F.A.Q in Ship to Ship Transfer Operations by DYNAMARINe

Frequently asked questions in ship to ship transfer operations March 2016

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Foreword

The STS FAQ guide is a remarkable work from DYNAMARINe and Clyde & Co since it provides useful insight for mariners and shore staff, for diligent planning of STS operations. A growing trend in collision incidents involving STS transfers has highlighted some of the complexities of liability and contractual arrangements associated with this practice as well as the potential for serious (P&I) pollution or personal injury claims. DYNAMARINe are operating a type of “TripAdvisor” consultancy, which collates data from Masters performing STS operations around the world. The validated data includes an array of useful information including comments regarding performance of Mooring Masters, fender providers, other ships involved in STS and deck crews. We understand that currently a large number of STS operations, about 12000, are conducted worldwide. Over 650 tanker Masters report their feedback to DYNAMARINe, for each STS operation they are involved, which, in our view, is a fantastic loss prevention tool for the Club’s tanker Members, providing essential background information during the planning stages of STS operations. Stuart Edmonston

Loss Prevention Director Thomas Miller P&I (Europe) Ltd

Testimonials

“STS operations present a number of risks that have to be properly controlled/mitigated with the implementation of effective risk control measures by all involved parties. In his respect, the STS F.A.Q. is considered as a commendable initiative taken by DYNAMARINe & Clyde & Co which will contribute to enhancing the awareness and knowledge of all stakeholders on the safety, legal and commercial considerations related to STS operations. Our cooperation with DYNAMARINe as regards their STS risk assessment services as well as our joint work in the delivery of STS training courses to our seafarers provides a valuable assistance in our efforts to ensure safe and flawless operations and it is expected that the STS F.A.Q. will be an additional useful tool in enhancing further the STS-related competence of our seagoing and shore personnel.” Mr. Sokratis Dimakopoulos

Deputy Managing Director of Tsakos Columbia Shipmanagement S.A.

“The F.A.Q. on Ship to Ship transfer is a very good initiative from DYNAMARINe & Clyde & Co. for the industry and more specifically for the officers who are responsible for executing a safe STS operation on the basis of OCIMF guidelines and STS Plan. This publication will assist shipboard practices in due diligence and effective preparedness of crew.” Capt. George Vasilakis

General Manager of Optimum Ship Services LTD

“Reading through the STS FAQ I was impressed on how well it collected and compiled information from multiple sources to give answers to questions that affect operational, safety and planning issues regarding STS operations. I am sure that it will become an invaluable tool for all tankers operators, both ashore, but also onboard for the Masters to gain a better understanding both of the regulatory framework but also of its practical application and the relation of all the parties involved in an STS operation.” Capt. George Asteros

Operations Director of Maran Tankers Management INC

“This effort has produced a deliverable of outstanding quality, considering the complexity and the risk, both physical and legal, associated with ship to ship transfers; the FAQs will provide a reliable source of reference for both the onshore and offshore STS stakeholders in their combined effort to ensure safe transfers.” Capt. Andreas Christopoulos

Operations Manager of Thenamaris Ships Management

“This is a document that will be provided to each BSM office managing tankers as a valuable resource for reference when planning for, and conducting, STS operations. Our long experience and satisfaction with Online.STS services make this a very welcome addition to our reference library where it will be used often.” Mr. Nick Rich

LPSQ Manager of Bernhard Schulte Management (Cyprus) LTD

“The completion and release of this edition, with the thorough, coherent and explanatory coverage of its subject, confirms the positive impression that I have from the provided services of DYNAMARINe in general, consisting at the same time a valuable tool for any person involved in the management of ship to ship operation. The thorough coverage and explanation of all issues and demands arising from the ship to ship operations are being presented in a wide range of definitions, examples and answers to any question may arise, provides knowledge and information of high standard and significant value. I am fully confident for its positive acceptance and recognition from the maritime and scientific community and that it will be widely used by respected professionals as well as from new comers in the maritime industry and will be set as a reference point soon.” Capt. Mattheou Dimitrios

CEO Arcadia Shipmanagement Co ltd and Chairman of Green Award Foundation

Acknowledgments Special thanks to the project manager of DYNAMARINe, George Papaioannou, for his valuable contribution to this publication. George has been involved in this project with great enthusiasm from the beginning.

Content Forward Testimonials Acknowledgments Contents List of questions Introduction - scope Glossary of terms About the authors Notice of terms of use Statutory requirements Publications, documents and resources STS plan Liabilities and obligations STS clause Clearance request, screening and due diligence POAC STS service providers LOI (Letter of Indemnity) Local authorities Operational – equipment Personnel transfer Mooring Lines Chocks – fairleaders Fenders Hoses Other equipment Safety/security Risk assessment – safety - emergencies TMSA Self Assessment Record keeping Post processing

1 2 4 5 6 11 12 13 15 16 17 18 25 27 30 34 36 37 38 40 40 45 46 47 50 51 52 52 56 56 59 59

List of questions

10.01. What main changes were made from the 2005 OCIMF STS guidelines to the guidelines of 2013?

11.01. Is it necessary to create a new STS Plan when a second hand vessel is purchased OR can the existing plan be kept from the previous tanker operator?

11.02. Is there a need to submit the STS PLAN to the service provider prior to each STS Operation?

11.03. Is it necessary to inform charterers in advance, if there are procedures in the STS Plan that are not included /advised in the latest OCIMF guidelines?

12.01. Is an STS plan required for all tanker vessels? Does the new regulation of MEPC 186/59 apply to all cargoes? Do Chemical Carriers, LNG and Gas carriers need to have an approved STS PLAN?

12.03. The regulation makes reference only to the STS operations between oil tankers at sea. Does the regulation apply to operations in port?

12.04. The regulation MEPC 186(59) does not apply in some specific cases, such as emergency STS operations and operations with FPSOs. Should the STS plan be followed in such operations?

12.05. During bunkering, the bunkers are considered to be the cargo of the bunkering vessel. Should the STS Plan be followed during bunkering operations?

12.06. Is the STS plan necessary for oil tankers that do not engage in STS operations?

12.07. What are the industry standards for STS operations and where are these presented? Are there any relevant questions in INTERTANKO Q88 or OCIMF VPQ?

12.08. How many copies of the approved STS Plan should a tanker vessel have on board?

12.09. Can the STS Plan divert from the latest OCIMF guidelines and include company specific policies?

12.10. Could bunkering operations be comparable with STS operations?

14.01. When is it necessary to revise the STS Plan and request re-approval from Flag or RO?

14.02. Do the STS plans created according to the 4th edition of the OCIMF guidelines need to be revised according to the new published guidelines?

14.03. Is it possible for a vessel to have a “non approved” STS PLAN?

15.01. Is it possible that the check-lists, included in the STS plan, divert from those of OCIMF/ICS/SIGTTO guidelines?

15.02. Can STS checklists be completed electronically?

15.03. Are the STS checklists considered part of the “STS RECORDS” according to the regulation 41 §5 of new chapter 8 of MARPOL ANNEX I?

16.01 Who is an STS organiser?”

16.02. Are charterers and cargo owners liable for the STS Service providers and POAC?

19.01. In which documents are the owner’s liabilities in STS operations stated?

20.01. Why does the charterer request clearance for the nominated vessel by the tanker owners? Isn’t this request covered by the STS clause?

20.02. How long should it take for a tanker operator to respond with his decision regarding a clearance request?

20.04. Should a Master be “held accountable” in having made an unreasonable decision to withhold his approval towards the commencement of the STS Operation?

List of questions

20.03. The charterer requests clearance for STS nominated vessels from the tanker owner in order to allow him to review vessel’s details and decide on her suitability. Is it necessary to state in the C/P STS clause the documents required for such clearance since there is no industry standard practice for this?

21.02. What are the steps a “tanker operator” should follow, in order to exercise best due diligence?

21.03. What resources are available for a tanker operator when exercising due diligence?

21.04. Is it possible for tanker operators to have the due diligence process standardized in STS Operations?

21.05. How can a tanker operator prove that he followed specific procedures and policies when exercising due diligence?

23.01. Which documents are useful, when a tanker operator is requested to clear a vessel?

25.01. When should a nominated vessel be rejected?

27.01. What should be ensured prior to organizing an STS operation?

28.01. If an accident occurs, what could be the consequences for the operator if he has failed in his due diligence actions?

29.01. Does the tanker operator or the Master have the right to refuse a specific service provider?

33.01. What is a suitable number of mooring/unmooring operations for a POAC?

33.02. How are the terms “similar circumstances” and “similar vessels” defined?

33.03. How can a mooring Master gain experience in order to become experienced for POAC duties?

34.01. Should the Master always rely on the advice of the POAC?

35.01. Is the service provider liable for the POAC?

35.02. Does the Master or tanker operator have the right to approve or refuse the participation of a specific POAC?

35.03. Are there means and a procedure in place by the ship owner to assess the experience of the service provider and POAC?

35.04. If the POAC is not fully employed by the service provider, would this affect the decision whether to accept his participation or not?

36.01. Does the STS Service provider have the right to deny the provision of information, such as records and ID information for the nominated POAC to the tanker operator?

37.01. Is it recommended to have an assistant to the POAC during the STS operations?

38.01. Should the tanker operator audit service providers?

42.01. What is the purpose of the LOI’s presented by Service Providers to tanker operators prior to the commencement of the STS Operations?

42.02. Do Masters have to sign an LOI presented by a Service Provider?

42.03 What level of liability would burden the tanker operator by accepting/signing an LOI presented by a STS Service provider?

45.01. What are the potential consequences when failing to notify the Authorities prior to the commencement of the STS operation?

45.02. If an STS operation takes place in international waters, is it required to inform the coastal administration?

45.03. Who has responsibility for the environmental protection inside an Exclusive Economic Zone (EEZ)?

45.04. Is approval from coastal authoritiesâ&#x20AC;&#x2122; necessary prior to the initiation of an STS transfer operation?

45.05. Do tanker operators have procedures in place to assess the suitability and risk assessment of the transfer location?

