEP), (resolution MEPC.54(32) as amended by resolution
MEPC.86(44) and Guidelines for the Development of Shipboard Marine Pollution
Emergency Plans for Oil and/or Noxious Liquid Substances (SMPEP) (Resolution
MEPC.85(44) as amended by resolution MEPC.137(53)).

Details of how to locate these documents can be found in Further Resources.

In October 2004 an amendment to Annex 1 of MARPOL was adopted in respect of an

addition to the regulation on shipboard oil pollution emergency plans, by which “all oil tankers
of 5000 tonnes deadweight or more shall have prompt access to computerised shore-based
damage stability and residual structural strength calculation programmes”, thus making this a
mandatory requirement.

A MARPOL SOPEP will usually contain five key elements, the first four of which are a legal
requirement, and they are:
• The reporting procedure the Master must follow in the event of an oil pollution incident.
• The list of authorities and other organisations to be contacted in the event of such an
incident.
• The immediate steps that must be taken by the crew to control any discharge of oil.
• A summary of the ship’s procedures and points of contact for co-ordinating the ship’s
response to an oil pollution incident with national and local authorities. This summary will
be of particular use to the company and relevant shore based organisations.

In addition to this, the plan will contain details on the response equipment the ship carries, its
training and review procedures. It will also contain information on how to determine if or when
salvage assistance should be called for, as well as other topics, such as company policies for
testing of the oil pollution response plan.

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All this information will be in your ship’s SOPEP, as well as a lot more specific information
about each topic.

It is worth remembering that a SOPEP is a living document which is updated regularly by

both ship and shore based personnel, as contact details and other information related to the
ship’s procedures changes.

The plan includes an action checklist. This is specific to each ship and includes the list of
mandatory notifications. Remember, these notifications must be made if there has either
been a spill or one is ongoing, or even if there has been no actual spill as yet but one
appears likely to happen.

Ships’ officers must be completely familiar with their ship's response plan. However, no plan
is of any use unless it can be reliably put into action when required. That is why regular
exercising of emergency plans is called for under MARPOL and the ISM Code.

Exercises and drills are often organised by Head Office and also by the Master. However,
sometimes they are organised on a national scale, and may well involve several vessels, port
authorities and spill clean-up operators.

IMO has made compliance with the International Safety Management Code (ISM)
mandatory. The 1997 resolution A852(20) introduced Guidelines for a Structure of an
Integrated System of Contingency Planning for Shipboard Emergencies.

This sets out how emergency plans required under SOLAS can be integrated with Shipboard
Oil Pollution Emergency Plans, thus simplifying the Safety Management System drawn up by
a Company in respect of Chapter 8 of the ISM Code on Shipboard Emergency
Preparedness.

With an integrated system, shipboard training can be conducted in such a way that both
safety and anti-pollution measures are dealt with simultaneously in drills and exercises.

Their main objectives are:

• to assist companies in translating the requirements of the regulations into action by
making use of the structure of the integrated system
• to integrate relevant shipboard emergency situations into such a system
• to assist in the development of harmonised contingency plans which will enhance their
acceptance by shipboard personnel and their proper use in an emergency situation
• to encourage governments, in the interests of uniformity, to accept the structure of the
integrated system as being in conformity with the provisions for development of shipboard
contingency plans as required by various IMO instruments, and to refer to these
Guidelines when preparing appropriate national legislation.

The Guidelines have since been revised following the 28th IMO Assembly in November 2013.
Appendix 3 features the key text from modules 1 to 5 of these Guidelines.

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2.5 Testing the ship’s response – part one

If a drill to test the ship’s SOPEP is being planned, whoever initiates the exercise must
ensure that there is a specific training objective. For instance, it may be decided that the plan
will be used to test communications between the ship and shore in response to a serious
incident, like a grounding. This could occur on any type of ship with a MARPOL SOPEP.

The scenario must be thoroughly planned well in advance. On the ship, this may involve the
Master and the Chief Officer. On shore, it may also involve key local authorities, Head Office
personnel or perhaps both. Good exercises must always be realistic and appropriate to the
size and type of ship and the typical problems that could occur. The scenario should be
different and interesting each time. It is worth remembering that the Master’s chief
concern will always be the safety of the crew and the ship.