46.01. Is the personnel transfer by basket a safe and acceptable procedure?

46.02. Is there any industry standards on the expiration date of Baskets used for Personnel Transfer?

46.03. What are the features of the cargo crane, in order to be suitable for personnel transfer by basket?

46.04. What options has the Tanker operator if cargo cranes are not designed for personnel transfer.

46.05. Which are the identified hazards involved in the transfer of personnel by cargo cranes?

47.01. What is the required number of mooring lines for a safe commencement of an STS operation?

47.02. In case you pass more than one mooring line through a closed chock/ closed fairlead, is the cumulative breaking strength of mooring lines less than the SWL of the closed chock?

47.03. Should ship owners have procedures in place to assess the condition of mooring lines and winches prior to each STS operation?

47.04. Can wire pennants (Wire mooring tails) be utilised in STS Operations?

48.01. Is it possible to perform an STS operation if there are not enough chocks/fairleaders of an enclosed type?

48.02. How many ropes can pass through a closed chock/ fairleader?

48.03. What is the minimum recommended number of closed chocks?

48.04. Should all tankers have closed chocks forward and aft of the manifold?

49.01. Who is responsible to provide fenders for an STS operation?

49.02. Which are the required parameters in order to define the fenders quantity and type in an STS Operation?

49.03. Who is responsible to ensure the provided fenders are adequate for the specific STS operation?

49.04. Should the Master have adequate capacity and means to assess the requirements for fender selection?

50.01. Is there a crucial difference if the fenders are located on the constant heading vessel or anchored vessel, instead of the manoeuvring vessel?

50.02. Is there a greater risk of contact during manoeuvring with this arrangement of fendering?

52.01. Are there any fender standards?

54.01. Which are the proposed actions by the Masters in case the service provider delivers inadequate number and size of fenders according to OCIMF?

57.01. What are the criteria to define whether a hose should be withdrawn from service or not?

57.02. Who is responsible for the intermediate connection of cargo hoses?

58.01. Should the main radio be transmitting on either ship involved in an STS operation?

58.02. Which communication equipment is allowed to be used during STS operations?

58.03. Should the ICCP be switched off prior to the STS operation?

60.01 Does the risk assessment developed prior to the STS operation identifies the potential sources and consequences of risk not less than those depicted at section 3.2.2 and Appendix K of the latest OCIMF guidelines?

60.02. When is risk at its highest with respect to a waveâ&#x20AC;&#x2122;s force and direction, during an STS operation?

60.03. Is there an assessment in place with respect to the crew experience and relevant requirements for training?

60.04. Is there a required procedure to assess the rolling effect during an STS?

61.01. During vessel approaching and manoeuvring, which safe practices are highly recommended?

61.02. What should be done in order to eliminate the potential for incendive arcing between two ships when presenting the hose string for connection?

61.03. In which areas of the ship should extra care be considered in order to avoid low resistance Ship to Ship electrical contact?

61.04. What actions are to be considered by the Master during an emergency situation?

61.05. What kind of arrangements should be made on both ships during the state of readiness for an emergency?

61.06. Under which conditions should an STS operation be suspended?

61.07. In which circumstances should night STS Mooring operations be aborted/ postponed?

61.08. What are the precautions for STS operations with same size vessels?

65.01. What records are necessary to be kept on board? (See 15.03)

65.02. Should incidents and near misses be included in STS records?

66.01. Is the assessment of STS records necessary?

66.02. Do technical operators have a procedure in place to collect past STS experience from their fleet, incident and near miss management for training purposes for senior deck officers?

List of questions

53.01. What kind of information should be included in the marking of ISO approved fenders?

Introduction – Scope It is almost five years since the ratification of MARPOL Annex 1 of Chapter 8 was introduced by the IMO to assist in the prevention oil pollution during ship to ship (STS) operations. The legislation has inevitably resulted in more requirements being imposed and made STS Operations more complicated for tanker operators. For example, the need for an STS Plan is an additional requirement to an area that is already well governed by OCIMF guidelines. MARPOL Annex I Chapter 8 requires the integration of the STS plan with the Ship owner’s Safety Management System (SMS) and thus will be opened to scrutiny in the event of an incident and subsequent legal actions. Tanker operators’ responsibility in STS operations is not only defined by the existence of an STS plan, they have to take a justified approach that takes into account commercial and safety considerations. The DYNAMARINe team has gathered data, answers and comments from a wide range of industry representatives involved in Ship to Ship transfer operations. The collected information has been used with current regulations, guidelines and practices to answer the questions raised in the FAQ with the aim of enhancing safety procedures and improving the efficiency of STS operations. The guide is intended to be treated as a ‘live’ document that is continuously updated with the feedback of all industry representatives. Question numbering is unique and will remain unchanged in future editions for more efficient reference.

Glossary of terms Charterer A person or company who employs the vessel to transfer and carry cargo. Doc Document of Compliance. ISPS International Ship and Port facilities Security Code JPO Joint Plan of Operations. Latest ocimf guidelines Ship to Ship transfers, CDI, ICS, OCIMF and SIGTTO Edition 2013. MOP Manual on Oil Pollution, Section 1 â&#x20AC;&#x201C; Prevention, 2011, IMO. Regulation Chapter 8 of Annex 1 of MARPOL convention of IMO (MEPC 86(59)). RO Recognized Organization by the flag administration. OCIMF Oil Companies International Marine Forum. Owner A ship owner whose vessel is being employed to transfer and carry cargo. POAC Person in Overall Advisory Control. Service provider An STS Service provider that provides the STS Equipment and the POAC. SMS Safety Management System. STBL Ship to be lightered. Technical operator The ISM Manager of a vessel or DOC holder. TMSA Tanker Management Self Assessment.

Notice of terms of use While the information hereunder has been compiled with the use of the most current information available, it is intended to be used purely as a guide at the userâ&#x20AC;&#x2122;s own risk. No warranties or representations are given, nor is any duty of care or responsibility accepted by the authors, the members or employees of the authors or by any person, firm, company or organisation who or which has been in any way concerned with the collection of information or data, the compilation of any translation, publishing, supply or sale of the Guide, for the accuracy of any information or advice in the Guide or any omission from the Guide or for any consequence whatsoever resulting directly or indirectly from compliance with, adoption of, or reliance on the Guide even if caused by failure to exercise reasonable care.

Statutory requirements The increasing request for Ship to Ship transfer operations in Oil Cargo strengthen the need for tanker operators to clarify legal issues associated with the STS operations. The ratification of the MEPC 186(59) has brought a plethora of changes to the legal status because it includes the STS procedures to the Safety Management System of tanker operators. Meanwhile, Manual on Oil Pollution section I, Prevention, IMO (herewith referred to as MOP) is revised in order to be harmonized with and supplement the new chapter 8 of Annex 1 of MARPOL. Finally, all guidelines on STS operations from OCIMF and SIGTTO are superseded by a new publication on STS for Petroleum, Chemicals and Liquefied Gases signed by CDI, ICS, OCIMF and SIGTTO. This updated guide is harmonized with both the MARPOL amendments and MOP. It also takes into consideration a wide range of vessel types, including barge operations and reverse type Ship to Ship transfers, during which a smaller laden vessel comes alongside a larger ship to transfer her cargo. STS operations involving vessels at anchor, underway, alongside jetties, or lying at buoys is addressed and has also been expanded to include port transfers for the first time and operations probably involving multiple vessel transfers, especially in the case of chemical tankers. It is emphasized that the requirements of Chapter 8 of MARPOL Annex 1 (the â&#x20AC;&#x153;Regulationâ&#x20AC;?) should be adhered to in all operations involving oil cargoes. In respect to other cargoes, such as LPG, or LNG, the requirements should be followed as a matter of best practice.

Publications, documents and resources The main documentation that applies to Ship to Ship transfer operations is: –– Chapter 8 of Annex 1 of MARPOL Convention, IMO (MEPC 86(59)) –– Manual on Oil Pollution, Section 1 – Prevention, 2011, IMO –– Ship to Ship Transfer Guide, 2013, CDI/ICS/OCIMF/ SIGTTO –– Mooring Equipment Guidelines, Third edition 2008 –– DYNAMARINe – onlineSTS.net, A proposed methodology for TMSA in STS operations (2014) The latest OCIMF guidelines have an updated list of bibliography related to Ship to Ship transfer operations. 10.01. What main changes were made from the 2005 OCIMF STS guidelines to the guidelines of 2013?

–– Vessel approaching and mooring sections have been revised –– Responsibility for cargo operations follows the new guidelines –– Planning of cargo transfer has been enhanced –– Unmooring procedures have been enhanced –– Fenders and Fender requirements for in port transfers, low pressure fenders, ribbed and foam filled fenders have been amended –– New standards have been included –– Personnel transfer at sea and port operations amendments –– Contingency planning section has been revised –– Checklists revised to meet the new guideline requirements

The latest OCIMF guidelines have been revised to cover more safety needs in all STS operations. In both guidelines the essential topics are covered, however, the new 2013 guidelines addressed certain areas in greater depth. The main areas that have been updated according to the new guidelines are the following: –– Manning of Ship to Ship transfer operation and prevention of fatigue –– Enhanced guidelines have been issued for the role of POAC according to the regulations –– Allocation of duties includes training and familiarization procedures for ship’s personnel –– Further ship compatibility requirements for operations involving vessels of similar length and dumb barges –– Updated requirements for weather precautions –– Risk management includes new risk assessment for the transfer location and the ship to ship operation –– Readiness of available fire-fighting equipment, emergency and other safety measures follows new requisites

STS plan The objective of the STS operations plan According to the Regulation, the main objective of the STS operations plan is to prescribe how to conduct STS operations. It is a ship and company specific plan, and should include all necessary information and procedures that are required for the safe execution of STS operations. The STS operations plan is part of an existing Safety Management System (SMS) of the ship. Therefore, the scope of the plan should be in line with ISM objectives. In practice, this means that the policies and procedures should follow the form of the ISM requirements. For example, the STS plan should: –– Include safety practices –– Ensure a safe working environment –– Assess all identified risks and establish appropriate safeguards –– Promote a continuous improvement scheme –– Be in-line with all applicable rules, regulations, codes, standards and guidelines Finally, the TMSA concept should also apply to the policies and procedures described in the STS operations plan. Consequently, it is prudent to place specific goals and then monitor the performance of the operations towards achieving these goals. 11.01. Is it necessary to create a new STS Plan when a second-hand vessel is purchased OR can the existing plan be kept from the previous tanker operator? The STS plan is subject to approval by the flag administration and whenever the flag of the vessel is changed, the current flag administration has to reapprove it. Additionally, since the STS Plan is also a company specific plan and part of the SMS (Safety Management System), it should reflect the current tanker operator’s policies and procedures. Thus, whenever a second-hand vessel is purchased, or a DOC management change occurs, a new, updated STS plan should be prepared and approved by the flag administration or authorised RO. There is only one case in which the STS plan is not required to be revised and re-approved and that

is when the former DOC Company and the current DOC Company of the vessel have exactly the same STS operation policies and procedures, and the vessel remains under the same flag. This is not expected to be a common case. 11.02. Is there a need to submit the STS PLAN to the service provider prior to each STS Operation? According to paragraph 6.2.1.2 of section 1 of the Manual on oil pollution, the POAC should have “thorough knowledge of the STS Plan”. Prior to each STS Operation, when the nominated service provider is appointed it is advisable to submit the STS Plan to the provider and request the attending POAC to review it prior to the preparation of the Joint Plan. 11.03. Is it necessary to inform charterers in advance, in case there are procedures in the STS Plan that are not included /advised in the latest OCIMF guidelines? It is advised that charterers should be informed at the time the charter party is agreed of any special procedures or limitations that are not prescribed in the latest OCIMF guidelines. Normally the STS clause prescribes that STS operations should be conducted according to the latest OCIMF guidelines. Should there be differences in the STS procedures and policies, those should be known to the charterers when the vessel is considered for chartering, and not prior to an STS operation.

Applicability of the STS plan 12.01. Is an STS plan required for all tanker vessels? Does the new regulation of MEPC 186/59 apply to all cargoes? Do Chemical Carriers, LNG and Gas carriers need to have an approved STS PLAN? According to the Regulation, the STS plan should be followed for any transfer of oil cargo. Bunkers are explicitly excluded. The following categories subdivide the full scope of substances in bulk, covered by the term oil according to MARPOL annex I, “type oil as cargo in bulk” –– Crude oils –– Fuel and residual oils –– Unfinished distillates, hydraulic oils and lubricating oils –– Gas oils including ships bunkers –– Kerosenes –– Naphthas and condensates –– Gasoline blending stocks –– Gasoline and spirits –– Asphalt solutions According to the Regulation, only oil carriers that may be engaged in STS operations are required to have an STS plan on board. Nevertheless, paragraph 1.1 of the OCIMF guidelines advises that all tanker vessels, including chemical (Annex II cargoes) and gas carriers should have an STS plan on board according to the latest OCIMF guidelines. Because STS is permitted by all standard tanker c/p, an STS Plan should be prepared for all tankers unless STS operations are specifically excluded by the c/p. 12.03. The regulation makes reference only to STS operations between oil tankers at sea. Does the regulation apply to operations in port? The Regulation applies only to operations at sea. Thus, an STS operation in port does not require a POAC or to ascertain that the STS operation will take place in accordance to the STS plan. However, according to best practice, STS operations should be performed in line with the latest OCIMF guidelines. This consequently requires an STS Superintendent and adopted procedures, as indicated in the STS plan. The qualifications of the STS Superintendent in STS operations within port limits may be subject to local administration requirements. It is recommended that OCIMF guidelines should be followed for all STS transfers, even if in port, as a matter of best practice.

12.04. The regulation MEPC 186(59) does not apply in some specific cases, such as emergency STS operations and operations with FPSOs. Should the STS plan be followed in such operations? It is strongly recommended to take into account the STS plan and latest OCIMF guidelines as a guide in such operations. However, specific cases are excluded from the regulation such as an emergency STS or when either of the ships involved is a warship. In addition, cargo transfer operations associated with fixed or floating platforms and offloading facilities (FPSO, FSU) are also excluded. In these cases, the tanker operator should proceed, taking into account that this is a non-routine operation. However, as mentioned above, it is strongly recommended that the STS plan and latest OCIMF guidelines are consulted. 12.05. During bunkering, the bunkers are considered to be the cargo of the bunkering vessel. Should the STS Plan be followed during bunkering operations? It is clear that bunkering operations are excluded from the regulation. However, when the bunkering vessel is loaded via an STS operation, then the STS plan is to be followed. In this case, a POAC should also be considered. Normally, the Master of the bunkering ship is acting as a POAC, provided that he is experienced and has all the required qualifications. Despite the fact that the bunkering operation is excluded from the regulation, a risk assessment should always be developed and in the case that a proper fendering system is required, this should be carefully planned. 12.06. Is the STS plan necessary for oil tankers that do not engage in STS operations? No, tankers not engaged in STS operations are not required to have an STS plan. However, in this case the ship does not fulfill the OCIMF requirements and will be noticed in a SIRE survey.

Bunkering operations are excluded from IMO MEPC 186(59)

It has to be noted also that currently no classification notation exists for ships involved in STS operations. Should Classification Societies introduce such notation in the future, it will be clear enough which vessels should or should not have an STS plan in order to comply with the assigned notation. Because of the usual provision in all standard tanker c/p, an STS Plan should be prepared for all tankers unless STS operations are specifically excluded by the c/p.

12.07. What are the industry standards for STS operations and where are these presented? Are there any relevant questions in INTERTANKO Q88 or OCIMF HVPQ? The industry standards are reflected in the latest edition of OCIMF guidelines and associated appendices. Vessels that comply with the industry standards should have items 8.26 and 6.25 of INTERTANKO’S standard tanker chartering Questionnaire 88 (Q88) Version 3 answered with “YES”. If questions 8.26 and 6.25 are answered with “NO”, then the vessel cannot participate or be nominated for an STS Operation since possible vessel incompatibilities might occur. Similarly, question 13.1 of OCIMF HVPQ should also be answered with “YES”. 12.08. How many copies of the approved STS Plan should a tanker vessel have on board?

The latest 2013 OCIMF/SIGTTO/ICS/CDI guidelines give support to the implementation of STS procedures during the bunkering operations, under an approved STS Plan. The following is mentioned at the foreword of the Publication: “The recommendations reflect the wide range of ship types, barges included, that may be involved in transfer activities and provide guidance for transfers undertaken both at sea and in port. … Such activities may include traditional STS transfers at sea, at anchor, or under way and inport transfers with one ship being at anchor. Although emergency lightering operations involving a disabled or stranded ship are not specifically addressed, many of the principles contained herein will apply.“

It is advisable that STS records, inclusive of the JPO, be kept in dedicated folders.

Although it is widely accepted that STS operations refer to cargo transfer, the guideline which refers to all transfer activities and bunkering is a transfer activity. As emergency STS operations are not included in the concept of MEPC 186(59), the revised Chapter 8 of MARPOL ANNEX 1, the guide makes reference to the fact that in such cases the recommendations included therein will apply. Bunkering operations are excluded from the revised Chapter 8 of MARPOL ANNEX 1.

12.09. Can the STS Plan divert from the latest OCIMF guidelines and include company specific policies?

Furthermore, the following is mentioned in paragraph 1.1 of the latest OCIMF/SIGTTO/ICS/CDI guidelines:

In principle, the STS plan should not divert from the latest OCIMF guidelines. To be more specific, the regulation refers to the 2005 edition of the OCIMF guidelines, however in practice, industry always refers to the latest guidelines.

“The purpose of this document is to provide guidance to Masters and operators of vessels undertaking side-by side ship to ship (STS) transfer operations of crude oil, petroleum products, chemicals and liquefied gases, both at sea and in port. Other parties may also benefit from studying these guidelines. Such parties may include ship charterers, traders, STS service providers and those contracting STS service providers. The advice contained in this publication may be supplemented by instructions from individual operators in order that particular aspects of their own procedures can be covered.”

According to MOP §6.2.4.2, three copies of the STS plan should exist: one at the bridge, one at the cargo control room (CCR) and one at the engine control room (ECR). Attention is drawn to the consistency of the copies. Any amendments should be reflected in all copies.

The STS plan can also include additional policies and procedures but they should always be in line with the guidelines. This is clearly mentioned in the latest OCIMF guidelines: “the advice contained in the guidelines may be supplemented by instructions from individual tanker operators in order that a particular aspect of their own procedures can be covered” 12.10. Could bunkering operations be comparable with STS operations? In principle, bunkering operations are not the same as cargo transfer operations. However, the operation is vulnerable to hazards similar to those of STS operations and in some cases involve large sized vessels. There are cases where the charterer requests to implement STS procedures during bunkering.

It is clear that there is no reference to bunkering operations. Nevertheless, there may be occasions where it makes sense to apply STS procedures in bunkering operations, to assist in ensuring safety and security.

Bunkering is only one facet of a vessel’s dynamic operating schedule, but is categorised as a critical operation under the ISM Code 19

Bunkering is only one facet of a vessel’s dynamic operating schedule, but is categorised as a critical operation under the ISM Code. This code requires companies to document and implement clear and detailed procedures, standards and instructions for safety management on board. Furthermore, it requires companies to provide safe working practices and provide the means to identify risks. Many companies incorporate the ISGOTT Bunkering Safety Checklist in their operations procedures, whilst some port authorities may insist that ISGOTT procedures be implemented. Checklists can serve as a tool to assist a vessel’s crew in undertaking the operation effectively, as long as diligence is exercised, when undertaking the actual task. MARPOL Regulations govern the Prevention of Oil Pollution as a result of oil pollution incidences. It is therefore compulsory for ships of more than 400 Gross Tons or oil tankers over 150 Gross Tons to carry a Shipboard Oil Pollution Emergency Plan (SOPEP) on board. The SOPEP conveys information from the owner to the Master on how to react in cases of an oil spill. The specific actions needed to be taken as well as the immediate communication between owner and other contact points are listed in a format required by the MARPOL Regulations.

Guidelines for the preparation of STS plan The following basic references should be taken into account, according to the Regulation: –– Manual on Oil Pollution, section I - Prevention, (2011, IMO) chapter 6 –– Ship to Ship Transfer Guide for Petroleum, Chemicals and Liquefied Gases”, 1st edition by CDI/ICS/OCIMF/ SIGTTO It worth mentioning that IMO, MEPC 186(59) (2009), makes reference to the 4th edition of ICS/OCIMF STS guidelines. However, the new publication of STS guidelines by CDI/ICS/OCIMF/SIGTTO supersedes and unifies a number of previous guides. In addition, STS clauses normally refer to this particular guide. There are also a number of templates available from classification societies that may be used as a reference. However, company-specific STS policies have to be developed and these should be included in the STS plan.