The Master and the Chief Officer may decide not to tell their teams exactly when the drill is
likely to start, but they may tell them one is likely to happen sometime soon. In a
communications drill, it will not be necessary to take the actions necessary in a real incident,
such as stopping the ship’s engines or intake fans, and so on. However, all parties involved
will report actions like these as though they were really carrying them out.
• At an appropriate moment in the ship's operations the Master begins the exercise. S/he
starts by informing the engine room.
• In a real emergency the Master would muster the whole crew, but in a drill situation like
that in the video, the Master will probably only inform those who need to be mustered for
the purposes of the drill. However, there must be a clear procedure, understood by the
whole crew, for stopping any drill in the event of a real emergency.
• For this exercise, the Master and another officer remain on the bridge.
• The emergency party, who in a real incident would probably be on deck, are in the cargo
control room.
• Another officer plays the part of the coast guard and other shore based authorities. S/he
has a radio for communications, as well as a chart of the relevant area.

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• The company personnel involved on shore gather in a meeting room in their offices.
• For reference, the Master gets out the SOPEP.
• The emergency party, generally led by the Chief Officer, will notify the Master of the
events supposedly taking place on deck by radio.
• Once more making it clear that it is a drill, the Master gives details of the incident to shore
based organisations, starting with the nearest coastal State. For the purposes of the drill,
this means using the radio to communicate with the officer whose job it is to represent
those organisations.
• Under MARPOL, it is mandatory to notify the coastal State if there is either an actual
discharge of oil, or it appears likely that there will be one. The authorities must have
accurate and up to date information in order to consider their own response.
• The next people who must be notified are the ship’s owners or operators. With both them
and the coastal authorities, the Master sets up a schedule of communications so that
everyone knows when they will get an update. At this stage, all the key players are now
involved.

2.6 Testing the ship’s response – part two

At the same time as the key players are being notified about the incident, the Master is also
receiving more information about it and planning a response. It is advisable for the Master to
stay on the bridge throughout. It is the best place from which to co-ordinate activities and
continue to talk to the shore based authorities.

To get information about events on deck, the Master talks to the Chief Officer. The Chief
Officer gives the Master precise details of what is happening. S/he then notifies the coastal
State and the owner of the facts as s/he understands them.

As well as a contact list, the SOPEP has a helpful list of information that will be required by
those the Master has to get in touch with. Even the obvious can be forgotten in stressful

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situations. Good communications are the most vital factor in any response to a spill. This
does not just mean by people based on the ship.

The people involved on shore also have an important role to play - their own emergency plan
will be integrated with the ship's. As well as organising the clean-up operation, they can notify
most stakeholders - the P&I Club, for instance, who may decide to send experts to the scene.

Everyone on shore and on the bridge should keep a timed record of the information they
receive, as well as their decisions and commands. A record like this will be very important in
the event of any legal proceedings later on. All charts with any notes or plots, as well as
cargo arrangements and any other relevant paperwork must be kept.

The SOPEP will also include a helpful list of possible methods of reducing pollution or a
bunker spill. These could include transferring the cargo between tanks, lightering and so on.
The relevant shore authorities will have to give their permission for any procedure that
involves transferring cargo or moving the ship.

Provided everyone on board is safe, the highest priority will be reducing the quantity of oil
reaching the surrounding environment. In this scenario there is a slow leak from a second
tank. If the oil from this tank, as well as the oil remaining in the ruptured tank can be
transferred, the amount of pollution can be reduced.

A grounding or any damage to the hull can affect the structural integrity of the ship.
This may invalidate the stress calculations developed on board, making it impossible for
the ship’s staff alone to evaluate the extent of the damage accurately.
In these circumstances, the shore team may need to involve an external stability consultant,
such as a naval architect, or refer to the Classification Society for damage stability
calculations, or perhaps do both.

Providing technical assistance is just one of many things that the shore office can do to help,
so they must be integral to the ship's oil spill response. The team also has ready access to
specialist organisations like OCIMF, the Oil Companies International Marine Forum, and
ITOPF, the International Tanker Owners Pollution Federation, usually via the relevant P&I
Club.

Media and press interest is liable to be intense, and, without information, the press are liable
to draw their own conclusions. Ideally, the ship and company’s response to the media should
be co-ordinated on shore. Press briefings should be regular, as full and accurate as the
circumstances allow and devoid of any speculation.

Throughout, both the coastal State authorities and the vessel’s P&I Club should be kept up to
date with the situation and any action being considered. Bear in mind that, in a real incident,
the coastal State authorities have the legal authority to direct the ship's movements, for
instance if they feel that the ship should be moved to a more sheltered and less vulnerable
location.

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However, the various parties, including both the ship’s operator and the coastal State, will
always look to reach an agreement on any action to be taken. After personal safety
concerns, the main priority will always be to reduce the risk of pollution.

It is worth noting that, if the ship's engine is out of action, a specialist salvage contractor
may need to transfer portable emergency pumping equipment and a source of inert gas
supply to the ship.

The Master can end the drill once its main objectives have been achieved and the ship can
return to her normal operational footing.

Soon after any exercise of this nature there must be a formal debriefing - this is as important
as the exercise itself:
• all aspects of the response must be analysed and any issues identified and referred to
the company for consideration
• any improvements to the effectiveness of the plan must be put into action
• drills should then be logged and available for inspection as evidence by Port State
Control inspectors.

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3 FURTHER RESOURCES

Related Videotel programmes

Good Bunkering Practice (Edition 2) - Code 962
Fighting Pollution – Preventing Pollution at Sea, Edition 4 (Code 1122)

Guides and regulations

International Maritime Organization (IMO)

To access IMO published documents, go to https://docs.imo.org/ and click on the Register
button to set up an account. Then click on the IMODOCS Public Area link at the top left of the
screen. Here you can search for the documents you need in the Search field at the top right
of the screen.

Guidelines for the Development of Shipboard Marine Pollution Emergency Plans for Oil
and/or Noxious Liquid Substances (MEPC 44/20, Annex 7, Resolution MEPC.84(44))
International Maritime Organization (IMO) https://docs.imo.org/
Search under MEPC 44/20. Annex 7 is on pages 115 – 135.
This contains a useful example format in appendix 2 for a shipboard marine pollution
emergency plan.

Draft Guidance on the Safe Operation of Oil Pollution Combating Equipment

(MEPC 67/12/2) International Maritime Organization (IMO) https://docs.imo.org/
Search under MEPC 67/12/2
At the time of writing, this guidance is to be further edited and finalised, but as yet it is
undecided if it will be published in booklet form or remain in electronic format.

US Government Publishing Office

Electronic code of federal regulations: http://www.ecfr.gov
Title 33: Navigation and Navigable Waters
Part 155: Oil or hazardous material pollution prevention regulations for vessels
Subparts D: Tank Vessel Response Plans for Oil
Subpart I: Non-tank Vessel Response Plans
Subpart J: Salvage and Marine Fire Fighting

United States Coast Guard Homeport website

A useful tutorial for using the USCG web based template for the development and submittal
of a Vessel Response Plan: http://evrp.uscg.mil/default.asp
Personal Protective Equipment Sampling Matrix for the off and on shore response to oil
spills, published by the US Department of Labor’s Occupational Safety & Health
Administration: https://www.osha.gov/oilspills/oil_ppematrix.html

The following publications, listed by publisher, are suggested to provide additional

assistance in the preparation of shipboard oil pollution emergency plans:

International Chamber of Shipping (ICS)

12 Carthusian Street, London EC1M 6EB, United Kingdom

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- Tanker Safety Guide (Chemicals)

IMO Publications Section

4 Albert Embankment, London SE1 7SR, United Kingdom

- Code for the Construction and Equipment of Ships Carrying Dangerous Chemicals in
Bulk (BCH Code) 2008 Edition, ISBN 978-92-801-15093
Available in English, French, Russian and Spanish

- Guidelines for the Development of Shipboard Marine Pollution Emergency Plans

2010 Edition, ISBN 978-92-801-15185
This booklet version includes Guidelines for the Development of Shipboard Oil Pollution
Emergency Plans (SOPEP) and Guidelines for the Development of Shipboard Marine
Pollution Emergency Plans of Oil and/or Noxious Liquid Substances (SMPEP)

- International Code for the Construction and Equipment of Ships Carrying Dangerous
Chemicals in Bulk (IBC Code) 2007 Edition, ISBN 978-92-801-4226
Available in English, French, Russian and Spanish

- International Safety Management Code (ISM Code) with Guidelines for its
Implementation 2014 Edition, ISBN 978-92-801-15901
Available in English, French and Spanish

- Manual on Chemical Pollution (Section 1 - Problem Assessment and Response

Arrangements) 1999 Edition, ISBN 978-92-801-60963
Available in English, French and Spanish

- Manual on Oil Pollution, Section II, Contingency Planning 1995 Edition, ISBN 978-92-
801-13303
Available in English, French, and Spanish

- Provisions Concerning the Reporting of Incidents Involving Harmful Substances under

MARPOL 1999 Edition, ISBN 978-92-801-60987
Available in English, French and Spanish

Witherby & Co. Ltd.