As the Master is responsible for ensuring safety, it is also important to clarify due diligence procedures. These procedures should refer to the screening of participating vessels, the review of POAC qualifications and STS service provider credibility, the review of the provided equipment (including fender selection) and the assessment of records. An important issue is to build the Master’s confidence. In doing so, supplementary information regarding good practices, liabilities, STS equipment and lessons learned should accompany the STS plan. The essence of the plan should be focused on the procedures, while the checklist and the supplementary information should be placed in annexes, which are amendable without the need of flag/RO re-approval.

Approval of STS plan The STS plan should be approved by the Flag Administration. Some Flag administrations may request or require that the STS Plan be submitted to the RO for approval, i.e. the classification society of the vessel. 14.01. When is it necessary to revise the STS Plan and request re-approval from Flag or RO? The STS Plan should be revised if any of the following cases apply: –– When a new tanker vessel is purchased –– When OCIMF produces an amended version of the latest guidelines. This is a commercial requirement and not statutory. MARPOL refers to the 4th edition of ICS/ OCIMF STS guidelines and not to the latest edition/ publication. However STS Operations take place as per the STS Clause as included in the charter party, which normally refers to the latest guidelines. Thus, this requirement has to also be reflected in the STS PLAN. Currently Liberia (Marine Notice POL-011 Rev. 05/14) and Marshall Island (Marine Notice No. 2-013-10 Rev. 11/14) Flag administrations require STS Plans to be updated according to latest industry guidelines –– When STS policies and procedures are altered and subject to the requirements of the approval letter from the Flag or RO –– In case the vessel is registered under a new Flag/ Maritime administration The STS plan does not need re-approval for amendments in appendixes and check lists, if this is not explicitly mentioned in the approval letter.

14.02. Do the STS plans created according to the 4th edition of the OCIMF guidelines need to be revised according to the new published guidelines?

15.01. Is it possible that the checklists, included in the STS plan, divert from those of OCIMF/ICS/SIGTTO guidelines?

The STS plans created according to the 4th edition of the OCIMF guidelines need to be revised according to the new published guidelines. This may be justified by the following arguments:

The checklists as presented in the latest OCIMF guidelines are recommended and not mandatory. Although each tanker operator could create his own checklists, it is not recommended to do so, as this would create confusion during the completion of the checklists by the vessels engaged in an STS Operation. Unification of forms is an advantage for mariners, and assists towards good and comprehensive communication.

–– In most charter party agreements, STS Operations take place according to “Latest STS guidelines”, therefore such commercial requirement has to be also reflected in the SMS and STS Plans –– The new VIQ 6 (March 2014) already issued by OCIMF includes the new STS guidelines publication and associated requirements. The following is noted in the new VIQ 6: “Operations plan shall be developed taking into account the information contained in IMO’s “Manual on Oil Pollution, Section 1, Prevention and the ICS/OCIMF/SIGTTO/CDI “Ship to Ship Transfer Guide, for Petroleum, Chemicals and Liquefied Gases” First Edition November 2013” –– Vetting inspections by oil majors will require to have the new STS guidelines implemented on board your vessels and this is reflected in the SMS through the STS Plan. The content of the latest OCIMF guidelines and FORMS have changed a great deal, and revision of the STS PLAN is strongly recommended 14.03. Is it possible for a vessel to have a “non approved” STS PLAN? The existence of an STS Plan reflects policies and procedures of tanker operators. Approved STS plans are “mandatory” to vessels that bear a class notation, partially or solely, as an “oil tanker”. Other types of vessels, such as gas carriers, may have STS plans; however, it is not required to be approved by the flag or RO.

STS forms and/or checklists STS forms and/or checklists are completed before, during and after the completion of the STS transfer. The purpose of a checklist is to provide a methodology to ensure that all steps of a procedure are followed as prescribed. This methodology has proven to be a very successful practice, minimizing human error. Checklists do not in any way substitute the procedures of the plan. They are a methodology for applying the procedures. This is the reason why checklists are not included in the approval of the STS plan.

Should a tanker operator wish to extend the content of the checklists further, in order to satisfy certain safety or quality criteria, it is recommended to have supplementary topics, following those denoted by the latest OCIMF guidelines. In this way unification can be achieved and misinterpretation be avoided. 15.02. Can STS checklists be completed electronically? Yes, the STS checklists can be completed electronically. Actually, it is preferable to have them in an electronic format in order to: –– Easily transmit copies to the operations and HSQE department of the tanker operator –– Easily archive and retrieve information –– Present them to authorities or during vetting inspections, upon request A hard copy or scanned copy is also advised to be kept for either back-up or authentication purposes. 15.03. Are the STS checklists considered part of the “STS RECORDS” according to the regulation 41 §5 of new chapter 8 of MARPOL ANNEX I? Yes, according to the regulation, records of the STS operations are considered to be the following: –– The Revised Annex I of MARPOL chapters 3 and 4 (resolution MEPC.117(52)); requirements for recording bunkering and oil cargo transfer operations in the Oil Record Book –– Any record required by the STS operations Plan STS check-lists are therefore part of the records.

Liabilities and obligations Liabilities and obligations of Charterers/STS organizers 16.01 Who is an STS organiser?” According to the latest STS OCIMF guidelines an STS Organiser “is a shore based operator responsible for arranging an STS transfer operation. The Organiser may be an STS Service Provider.” The term “STS ORGANISER” is referenced in four separate sections throughout the latest OCIMF guidelines and in many cases this particular term is confused with the role of the STS Service Provider. The STS organiser can be either: –– The cargo owner who has ownership of the cargo to be transferred via STS –– Involved charterers –– The STS Service Provider who takes responsibility to assist the STS operation with the necessary technical and advisory resources –– The Technical operator who manages a vessel involved in an STS operation The definition of the STS Service Provider is explained in the latest OCIMF guidelines as “Companies sometimes employed to organise and assist with STS transfers. The services offered by these companies vary, but often include the provision of personnel and equipment to facilitate the STS transfer. The STS Service Provider may also supply the essential personnel and equipment needed, such as hoses, fenders and support craft. The STS Service Provider may also be referred to as an STS Contractor or STS Resource Provider.” The term “STS ORGANISER” appears at the following sections of the latest OCIMF STS guidelines: A. Section 4.3 states: “the STS organizer generally provide pre-arrival information to nominated ships. The STS organiser may be the operator of the ships if carrying out in-house operations, or may be an STS service provider. Normally such providers send advance STS instructions to the ships concerned.” According to this section the STS ORGANISER will inform both participating vessels of all necessary information prior to the STS operation. This information is described in detail at section 4.3.2 of the latest OCIMF guidelines. The understanding is that this is a responsibility of the charterer/cargo owner who

arranges for the STS operation. Once an STS Service Provider is contracted for the technical assistance and needed resources, he acts on behalf of the charterer/ cargo owner as the STS ORGANISER B. At section 9.1.3 of the latest OCIMF guidelines reference is made to the verification of age of utilized fenders by the master, shipping company or STS organiser, and if these are provided by an STS service provider. In this reference the “STS ORGANISER” is a different entity from that of the STS service provider since the age of fenders should be “ascertained” prior to use. Therefore it is concluded that in this case the STS Organiser is the charterer/cargo owner, or a Tanker commercial operator C. At the second to last paragraph of section 9.1.3 the following is mentioned: “It is the responsibility of the STS organiser to determine the fender requirements and to agree these with all other parties involved” The parties involved in an STS Operation are the technical operator and his Master, the STS Organiser and STS Service Provider. In this case, if the STS Service Provider and STS Organiser are the same entity, then fenders should be agreed upon between the Service Provider and the Master. If the STS organiser is the charterer/cargo owner then he should determine fender requirements and agree with those of the Service Provider and the Master. From above paragraphs, it is clear that the “STS ORGANISER”, as a term, is in fact confusing since in most cases it reflects the duties of the STS Service Provider. The STS ORGANISER is the entity that “ORGANISES” an STS operation. In simple terms, it decides on both participating vessels, the STS location and Service Provider. The confusion in his role, in conjunction with the role of the STS Service Provider, is a result of the charterer’s duties and responsibilities denoted within the STS clauses of various charter parties. The STS Service Provider is a servant to the charterer/ cargo Owner and as such he undertakes to provide the appropriate resources for the safe completion of the STS operation.

The definition of the STS Service Provider is explained in the latest OCIMF guidelines as “Companies sometimes employed to organise and assist with STS transfers.

Having mentioned the above, as a matter of consistency, it is proposed that all STS Stakeholders have the STS Organiser well defined prior to each STS Operation. In doing so, tanker operators should request from their brokers/ charterers to revert with the STS ORGANISER full style prior to the commencement of the STS Operation. 16.02. Are charterers and cargo owners liable for the STS Service providers and POAC? The charterers/cargo owner who actually organized the STS operation, appoint all parties involved in the operation and agree their duties. Under common charterparty clauses they usually have to exercise due diligence in order to ensure that all necessary resources towards a successful operation are available, including the appointment of STS service providers. The liability for ensuring the safety of the operation stays with both Masters of the vessels. Careful attention should be paid as the STS Service provider may have a direct contractual commitment with cargo owners and not directly with owners or charterers. It is sensible to ensure that STS Service Providers are being audited on the basis of industry standards to maintain best practice.

he deems inappropriate. Attention should be paid the legislation of some flag states which require approval of the POAC by the administration. Liabilities and Obligations of Tanker Operators and Masters OCIMF guidelines are very clear in this respect. At paragraph 1.5.1 the following is stated: “The Master of each vessel shall always remain in command of his vessel, crew and cargo, and shall under no circumstances permit safety to be jeopardized by actions of others” Tanker Operators should exercise their due diligence and assist the Master in every feasible manner to ensure the safety of the operation. 19.01. In which documents are the owner’s liabilities in STS operations stated? The owner’s STS liabilities are stated in the governing charter party STS clause or elsewhere in the contract between the ship owner and the charterer.

Liabilities and obligations of service providers STS Service providers are appointed by charterers / cargo owners, under a contract that should meet the requirements not less than those of the latest OCIMF guidelines. Their role is to provide equipment according to agreed standards and arrange an experienced and qualified POAC, should one be requested. They bear no liabilities in ensuring safety of the operation.

Liabilities and obligations of POAC The official role of the POAC is to have advisory control during the STS operation. He bears no official responsibility; however, he is supposed to advise and assist the Master in all matters. The Master remains responsible in all respects for the safety of his ship and crew and can disregard any advice by POAC in cases

STS clause A commercial agreement The STS clause in the charter party provides the option to the charterer to discharge all or part of the cargo by Ship to Ship transfer means. The ship owner and charterer agree on the conditions and requirements for the STS transfer and this is depicted in this clause. There are various STS clauses, but they generally all require that the operation will take place according to the latest OCIMF/ICS guidelines. 20.01. Why does the charterer request clearance for the nominated vessel by the tanker owners? Isnâ&#x20AC;&#x2122;t this request covered by the STS clause? Charterers exercise their due diligence with respect to all the participating elements in an STS operation. However, tanker operators have to ensure safety and thus they have to agree that the participating vessel is suitable for the STS operation. The charterer is not responsible for the safety of the STS operation. Each ISM Manager (Technical operator or DOC holder) is responsible to ensure the safety of his vessel during operation. Thus, he has to review the suitability of the nominated vessel and provide his consent for the operation. Such consent should be the outcome of a risk assessment on the basis of established and standardized procedures. 20.02. How long should it take for a tanker operator to respond with his decision regarding a clearance request? The response time depends on the availability and accuracy of the provided clearance documents, as well as the screening procedure of the tanker operator. Prompt response is highly appreciated from charterers. The provided information should be reasonable for the purpose of evaluating vesselsâ&#x20AC;&#x2122; suitability. In case this information is poor, the tanker operator has the right to request additional information.

20.03. The charterer requests clearance for STS nominated vessels from the tanker owner in order to allow him to review vesselâ&#x20AC;&#x2122;s details and decide on her suitability. Is it necessary to state in the C/P STS clause the documents required for such clearance since there is no industry standard practice for this? Final approval of the proposed vessel for STS operations remains with the Master, who has the right to refuse, abort or suspend the operation at any time. Such a right should be exercised reasonably and upon due consideration of the information provided. The clearance process includes the request of the charterer towards the tanker operator to approve a nominated vessel on the basis of safety and suitability. Thus the operator has the right to review the details of nominated vessels and revert to his charterer in reasonable time with a decision that has to be justified on the basis of industry practices. If the vessel is approved as suitable, then appropriate planning should take place prior to the operation. In order for the tanker operator to conclude that the proposed vessel is suitable he needs the characteristics of the vessel and selected documents, which ensure that the vessel is fit to perform the STS operation according to the regulations, the latest OCIMF guidelines and STS Plan policies and procedures. A risk analysis should also be developed in order to request specific risk mitigation measures or any other subjects associated with safety issues. Such risk assessment could be established by the charterer and be delivered to the tanker operator for review at the nomination phase. General risk assessment on the impact of STS elements requires resources and statistical data. If the clearance process is clearly prescribed and the required documents clearly mentioned in the STS clause, all the arrangements will be simplified and accelerated. It worth mentioning that prompt response is highly appreciated by charterers.

20.04. Should a Master be “held accountable” in having made an unreasonable decision to withhold his approval towards the commencement of the STS Operation? The Master is fully accountable to ensure safety in an STS Operation. In order to do so, he has to receive all necessary information for the participating vessel in advance such as, but not limited to, a vessel description, valid STS plan, a mooring arrangement and confirmation that the vessel has no outstanding conditions of class that relate to her STS performance. Also, the STS transfer OCIMF checklists 2 and 3 must be completed and then reviewed prior to the mooring operation. It could be considered unreasonable for the Master to withhold his approval for a STS to commence when he has failed to perform his obligations and actions. The charterparty STS clause should be comprehensive and concise for the Master. This will allow him to understand his accountability, his obligations and required actions.

Some charter parties, such as Shell Voy 6 mention at the “safe berth” clause the following: “… Notwithstanding anything contained in this Charter, Charterers do not warrant the safety of any port, berth or transshipment operation and Charterers shall not be liable for loss or damage arising from any unsafety if they can prove that due diligence was exercised in the giving of the order or if such loss or damage was caused by an act of war or civil commotion. … ” Such rider clauses state an exclusion of the charterer’s liability, provided that there is proof that due diligence was exercised in the giving of the order.

If the vessel is approved as suitable, then appropriate planning should take place prior to the operation from the tanker operator.

20.05. In some STS clauses, reference is made that the STS operation is “….at charterer’s risk”. Does this mean that the charterer will be held responsible for any incident or accident? The full STS clause and charterparty must be considered. In general, there will be a strong argument that the charterers are taking on risk for the STS operation although this may vary from case to case. Generally, the Master of each vessel remains in command of his vessel and crew and shall under no circumstances permit safety to be prejudiced by the actions of others, including STS service providers and POAC. In the event of any incident or accident, the actions of the tanker operator, STS service provider, POAC and the Master will always be investigated when deciding liability irrespective of the STS clause. Careful consideration should be given to the full terms of the charterparty.

Clearance request, screening and due diligence Due diligence concept in STS operations 21.01. Is safety in STS operations guaranteed through due diligence? There are no safeguards that can make the probability of accident equal to zero. However, all stakeholders (tanker operators, STS organizers, etc.) should estimate the risk of the operation and take all necessary and feasible risk mitigation measures to minimize the adopted risk to an acceptable level. If there is any available information which can be used to estimate the risk and/or mitigate the risk this should be utilized. All possible risk mitigation measures should be considered even if minimal. The objective in this case is not limited only to bring the risk in an acceptable level; the objective is to minimize the risk. 21.02. What are the steps a “tanker operator” should follow, in order to exercise due diligence? The tanker operator should: –– Establish policies and procedures for assessing the risk and for taking risk mitigation measures –– Keep comprehensive records –– Review records and all available information in order to generate lessons learned and improve the adopted policies and procedures 21.03. What resources are available for a tanker operator when exercising due diligence? The tanker operator should rely on: –– The STS Policies and procedures –– The latest OCIMF guidelines

21.04. Is it possible for tanker operators to have the due diligence process standardized in STS Operations? It has been proven by information available from third party service providers that exercising due diligence could be a standardized process by adopting justified policies and procedures. Any adopted procedure should focus on minimising the administration burden, rapid response during the clearance request by charterers and should also make use of past accumulated knowledge from STS operations. 21.05. How can a tanker operator prove that he followed specific procedures and policies when exercising due diligence? The tanker operator could prove that he follows specific procedures and policies by maintaining records of an adopted methodology. Such methodologies are available from 3rd party contractors. The utilization of a 3rd party consulting company is not obligatory; however, it strengthens the position of the tanker operator since it minimises required resources.

The purpose of the clearance request Although the Charterer should review safety procedures and avoid operations with excessive risk, the final responsibility for ensuring safety rests with the tanker operator and the Master. The tanker operator has to review proactively the suitability of the nominated vessel. The final approval of the vessel proposed for the STS operation is given by the Master, who has the right to abort or to suspend the operation at any time due to safety reasons. The clearance process is initiated through a request towards the tanker operator to review the suitability of the proposed vessel for the STS operation. If the vessel is found suitable, then appropriate planning shall be initiated.

–– Available information from third party sources.

Screening procedure

–– Time to assess his risk and the nominated vessel suitability

Prior to accepting a vessel to participate in an STS operation, the screening process should include but not be limited to the following:

–– Knowledge on risk mitigation actions

–– Confirmation that the prospective STS vessel has P&I cover in place via a recognized P&I insurer –– Confirmation that the prospective STS vessel is in class with a recognized classification society –– A completed list of the particulars of the prospective STS vessel should be available

–– If practicable, vessel’s historical Port State Control (PSC) records –– Confirmation that suitable security arrangements are in place on the participating STS vessel and that she has an approved security plan onboard –– Declaration that a risk assessment has been undertaken prior to each STS operation –– Obtain information about participating vessel past STS performance

–– Utilizing a closed chock for multiple lines is acceptable provided that measures against chafing are taken. Open chocks and fairleaders can be used only in special circumstances (e.g. barges) provided that proper planning is agreed on by both Masters and the POAC. Otherwise, open chocks and fairleaders are considered unsafe and unsuitable for STS operations –– Incompatibility due to different policies and procedures prescribed in the STS plans of both ships

–– Information of the last SIRE/CDI inspection date

–– A condition of class which could affect the STS performance

Furthermore, the screening process should be part of a clearly documented procedure with tanker operator policies clearly outlined.

Reasons for a tanker operator to reject a vessel

23.01. Which documents are useful, when a tanker operator is requested to clear a vessel? When a tanker operator is requested to clear a vessel the following documents will be useful: –– Q88 or VPQ or equivalent in order to review the characteristics of the vessel and its status regarding the certificates –– Class Status in order to review the class records, memos & conditions, if any –– P&I certificate in order to review the insurance status of the vessel –– IOPP form B –– Crew matrix and STS experience of the crew in order to take into account experience of the crew –– Confirmation of STS plan approval

Possible vessel incompatibility or unsuitability issues Some possible vessel incompatibility issues include, but are not limited to the following: –– Incompatible mooring arrangement, poor quality and/or damaged mooring lines. Furthermore, wire mooring lines without tails can also be considered as unsuitable.

In some cases, nominated vessels could be rejected by tanker operators, when the vessel’s suitability is not justified on the basis of the documents provided by the charterer. In such a case the tanker operator should clearly and promptly justify his decision in order to allow time for the charterer to respond with more information or alternatives. Owners are requested to declare at HVPQ question 13.1.1 or Q88 question 8.26 whether their vessel complies with the recommendations contained in the latest OCIMF/ICS guidelines. Usually the answer provided is “YES” and although an obvious one, it is considered that owners’ answer should be the outcome of a careful verification process, taking into consideration the physical characteristics and available equipment on board their vessel as well as the procedural requirements, as reflected both by the latest STS guidelines and the STS Plan of the technical operator. 25.01. When should a nominated vessel be rejected? A nominated vessel may be rejected for ship–to-ship transfer when it is not considered to be suitable. The reason(s) for the rejection must be made clear to the charterer in order to provide the opportunity to investigate further on the condition of proposed vessel.