32-36 Aylesbury Street, London EC1R OET, United Kingdom

- Oil Tankers – A Pocket Safety Guide 2015 Edition, ISBN 978-1-85609-444-3

- Response to Marine Oil Spills 2012 Edition, ISBN 978-1-85609-354-5

- Ship to Ship Transfer Guide for Petroleum, Chemicals and Liquefied Gases
2013 Edition, ISBN 978-1-85609-594-5

Government Printing Office, Washington DC 20402, United States

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- Chemical Hazards Response Information System (CHRIS) Hazardous Data Manual
https://www.uscg.mil/directives/cim/16000-16999/CIM_16465_12C.pdf
Also available from the Superintendent of Documents

- U.S. Code of Federal Regulations, Title 46, Part 150, Compatibility of Cargoes
http://www.gpo.gov/fdsys/pkg/CFR-2015-title46-vol5/pdf/CFR-2015-title46-vol5-
part150.pdf
Also available from the Superintendent of Documents

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4 APPENDICES

4.1 Appendix 1 Prevention of Oil Spills During Routine Operations

1. Prevention of oil spills during bunkering operations
Step 1 - a written plan
A bunkering operation should be treated with the same care as a cargo loading operation.
Follow the procedures and checklists set out in your ship's manuals. Before a bunkering
operation begins:
• brief all officers and crew who will be involved and make sure they have access to the
plan
arrange a meeting between the ship's staff and the bunker supplier to discuss the
bunkering plan
• make sure that nothing is overlooked. For example, activities such as cargo operations
or tank transfers which are taking place at the same time as the bunkering. A sudden
change in the ship’s trim during the bunkering operation could be disastrous
• make sure that everybody understands the units of measurement and rates of flow
• agree procedures for both emergency shutting down and topping off
• agree a communications strategy
• discuss the checklist and sign it off

Step 2 – before bunkering begins

• correctly line up the piping system
• close all bunker system valves and connections not required
• close and lash any sea or overboard valves connected to the bunker system
• ensure that the bunker supply personnel have checked the hoses to confirm that they
are in good condition
• plug all scuppers
• place drip trays below all connections and air vents
• open air vents so that the displaced air can escape freely
• make ready absorbent and/or adsorbent materials (sand is an effective absorbent;
provided it is ready to hand and available in sufficient quantity)
• make sure that portable pumps are readily available
• once everything is agreed and the ship has checked the bunker tanks, make and check
the connections
• test lines of communication
• when everything is secure, begin bunkering

Step 3 – during bunkering

• the Officer in Charge gives the order to commence once s/he is certain that all the
valves to the designated tanks are open
• start and end the transfer at a low flow rate
• be aware that things can go wrong at any time. Have an action plan ready to cope with
the worst possibility
• it is essential to keep a vigilant deck watch, including a regular check on the mooring
arrangements
• continually check all pipework and air vents for oil leaks

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• monitor transfer rates carefully
• keep to the figures set out in the plan to ensure there is no over-pressurisation of tanks
• keep continuous communication between ship and bunker operators, preferably by
visual, voice and radio contact. Most bunkering spills are caused, or made worse, by a
failure in the communications between the ship and the bunkering personnel
• leave ample ullage space for draining the hoses
• make sure everyone is alert and ready to stop the procedure immediately if there is any
sign of a leak. The quicker the pressure is reduced, the smaller the spill
• ensure that there is extra monitoring of the deck containment system when transfer
operations take place during rain. Note particularly that with scuppers plugged, the
deck can fill with water, so any spillage will overflow quickly over the side

Step 4 – after bunkering operations are complete

• once topping off is complete, the disconnection procedure can begin
• drain all hoses before disconnection
• blank flange all bunker system connections as soon as the hose is disconnected
• securely close all fuel lines and tank filling valves
• perform final ullaging to confirm the quantity received and to ensure that there is ample
space for expansion

2. Prevention of oil spills during tanker cargo operations

Step 1 – before loading cargo
• have a cargo loading plan
• make sure that absorbent material (e.g. sawdust) is readily available
• check that oil booms (if carried) are ready
• check and lash sea valves
• check that cargo/pump room/bulkhead and other valves are closed (where practicable)
• check that the crude oil washing system is isolated and that the line up has been
checked
• ensure that adequate crew will be available to control changeover of tanks, etc.
• ensure that gauging arrangements are ready
• ship/shore agreement of maximum loading rate and maximum working pressure
• ship/shore agreement on emergency stop procedures

Step 2 – during loading of cargo

• start loading slowly into one or few tanks
• check that cargo is entering these tanks
• check for leaks
• check levels of all tanks (including those not being filled and those completed)
• check hoses, loading arms and manifolds for pressure, safe support and absence of
leaks
• check unused manifold blanks for leaks
• check overside for any signs of leakage
• check pump room for signs of leakage
• check for absence of build-up pressure in tanks (venting system)