–– Incompatible manifold arrangement and lack of needed reducers –– Condition/maintenance records of cargo hoses crane. –– None or inadequate number of chocks of enclosed type

The general rule of thumb is that when a vessel is not complying with OCIMF recommendations, then it shall be considered as unsuitable and should be rejected.

28.01. If an accident occurs, what could be the consequences for the operator if he has failed in his due diligence actions?

Risk mitigation measures in the clearance phase

However, proving that the operator has acted with due diligence can be a great advantage towards consideration of a case.

Depending on the situation there are a number of risk mitigation measures. Indicatively some of these measures are the following: –– In case there are not enough closed chocks, a closed chock can be utilized by multiple lines, provided that protective measures against chafing of lines have been placed –– Adding extra watches can minimize several risks (e.g. risk due to increased traffic, mooring line break-down due to chafing or excessive tension due to rolling effect, etc.) –– Calm weather conditions and use of tugs can decrease the risk of vessel contact, when in fact there are restrictions in maneuverability –– The presence of an assistant POAC in the constant heading vessel may improve communication between large vessels or prolonged STS operations

Preliminary phase of the organization of an STS transfer operation 27.01. What should be ensured prior to organizing an STS operation? In the preliminary organization of an STS transfer operation, it has to be ensured that the ships used are compatible in both design and equipment; that they comply with the various recommendations included in the plan and that mooring operations, hose handling and communications can be conducted safely and efficiently. Finally, it has to be confirmed that both vessels have an approved STS Plan and that the checklists as proposed at the latest OCIMF guidelines are completed.

Essential information that master should be aware of prior to the STS operation Essential information that should be passed to the Masters of each participating vessel prior to the commencement of an STS operation is that of Checklist 1 of the OCIMF guide along with fender and hoses maintenance certificates.

The liability of the operator is likely to be governed by the contract under which cargo owners / charterers appointed them. Most operators have standard terms of business that attempt to exclude all liabilities. Careful consideration of the contract and wider circumstances will be required on each occasion to establish whether the operator might be liable to the Owners and / or Charterers for any lack of diligence.

Credibility screening of STS Service providers 29.01. Does the tanker operator or the Master have the right to refuse a specific service provider? Although charterers request clearance for nominated vessels in an STS operation, they do not exercise the same practice for the Service providers, who play an important role to the safety of the STS operation. Service providers are normally not nominated by tanker operators, who have to ensure the safety of the operation. Thus, the charterer should promptly‫ ‏‬provide to the tanker operator the full style of the organization that will act as the STS service provider‫ ‏‬and any information available that assist the risk assessment of the tanker operator. A refusal for a nominated service provider should be justified on the basis of best industry practices towards ensuring safety and mitigating risk. The existence of assessments for past STS operations is useful in justifying such exercise. Screening of other STS elements (POAC, Location, etc.)

Improper practices during an STS operation affect the reputation of the involved service provider and POAC.

POAC Definition According to MOP, the POAC is defined as a qualified and experienced senior deck officer, who will either be one of the Masters involved or an STS superintendent. A POAC is required for MARPOL ANNEX 1 cargoes and for STS Operations at Sea. Local administration rules and regulations should be consulted for POAC requirements.

Required qualifications According to MOP, the POAC should have at least the following qualifications: –– An appropriate management level deck license or certificate meeting international certification standards, with all International Convention on Standards of Training, Certification and Watch keeping for seafarers 1978, (STCW Convention) and dangerous cargo endorsements up to date and appropriate for the ships engaged in STS operation. Therefore, the POAC could be a former Master or chief officer (chief mate), who has attended the Management Level Course (MLC) for marine deck officers in compliance to regulation II/2 of the STCW Convention. In addition, dangerous cargo endorsements should be up to date and appropriate for the ships engaged in the STS operation. –– Attendance at a suitable ship handling course –– Conduct of a suitable number of mooring/unmooring operations in similar circumstances and with similar vessels. This should be recorded and available upon request for review –– Experience in oil tanker cargo loading and unloading. This should also be recorded and available upon request for review –– A thorough knowledge of the geographic transfer area and surrounding areas. The STS Service Provider who proposes the specific POAC should verify the familiarization of the POAC with the geographic transfer area and surrounding areas. In case the POAC is not supported by a reputable STS Service provider, a suitable number of past STS operations in the area are good indication of his knowledge in the geographical area –– Knowledge of spill clean-up techniques, including familiarity with the equipment and resources available in the STS contingency plan

–– A thorough knowledge of the STS operations plan. It is prudent to send the STS plan to the POAC electronically prior to the operation. Additionally, discussions with the Masters regarding the STS plans are considered prudent 33.01. What is a suitable number of mooring/unmooring operations for a POAC? MOP makes reference that the POAC should have completed a suitable number of mooring/unmooring operations. A specific number that ensures an optimal level of experience is subjective and depends on various parameters such as the past experience and skills of the POAC; training and experience in similar operations, conditions during specific mooring/unmooring operations etc. The experience of the POAC should be ascertained by the Master, on a case by case basis, in conjunction with the conditions and complexity of the STS operation. 33.02. How are the terms “similar circumstances” and “similar vessels” defined? The term “similar circumstances” is defined as and used when describing (but not limited to) similar weather conditions, similar STS equipment, similar vessel traffic or geographical restrains, or similar STS type. The term “similar vessel” can be used to describe a vessel of the same type and up to a 10% difference in overall length. 33.03. How can a mooring Master gain experience in order to become experienced for POAC duties? If a mooring Master is inexperienced in specific STS operations or for a specific type of vessel, he can then act as an assistant POAC in order to gain experience.

Duties – authorities – responsibilities of POAC The duties, authorities and responsibilities are clearly described in the Manual on Oil Pollution. 34.01. Should the Master always rely on the advice of the POAC? The Master should always actively consider the advice of POAC. The Master should understand that he remains ultimately responsible for the safety of the vessel. The POAC acts in an advisory capacity only and there are cases where the advice of the POAC could be detrimental towards overall safety. It is very important that the Master of each vessel always remains in command of his vessel, crew and cargo.

The Master should not jeopardize, under any circumstance the safety of the operation. He should always be alert and ready to take control, and either stop the STS or consider not following the advice of the POAC if they feel that the directions of the POAC are unsafe. In these circumstances, the concerned Master should communicate directly with the Master of the other vessel to agree any action to be taken. It is also suggested that, where appropriate, the concerned Master should seek guidance from ashore (including from its POAC).

POAC and service provider One of the services offered by the STS Service providers is to propose a qualified and experienced POAC. They have to ensure that the proposed POAC is qualified according to the regulations and that he/she has adequate experience. The POAC has to attend regular refresher courses, be aware of local legislation and facilities, and have relevant experience for the specific STS operation. The POAC could be one of the vessels’ Masters should their experience and training satisfy the regulations’ requirements. 35.01. Is the service provider liable for the POAC? The service provider has a duty to provide a POAC that satisfies the requirements of regulations. He is not responsible for the actions of the POAC and the safety of the STS operation, which remains with the Master. The liability of the service provider is, however, likely to be governed by the contract under which cargo owners/ charterers appointed them. Most service providers have standard terms of business that attempt to exclude all liabilities. Careful consideration of the contract and wider circumstances will be required on each occasion to establish whether the service provider might be liable to the Owners and/or Charterers in respect of the POAC. 35.02. Does the Master or tanker operator have the right to approve or refuse the participation of a specific POAC? Yes, in order to ensure safety, the Master and the tanker operator has the right to ask for a proper qualified and experienced POAC. In addition, the Tanker operator has the right to refuse a specific POAC based on unsatisfactory records of past performance and inadequate follow-up actions using the safety management system of the service provider. In these specific cases the tanker operator, prior to

reaccepting the POAC, has the right to ask if the specific POAC has attended any refresher courses, gained any extra experience, or has taken other reasonable measures in order to improve his skills. 35.03. Are there means and a procedure in place by the ship owner to assess the experience of the service provider and POAC? Section 1.8 of the latest OCIMF guidelines states that: “that factors such as location, service provider and equipment to be used may result in additional training being required for experienced personnel. Where there is little or no experience with STS operations, consideration should be given to providing additional experienced STS personnel prior to the operation to assist with the training of personnel and the STS operation.” The experience of the service provider and POAC is of paramount importance. The level of experience of the service provider and POAC may result in requirements for additional training of crew. For this reason, Technical operators should have procedures in place that would allow for the evaluation of service provider and POAC experience. The latest OCIMF guidelines have made provisions for the quality assurance of service providers by the users of their services, i.e. the technical operators. 35.04. If the POAC is not fully employed by the service provider, would this affect the decision whether to accept his participation or not? No, the screening of the POAC should be performed strictly according to his qualifications and his past performance. Full employment of POAC is a contributing factor only to the quality assessment of service providers.

POAC and security 36.01. Does the STS Service provider have the right to deny the provision of information, such as records and ID information for the nominated POAC to the tanker operator? There are no grounds for a service provider to deny the provision of information, records and ID information of the nominated POAC to the tanker operator. ID information is an ISPS requirement and qualifications and performance records are required in order for the tanker operator to perform due diligence and ensure safety.

Assistant POAC 37.01. Is it recommended to have an assistant to the POAC during the STS operations? The participation of an assistant to the POAC during the STS operations is not mandatory. However, it would be highly recommended in cases where the risk of the STS operation is considered higher than normal due to external factors. In such cases an assistant to the POAC could contribute to with the heavy duties of the POAC and minimize the risk factors. An assistant to the POAC could be also utilized for training purposes.

STS Service providers Quality assurance If an STS service provider is employed by the charterer/ cargo owner, the quality of the services and equipment provided are paramount if operations are to be carried out safely, reliably and efficiently. It has to be pointed out that the responsibility for the STS operation always lies with the Master who shall under no circumstances permit safety to be jeopardised by the actions of others, including the service provider. Although the current industry regime provides guidelines for the assessment of service providers, there are currently no international standards such as ISO. Some STS service providers have some form of ISO 9001 or 14001 accreditation. However, this should not be the only determinant of quality. Performance records and previous industry experience may be important when assessing an STS service providerâ&#x20AC;&#x2122;s ability to meet customer and regulatory requirements. STS service providers might be subject to assessment by users of their services who are the ship owners and their Masters. 38.01. Should the tanker operator audit service providers? Although in most cases tanker operators do not have any contractual agreements with the STS service providers, they use their services and have the right to assess their procedures towards ensuring safety.