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• make sure that those now on watch know the loading plan, including the arrangements
for finishing and emergency stop
• ensure that there are enough crew members available to control the changeover of
tanks and that they understand the procedure
• ensure that enough space is left in each tank after completion to allow for draining or
blowing the hoses or loading arms

Step 3 – completion of loading of cargo

Before disconnection
• check that hoses/loading arms have been properly blown or drained
• check that manifold valves have been closed
• check that there is space available in the drip trays
• check scupper plugs, particularly at aft end of main deck

After disconnection
• check that hoses/loading arms were blanked or sealed before lifting overside
• check that ship’s manifolds were blanked
• check that ship’s deck lines and drip trays were drained
• check that tank valves (including last tank) were closed
• check that scupper plugs, absorbent materials, etc. were stowed

Ballasting through Cargo System

Before commencement
• check that the COW system has been isolated and the line up checked
• check that there will be adequate crew available to control changeover of tanks, etc.
• ensure that gauging arrangements are ready
• check that the cargo manifold valves are closed and blanked
• check that the vacuum is on the sea suction crossover line
• check that the risers above the cargo pumps have been drained of oil
• check that the valves into the tanks have been opened
• ensure that the pump start procedure was discussed and agreed with the engine room
• check that the sea valve is closed until the pump is started

During ballasting
• ensure that pumps are slowed down in good time before completion
• ensure that ample ullage space is left on completion to reduce the risk of overflowing
contaminated ballast

After ballasting
• check that the outboard and inboard sea chest valves were closed immediately after
the pump is stopped
• check that the tank valves were closed
• check the security of the venting system, the gauging systems, hatches and sighting
ports

3. Prevention of oil spills during crude oil washing

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The following should not be regarded as a comprehensive check list for COW operations.
The ship’s COW Manual will give fuller directions.

Step 1 – before arrival at Discharge Port

• check that the tank washing pipeline system has been isolated from the water heater
and the engine room
• ensure that all hydrant valves on the tank washing line have been blanked and that all
valves to fixed tank washing machines have been shut
• check that tank cleaning lines have been pressurised and leakages made good
• ensure that portable drive units for fixed tank washing machines have been tested
• ensure that pressure gauges on top discharge line, manifold and tank cleaning main
have been checked
• ensure that the stripping system monitoring equipment has been checked
• check that the communication system has been checked and tested
• ensure that the organisation plan has been drawn up and posted with the duties and
responsibilities defined
• ensure that the discharge/crude oil wash operation plans have been drawn up and
posted

Step 2 – before Crude Oil Wash Operation

• check that the communication link between deck/control station and shore/control
station has been established and is working properly
• ensure that the crude oil wash abort condition and procedures have been discussed
and agreed by both ship and shore staff
• ensure that fixed and portable oxygen analysers have been checked and are working
properly
• check that the inert gas system is working properly and that the oxygen content is
correct
• check that all cargo tanks have positive inert gas pressure
• ensure that a responsible person has been assigned to check all deck lines for leaks
as soon as washing starts
• ensure that valves and lines both in the pump room and on deck have been checked

Step 3 – during Crude Oil Wash Operation

• ensure that the quality of inert gas delivered is being frequently checked and recorded
• ensure that all deck lines and machines are being checked often for leaks
• check that COW is in progress only in designated cargo tanks
• ensure that the pressure in the tank wash line is as specified in your COW manual
• ensure that the washing machines in operation and their drive units are being
frequently checked and that they are working properly
• check that a responsible person is stationed continuously on deck
• ensure that the level in the holding tank is frequently checked to prevent any possibility
of overflow
• ensure that all valves between the discharge line and the tank wash line are closed
• ensure that all valves to washing machines are closed
• ensure that the tank wash line has been drained of crude oil

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• ensure that cargo pumps, tanks and pipelines have been properly drained as specified
in your COW manual

Prevention – Summary
The following points are essential in order to reduce the chance of an operational spill in
both bunkering and cargo operations:
• good planning
• thorough checking of equipment
• keeping to the correct procedures

General Prevention – Summary

Although attention to careful strategies for preventing routine oil spills is very important, it
is equally important to be aware of all of the potential causes of oil spills; including poor
navigation, inadequate voyage planning, stress and fatigue.

4.2 Appendix 2
IMO Assembly 28th session, 5th December 2013. Resolution A.1072(28)

Revised Guidelines for a Structure of an Integrated System of Contingency Planning

for Shipboard Emergencies (modules 1 to 5):

Module I: Example Introduction text:

“Introduction
1. The system is intended to prepare shipboard personnel for an effective response to an
emergency at sea.