It is not practical for a tanker operator to physically audit service providers prior to using their services. However, it is prudent to ask for assurances and possible records associated with the required resources, experience, and professionalism to provide their services with the expected level of quality.

Audit from charterers The charterer/cargo owner will only assign the involved parties and set the standards. Although they are not directly liable to ensure safety, they have to ensure that all required conditions are satisfied and that safety is preserved. For this reason they have to audit all hired stakeholders and ensure that they can provide their services with the expected level of quality. TMSA and SIRE are tools to audit tanker operators and vessels. Service providers are audited in a similar manner, through OCIMF standards.

Screening of STS Service providers from tanker operators The level of quality from the STS service providers is crucial towards the safety of the operation. Thus a prudent tanker operator should examine the participation of the STS service provider in the same way he does for the nominated vessel. However, the possible lack of a clear framework by the service provider does introduce some practical problems. Tanker operators should at least examine any information they can obtain and most importantly his past experience, if any, with the specific service provider. This is one example that reflects the importance of assessing and maintaining records of past STS operations. DYNAMARINe has developed a number of tools for effectively assessing the performance of STS service providers. It also introduced and implemented the concept that each tanker operator share safety-related information with other tanker operators.

Approval of authorities Some authorities (i.e. Denmark) request service providers to be pre-approved by them, in order to operate in their EEZ. Furthermore, according to some local regulations, tanker operators may be requested to ensure that they will only use service providers that are approved by local authorities.

LOI (Letter of Indemnity) Some service providers raise an LOI to the Masters or to the charterers, prior to the commencement of STS operations, in order to clarify that all liability towards overall safety and responsibility remains with the Masters of the vessels. 42.01. What is the purpose of the LOI’s presented by Service Providers to tanker operators prior to the commencement of the STS Operations? The purpose is for the tanker operator to accept and potentially take on some non-contractual risk, which otherwise they would not be exposed. The letter is an attempt by STS Service providers to transfer the responsibility for the operation on to the Master and with it all claims, costs and expenses. Accepting or signing an LOI may prejudice the ship-owners P&I insurance cover for the additional risk. In summary, by accepting an LOI the following can occur:

42.03 What level of liability would burden the tanker operator by accepting/signing an LOI presented by a STS Service provider? LOI’s presented by STS service providers extend the ship-owners’ liability beyond terms and conditions as agreed between the charterers and the ship-owners. For example, the LOI may require the ship-owners to accept the responsibility for all the actions of the mooring Master and the direct/indirect consequences during an STS operation. Signing an LOI, even for receipt only, may result in potential breach of the insurance coverage along with financial liabilities. Ship-owners, or the Master, if requested to accept an LOI should refer the matter immediately to their P and I Club.

To create a contractual relationship between the ship owner and the service provider –– To eliminate POAC liabilities unless gross negligence is proved –– To have the tanker operator be responsible for the entire STS Operation, crew and equipment to an unlimited value 42.02. Do Masters have to sign an LOI presented by a Service Provider? Before conducting an STS operation, some service providers tender LOIs to the Masters of the vessels and request that it is signed on behalf of the owner prior to the commencement of the STS Operation. Following several contacts as well as discussions with P&I clubs the following procedure is recommended to be adopted by the ship owners as a standard policy: 1. Masters/Managers should avoid signing LOI’s provided by STS Service Providers 2. If the STS SERVICE PROVIDER insists, then the P&I club should be immediately informed and consulted to avoid the potential risk of cover being prejudiced 3. Masters/ Managers should only sign the LOI, incorporating any suggestions from their P&I club

Local authorities Exclusive economic zone (EEZ)

–– Oil type and quantity

An exclusive economic zone (EEZ) is a sea zone prescribed by the United Nations Convention on the Law of the Sea over which a state has special rights regarding the exploration and use of marine resources, including energy production from water and wind.

–– A confirmation that both ships involved have an approved STS plan on board

Notification The notification to the coastal authorities shall include information such as: –– The name, flag, call sign and IMO number of the ship –– The estimated time of arrival of the ships which will be involved in the STS operation and the approximate duration of the operation

There are more than 170 dedicated STS locations worldwide

–– The date, time and geographical location. –– The type of the STS operation (at anchor, underway, mooring underway and then at anchor)

–– Identification of the involved STS Service provider and POAC

Application of notification The authorities should be notified for all STS operations within the EEZ at least 48 hours prior to the commencement of the STS operation, or as directed by national/local regulation. 45.01. What are the potential consequences when failing to notify the Authorities prior to the commencement of the STS operation? Notification for the commencement of an STS operation is obligatory according to the Regulation. When the local authorities become aware that a ship failed to notify them for an STS operation, they have the right to detain the ship if they are within the territorial waters. In case the operation takes place outside of the territorial waters and within the EEZ, the authorities have the right to notify the ship’s administration. 45.02. If an STS operation takes place in international waters, is it required to inform the coastal administration? When an STS operation is taking place within the EEZ (Exclusive economic zone), the coastal administration has to be informed in case the distance of the STS Location is less than 200 nautical miles from shore or if the STS Location is within the EEZ of the Coastal state administration. 45.03. Who has responsibility for the environmental protection inside an Exclusive Economic Zone (EEZ)?

45.04. Is approval from coastal authorities’ necessary prior to the initiation of an STS transfer operation? Approval from coastal authorities is necessary prior to the initiation of an STS transfer operation only in territorial waters. However, authorities bear the full responsibility of safety in the entire EEZ and thus they can prohibit the STS, or ask for additional measures in the entire EZZ. Notifications should be provided throughout the entire EEZ. 45.05. Do tanker operators have procedures in place to assess the suitability and risk assessment of the transfer location? The transfer location should be assessed for STS suitability. The STS organizer and the Service Provider play an important role as they should also assess the transfer location and provide relevant feedback to the Master. Section 2.3 of the latest OCIMF guidelines makes relevant reference “to the guidance and example checklists contained within OCIMF Ship to Ship Service Provider Management publication”. The Master, however, should undertake a risk assessment on the basis of provision of information from the service provider. For this reason the level of quality of the service provider should be ascertained prior to the STS operation. Any available information and past experience for the transfer location may prove valuable during the assessment phase.

The responsibility for environmental protection inside an EEZ is attributed to the coastal authority. However, coastal authorities must declare their EEZ.

Operational â&#x20AC;&#x201C; Equipment Personnel transfer Offshore operations, including Ship to Ship transfer operations, may include the transfer of personnel between the two seagoing vessels and or the service boats. It is important to clearly define the purpose, scope and responsibilities prior to each personnel transfer operation in order to avoid any damage and loss of life. Training for using the specific devices, as well as proper planning and risk assessment is of utmost importance. There are a number of alternative ways for bringing personnel on board. These include the use of net or baskets (including advanced baskets like FROG and TORO), swinging ropes, gangways, ladders and helicopters. The use of lifting appliances (net or baskets) is the most popular.

Personnel transfer by basket could be considered as a safe and acceptable procedure provided that all safety precautions and best practices are followed. Frog personnel transfer device. This device offers reduced risk personnel transfer

46.01. Is the personnel transfer by basket a safe and acceptable procedure? Personnel transfer by basket could be considered as a safe and acceptable procedure provided that all safety precautions and best practices are followed. Both ships are likely to be rolling during a Ship to Ship transfer operation so special care should be taken during planning and the risk assessment.

Additionally, the service range of lifting appliance during operation has to be carefully considered to ensure that it will not be exceeded at any circumstances. Furthermore the place should be manned all the time and in case of emergency, safe exits for attending personnel is required. The use of personnel transfer equipment should not be allowed for other duties.

The following issues should be reviewed by both Masters and officer in charge:

46.02. Is there any industry standards on the expiration date of Baskets used for Personnel Transfer?

–– Procedures: Personnel transfer baskets procedures should take place according to OCIMF and STS Plan guidelines. The latest OCIMF guidelines published on November 2013 include a section associated with basket transfers and Risk mitigation procedures. It has to be ensured that all STS Plans have been reviewed and updated accordingly to reflect the new guidelines

Baskets utilized for personnel transfer should undergo scheduled inspections according to manufacturer guidelines available through the manufacturers or other related organizations such as IMCA.

–– Maintenance: Personnel transfer baskets should bear a type approval, regularly surveyed and tested –– Cranes: The crane should be equipped with a special mode for personnel transfer. Range and operational loads are subject to the service requirements, mentioned in the specification and operations manual –– Training: Training should be regularly performed for each specific device. Operators should have adequate knowledge and experience and records should be available to provide proof –– Risk assessment: A risk assessment should be performed –– Proper Planning: Several restrictions and requirements on board shall apply for the safe conduct of the operation. Boarding area should be marked and be of adequate size for boarding, free hoisting and lowering. Planning should also predict for non-skid surface, free of obstacles such as piping, air vents, bollards etc. The boarding areas should also be wind and spray sheltered with low noise, free of vibrations and adequately illuminated. Finally, it should be ensured that both crane operator and banks man have good visibility of the embarkation –disembarkation area –– Briefing: Persons involved in basket transfer should be briefed for safety precautions and emergency actions. Users of the basket should always wear PPE and reflective vest and the operation should be attended by authorized people only

Such baskets were common on oil tanker vessels especially during STS operations; however, their use has been extended to all vessels as a recovery means for persons from the water under SOLAS III/17-I. Therefore, the inspection and maintenance of such baskets is a critical issue. Further to an investigation, onlineSTS.net concluded that the expiration date of such baskets depends on their condition after assessment. The question that is being raised is, “Who is going to make the assessment and how much will this cost in comparison to a brand new basket?” There are 2 options to consider: 1st option: The assessment of the basket’s condition will be made solely by the Master, however, taking into consideration the potential risk to life, it would not be prudent to adopt such assessment procedures. 2nd option: The assessment would have to be made by the manufacturer or a specialist with equivalent qualifications. In this case the cost of replacement with a brand new basket would probably be equivalent to a scheduled maintenance. As a conclusion ship owners and their operators are recommended to adopt: 1. Proper storage procedures for baskets 2. Scheduled visual inspection procedures prior to each use 3. Risk assessment procedures prior to each use 4. A replacement policy

46.03. What are the features of the cargo crane, in order to be suitable for personnel transfer by basket?

46.04. What options has the Tanker operator if cargo cranes are not designed for personnel transfer.

Generally the crane should comply with DIN EN 13852-11 for loading and discharging goods in the applied range of service and applicable environmental conditions. Due to higher safety aspects for personnel transfers a separate mode for personnel transfer should be available, which fulfills additional safety requirements. Enhanced inspection and testing is also recommended.