2. The prime objective of the system is to provide guidance to shipboard personnel with
respect to the steps to be taken when an emergency has occurred or is likely to occur. Of
equal benefit is the experience of those involved in developing the plan.

3. The purpose of the system is to integrate contingency plans for shipboard emergency
situations and to avoid the development of different, non-harmonised and unstructured
plans which would hamper their acceptance by shipboard personnel and their proper use
in an emergency situation. Therefore, the system and its integrated plans should be
structured and formatted in their layout and content in a consistent manner.

4. The aim of the system is to ensure the most timely and adequate response to
emergencies of varied size and nature, and to remove any threat of serious escalation of
the situation. Additionally, the system provides a structure to prevent critical steps from
being overlooked.

5. The system and associated plans should be seen as dynamic, and should be reviewed
after implementation and improved through the sharing of experience, ideas and feedback.

6. It should be kept in mind that there could be problems in communication due to differing
language or culture of the shipboard personnel. The system, as well as the integrated
plans, will be documented for use on board by the master, officers and relevant crew

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members of the ship, and the documents must be available in the working language of the
crew. Any change in personnel which results in a change in the crew's working language
requires plans to be issued in the new language. The module should provide information
to this effect.

7. The system is to be seen as a tool for implementing the requirements of paragraphs

1.2.2.2 and 8 of the ISM Code, or similar regulations in other IMO instruments, in a
practical manner."

Module II: Provisions

1. This module should contain information and explanations on how the system could be
developed on the basis of suggestions for improvement made by the individual company
and shipboard personnel.

2. The primary objective of shipboard emergency prevention, preparedness and response

activities should be to develop and implement an efficient and effective system which will
minimize the risks to human life, the marine environment and property, with a continuous
effort towards improvement.

3. To achieve this objective, there is a need for coordination of, and consistency in, safety
procedures between the company and its ships. Therefore, the module should require that
company shore-based and shipboard contingency planning and response are consistent
and appropriately linked.

4. Safety involves "top-down" and "bottom-up" commitment to active development and

application of safety procedures and practices by all persons, both ashore and afloat,
including management.

5. Free and open communication when evaluating emergency procedures, taking into
consideration accidents and near misses when using this system, should be pursued with
the objective of improving accident prevention, preparedness and response aboard ships.
The module should take care of this recommendation by providing information for the
implementation of an error reduction strategy with appropriate feedback and procedures
for modification of plans.

6. In summary, the module should inform the system user about the most important
requirements with which, at a minimum, the plans should comply. The following main
elements should be addressed in the module:
• procedures to be followed when reporting an emergency
• procedures for identifying, describing and responding to potential emergency
shipboard situations
• programmes/activities for the maintenance of the system and associated plans.

Module III: Planning, preparedness and training

1. This module should provide for emergency training and education of shipboard
personnel with a view to developing general awareness and understanding of actions to
be taken in the event of an emergency.

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2. The system and plans will be of little value if the personnel who are to use them are not
made familiar with them. Module III should therefore provide practical information which
enables each key member of the shipboard personnel to know in advance what their
duties and responsibilities are and to whom they are to report under the plans.
Responsibility should be assigned for each emergency system, and it should be
incumbent on the company that all relevant officers and crew members should understand,
be trained in and be capable of operating the emergency systems, such as fixed fire
extinguishing systems, emergency generator, emergency steering, fire pumps, etc.

3. Successful management of an emergency or marine crisis situation depends on the

ability of the shipboard personnel, the company, and external emergency coordinating
authorities to muster sufficient resources in the right positions quickly.

4. An important goal of planning, preparedness and training programmes should be to

increase awareness of safety and environmental issues.

5. Training should be at regular intervals and, in particular, be provided to shipboard

personnel transferred to new assignments.

6. Records of all emergency drills and exercises conducted ashore and on board should
be maintained and be available for verification. The drills and exercises should be
evaluated as an aid to determining the effectiveness of documented procedures and
identifying system improvements.

7. When developing plans for drills and exercises, a distinction should be made between
full-scale drills involving all the parties that may be involved in a major incident and
exercises limited to the ship and/or the company.

8. Feedback is essential for refining emergency response plans and emergency

preparedness based on the lessons learned from previous exercises, accident
investigations or real emergencies, and provides an avenue for continuous improvement.
Feedback should ensure that the company, as well as the ship, is prepared to respond to
shipboard emergencies.

9. In conclusion, the module should, as a minimum, provide information on the procedures,

programmes or activities developed in order to:

• familiarise shipboard personnel with the provisions of the system and plans
• provide training for shipboard personnel about the system and plans, in particular for
personnel transferred to new assignments
• schedule regular drills and exercises to prepare shipboard personnel to deal with
potential shipboard emergency situations
• coordinate the shipboard personnel and the company's actions effectively, and include
and take note of the aid which could be provided by external emergency coordinating
authorities
• prepare a workable feedback system.

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Module IV: Response actions
This module should provide guidance for shipboard personnel in an emergency when the
ship is underway, berthed, moored, at anchor, in port or dry-dock.

1. In an emergency, the best course of action to protect the personnel, ship, marine
environment and cargo requires careful consideration and prior planning. Standards for
shipboard procedures to protect personnel, stabilise conditions and minimise
environmental damage when an incident occurs should therefore be developed.

2. In this context reference is made to the guidelines already developed by the

Organization, which contain information to provide a starting point and to assist personnel
in the preparation of plans for individual ships.

3. The variety of plans to be incorporated in the system should be simple documents which
outline procedures different from those used for daily routine operations. With normal
operational procedures very difficult problems can be handled, but an emergency
situation, whether on the ship at sea or in a port, can extend those involved beyond their
normal capabilities.

4. In order to keep the plans held by ship and shore identical, and to reduce possible
confusion in an emergency as to who is responsible for which action, plans should make
clear whether the action should be taken by shipboard personnel or shoreside personnel.

5. Taking these particulars into consideration, the module "Response actions" should
comprise main groupings of emergency shipboard situations.

6. Potential emergency situations should be identified in the plans, including, but not
limited to, the following main groups of emergency:

• fire
• damage to the ship
• pollution
• unlawful acts threatening the safety of the ship and the security of its passengers and
crew
• personnel accidents
• cargo-related accidents
• emergency assistance to other ships.

In order to give the company the necessary flexibility for identifying, describing and
responding to further shipboard emergency situations, more specific types of emergency
should be included in the main groups.

7. The above-mentioned main groups can be further subdivided to cover the majority of
shipboard emergencies. The detailed response actions should be formulated so as to set
in motion the necessary steps to limit the consequence of the emergency and the
escalation of damage following, for example, a collision or grounding.

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8. The company should identify all possible situations where shipboard contingency
planning would be required relative to the operational requirements, ship's type, equipment
and trade. The company should consider which shipboard contingency plans should be
reviewed and/or updated whenever changing trade patterns.

9. In all cases priority should be given to actions which protect life, the marine environment
and property, in that order. This means that "initial actions" which are common for all
ships, regardless of their type and the cargoes carried, should be fully taken into account
when formulating "subsequent response" procedures.

10. The planning of subsequent response actions should include information relating to the
individual ship and its cargo, and provide advice and data to assist the shipboard
personnel. Examples of such information are listed below:

Information on:
o the number of persons aboard
o the cargo carried (e.g. dangerous goods, etc.)

• Steps to initiate external response:

o search and rescue coordination
o buoyancy, strength and stability calculations
o engagement of salvors/rescue towage
o lightering capacity
o external clean-up resources

Ship drift characteristics

• General information:
o cooperation with national and port authorities
o public relations.

11. Although shipboard personnel should be familiar with the plan, ease of reference is an
important element in compiling and using an effective plan. Allowance must be made for
quick and easy access to essential information under stressful conditions.

12. In summary, the module should guide those responsible for developing the system on
what should be included in emergency plans, namely:

• coordination of response efforts

• response procedures for the entire spectrum of possible accident scenarios, including
methods that protect life, the marine environment and property
• the person or persons identified by title or name as being in charge of all response
activities
• the communication lines used for ready contact with external response experts
• information concerning the availability and location of response equipment
• reporting and communication procedures on board ship.

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Module V: Reporting procedures
1. A ship involved in an emergency situation, or in a marine pollution incident will have to
communicate with the appropriate ship interest contacts and coastal State or port contacts.
Therefore the system must specify in appropriate detail the procedures for making the
initial report to the parties concerned. This module should take care of the following:

2. Every effort should be made to assure that information regarding:

• ship interest contacts

• coastal State contacts, and
• port contacts for reporting emergencies are part of the system and are regularly
updated.

3. The establishment and maintenance of rapid and reliable 24-hour communication lines
between the ship in danger and emergency control centre(s), company's main office and
national authorities (RCC, points of contact), is important.

4. Those managing response operations on board and services assisting ashore should
keep each other mutually informed of the situation.

5. Details such as telephone, telex and telefax numbers must be routinely updated to take
account of personnel changes. Clear guidance should also be provided regarding the
preferred means of communication.

6. In this context, reference is made to the Organization's guidelines and other national
specific plans which give sufficient guidance on the following reporting activities
necessary:

• when to report
• how to report
• whom to contact
• what to report.

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4.3 Appendix 3
UK P&I Club. Circular 7/15:
Oil Spill Response Organization Contract Requirements – Uruguay

Article 6 of Uruguayan Law 19.012, which entered into force on 23 November 2012,
established an obligation for certain types of vessels and floating structures to contract with
an Oil Spill Response Organization (OSRO).

Members are referred to the Club’s previous circular L.249 dated February 2015 which
informed Members of a new Uruguayan regulation, Disposición Marítima N° 149, which was
due to take effect from 20 February 2015. However, we subsequently informed Members that
the Uruguayan Coast Guard had decided to suspend the entry into force of this regulation,
pending clarification of certain issues with the OSROs.

On 4 May 2015, the Uruguayan Coast Guard published Disposición Marítima N° 157 (the
“Regulation”) (which replaces Disposición Marítima N° 149), specifying the types of vessels
which will need to have a contract with an OSRO, as well as technical and safety measures
required during bunkering operations and a draft OSRO contract. The Regulation will take
effect on 15 May 2015.

The information below is based on a direct translation of the Regulation. It is recognised that
this gives rise to uncertainty in some respects but at this stage we do not have information to
enable us to advise further on interpretation of the wording of the Regulation.

Vessels required to have an OSRO Certificate

The Regulation applies to the following types of vessels and floating structures:

a) Tankers, barges, small craft, fishing vessels or other marine equipment operating,
transferring or transporting hydrocarbons or derivatives, hazardous or noxious substances or
liquid minerals, or engaged in re-floating operations for vessels or marine equipment.

b) Any of the above vessels requesting authorization to anchor in waters under Uruguayan
jurisdiction for a period greater than 24 hours whilst waiting for orders or to enter Uruguayan
ports, terminals, berths, etc.

c) Vessels considered deficient by the Maritime Authority in accordance with Law 17.121
relating to assistance and salvage services provided to vessels posing a danger to navigation
or the environment).

d) Vessels supplying offshore platforms, fixed or mobile installations for exploration and
exploitation of living and non-living resources in the Territorial Sea, Contiguous Zone,
Exclusive Economic Zone or Continental Shelf.

Those vessels to which the Regulation applies are required to present the local Prefecture
with an OSRO Certificate issued by a local OSRO licensed by the Coast Guard, as well as a
P&I Club Certificate of Entry and, if appropriate, a CLC Certificate. Documents need to be
provided 24 hours in advance of anchoring, storage or transport operations.

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OSRO contracts must be entered into through a local agent (unless the vessel is Uruguayan
flagged, in which case the Owners may enter into such contracts directly).

Available OSRO Contracts

The previous circular informed Members that two OSRO's had been licenced by the Coast
Guard for the purposes of the Regulation, namely Marine Environmental Care Lasimar S.A.
and CINTRA Golantex S.A, and that the International Group had reviewed the contracts for
both OSROs.

The International Group now understands that Lasimar S.A. has ceased operations. The
terms of the CINTRA Golantex S.A. contract conform with the International Group vessel
response plan guidelines and the liabilities arising therein fall within the scope of Members’
P&I cover, without the need for additional cover to be purchased from the market.

The International Group understands that another OSRO, named LIFISOL S.A, has now
been licenced by the Coast Guard for the purposes of the Regulation. However, the
International Group has yet to receive and review the LIFISOL S.A. contract. An update to
Members will be provided once the LIFISOL S.A. contract has been reviewed.

Vessels not required to contract with an OSRO in advance

Those vessels which are not transporting, operating or transferring hydrocarbons or
derivatives, hazardous or noxious substances, or liquid minerals will not be required to have
a contract with an OSRO, except in the event of an oil spill, in which case MARPOL Annex I,
Chapter 5, Regulation 37 will apply.

Other Provisions
Vessels which remain anchored for more than 24 hours in Uruguayan waters will need to
appoint an Agent.

Vessels carrying liquefied natural gas (LNG) will need to comply with specific requirements,
which will be issued by the Coast Guard in due course.

Suppliers of bunkers and other oil products will coordinate their contingency plans with the
OSROs assigned to each transfer or transport operation.

The International Group will continue to review the Regulation, and any further update to
Members will be provided in due course where necessary.

All Clubs in the International Group of P&I Clubs have issued similar circulars.

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