Normally no lifting equipment shall be used for the lifting of persons unless it is designed for the purpose. MGN 332 of MCA (UK), for example, continues to state under regulation 9 – guidance note: “The lifting of persons must only be carried out using appropriately designated and marked equipment. No other equipment should be used for the purpose.”

The additional safety characteristics focus mainly on ensuring always manned operations, smooth and slow movements, low accelerations, backup power, brakes, unrestricted communication and visual contact with the crane driver. These include following issues:

If in exceptional circumstances it is necessary to use lifting equipment to lift personnel which has not been specifically designed for the purpose, the employer shall ensure that the control position of the lifting equipment is manned at all times and persons being lifted have a reliable means of communication, whether direct or indirect, with the operator of the lifting equipment. In addition, a risk assessment should be performed and operators (crane driver and banks man) should be experienced and familiar with the specific crane and the relevant procedures for personnel transfer.

–– Both acceleration and retardation should be guaranteed to be soft enough –– Normal lifting and lowering speed should be low and normally not exceed 0.5 m/s –– A secondary break circuit with an independent and separate control is required –– A manual release system for both lowering of the boom and load for leaving the carrier in a safe way is required –– A connection to emergency power system in case of blackout is required –– The activation switches or levers shall be of hold-to-run type. They have also to be clearly and permanently marked –– The operator should have a clear view of the load and lifting zone when using the emergency lowering control.

The following are some of the identified hazards associated with personnel transfer by basket. Those should be considered accordingly by Technical Operators and their procedures in SMS: –– Moderate – heavy Sea conditions resulting in excessive rolling of vessels during raising personnel from the support vessel –– Failure of the basket –– Mishandling of the crane by operator

–– A communication system for the crane driver with the responsible person is required

–– Inadequate training/competence of all personnel involved in the operation

–– The automatic overload protection system (AOPS) should be inactive

–– Unexpected basket contact with obstructions

–– Direct drive from the lifting equipment should not be allowed

–– Failure of the crane brakes

Furthermore, the range of the service shall be limited in accordance to the weather conditions and visibility. Normally the following limits should not be exceeded: wind of 10 m/s and sea state of 2 m significant wave height. (According to DNV Standard for certification of Lifting Appliances, October 2011 Ch.2 Sec. 9)

1. DIN EN 13852-1:2014-01: Cranes - Offshore cranes - Part 1: Generalpurpose offshore cranes

46.05. Which are the identified hazards involved in the transfer of personnel by cargo cranes?

–– Personnel Injury during landing on the vessel –– Failure of the crane wires –– Vessel blackout during transfer operation –– Inadequate lighting during night operations –– Seaworthiness of the crew and vessels involved –– Lack of communication and/or visibility by the crane operator

Due to higher safety aspects for personnel transfers a separate mode for personnel transfer should be available, which fulfills additional safety requirements. 39

Mooring lines 47.01. What is the required number of mooring lines for a safe commencement of an STS operation? According to the latest OCIMF guidelines, the required number of mooring lines for both participating vessels should be: –– Six mooring ropes in the forecastle –– Two mooring ropes at main deck forward –– Two mooring ropes at main deck aft –– Four mooring ropes at poop deck An important issue that has to be carefully noted during the planning phase is the fact that mooring lines leading in the same direction should be of same material and properties, i.e. MBL, elongation etc. 47.02. In case you pass more than one mooring line through a closed chock/ closed fairlead, is the cumulative breaking strength of mooring lines less than the SWL of the closed chock? The proposed procedure for establishing mooring plans allows that one mooring line should pass from each closed chock/ roller fairlead. In case closed chocks are not enough in number, then maximum two mooring lines could pass through closed openings. In such case, the SWL of the closed opening should not be less than that of the combined breaking mooring lines load. 47.03. Should shipowners have procedures in place to assess the condition of mooring lines and winches prior to each STS operation?

47.04. Can wire pennants (Wire mooring tails) be utilised in STS Operations? Wire mooring tails, instead of synthetic, could be utilised. Wire tails main purpose is to allow more time to disconnect the hoses and separate the two ships in case of deteriorating weather. Secondary purpose is to reduce the sacrifice of nylon tails chafing in the STBL (Mother vessel) chocks, being able to provide better elasticity to the moorings of two ships interacting in moderate swell. Wire tails increase the safety factor when the two ships have to separate due to worsening weather conditions. The wire tails are connected to the soft tails, and the soft tails to the ships mooring wires by means of a Mandal or of a Tonsberg shackle. Both shackles serve the same purpose, but they are rigged in opposite way. For a typical panama lightering vessel galvanised steel wire tails have the following characteristics: –– Diameter: 36mm –– Length: 11m –– MBL: 92-96 mt

The Master and technical operator should have procedures for testing and examination of relevant deck equipment, prior to each STS operation.

According to latest guidelines section 9.3 “It is important that ships involved in STS operations are equipped with good quality mooring lines, efficient winches, well placed and sufficiently strong closed fairleads, bollards and other associated mooring equipment. The correct functioning of winch brakes should be ensured through regular testing.” In this respect the Master and technical operator should have procedures for testing and examination of relevant deck equipment, prior to each STS operation. Such records should be made available if requested by a third party.

Chocks – fairleaders 48.01. Is it possible to perform an STS operation if there are not enough chocks/fairleaders of an enclosed type? For routine operations on the basis of the latest OCIMF guidelines no open fairleaders should be utilized, even those fitted with stopper bars. However, according to Manual on Oil Pollution Section I, paragraph 6.2.6.12, open fairleaders are not prohibited, provided that the oil tanker will always have a substantially greater freeboard than the other. Such STS operations will not be strictly in accordance with the latest OCIMF guidelines. In case there is a strong need to perform such an operation, the conditions listed below need to be carefully considered: –– The freeboard of a ship which is using open chocks or open fairleaders must remain higher than the freeboard of the other vessel during the entire operation; –– Adverse weather conditions and rolling should be avoided –– STS operations at anchor should be avoided –– The STS risk assessment should include hazards associated with the existence of open chocks/ fairleaders –– The service provider should be aware of the existence of open chocks/fairleaders –– Deck crew should be vigilant with mooring lines at the entire duration of the STS Operation In any case, STS operations with open chocks/ fairleaders are not considered a good practice and should be avoided.

Roller fairleaders fitted with stopper bars are not recommended according to latest OCIMF guidelines as this arrangement does not substitute the strength of a closed chocks.

48.02. How many ropes can pass through a closed chock/ fairleader? The maximum number of ropes allowed through a closed chock/ fairleader depends on the following factors: –– The Safe Working Load (SWL) of the chock and MBL of the mooring line –– The diameter of the ropes –– The availability of protecting sleeves (when using more than one rope in the same chock, protecting sleeves must always be used to avoid mooring lines chafing)

48.03. What is the minimum recommended number of closed chocks? According to the latest OCIMF guidelines and industry best practices it is recommended to have at least 6 closed chocks at the forecastle, 2 closed chocks at the main deck forward and 2 at main deck aft and 4 closed chocks at the poop deck. The safe practice is to use one chock per mooring line. All other practices add extra risk in the operation. The number of chocks is directly related with their SWL and the breaking strength of mooring lines passing through. In case more than one mooring line passes through a closed chock, attention is drawn to the load capacity onto the chock as exerted from the Mooring lines. For example, if a closed chock has an SWL of 45 mt and 2 mooring lines with breaking strength equal to 35 mt pass through, then this could result in exerted load to the chock beyond its design limits. This is a practice which is not safe according to OCIMF and careful analysis of the incurred risk should be considered during the establishment of the combined mooring plan.

Fenders 49.01. Who is responsible to provide fenders for an STS operation? Fenders should be provided by the STS organiser or the STS service provider. The charterparty may provide who has the risk / responsibility between Owners and Charterers for the number and quality of the fenders. Careful consideration should be given to the charterparty wording. In the second to last paragraph of section 9.1.3 of the latest OCIMF guidelines, the following is mentioned: “It is the responsibility of the STS organiser to determine the fender requirements and to agree these with all other parties involved.” 49.02. Which are the required parameters in order to define the fenders quantity and type in an STS Operation? The required parameters to define the quantity, size and type of fenders in an STS operation are the vessels’ displacements, the type of the STS operation the approaching speed of the ships and weather conditions.

48.04. Should all tankers have closed chocks forward and aft of the manifold?

49.03. Who is responsible to ensure the provided fenders are adequate for the specific STS operation?

According to latest edition of OCIMF Mooring equipment guidelines, the oil tanker’s spring lines terminate on the discharge ship in a location not usually fitted with closed chocks. For this reason it is recommended that tankers over 160 kDWT be fitted with closed chocks with openings of 500x400mm, about 35 meters forward and aft of mid-length on the starboard side. Since the 500x400mm dimension is not a common standard size, some operators have successfully used two closed chocks with 500x250mm openings arranged in pairs, in place of a single 500x400mm chock.

The Master of each vessel has the overall responsibility for safety as such should not be compromised by any actions of third parties, as mentioned in the latest OCIMF guidelines.

In case more than one mooring line passes through a closed chock, attention is drawn to the load capacity onto the chock as exerted from the Mooring lines.

Prior to the commencement of the STS Operation, details of fenders to be used are to be provided to each Master by the service provider and/or the POAC. In case the calculations made by the Master do not agree with those of the service provider, then the Master should request further explanation. The factors that affect the fender selection, such as weather conditions, type of fenders, displacement and parallel body length of participating vessels as well as the type of STS operation (normal or reverse), need to be carefully chosen and/or included in the Risk Assessment of the Master.

49.04. Should the Master have adequate capacity and means to assess the requirements for fender selection? Fender Selection is one of the most important procedures at the STS operation. Although this usually takes place from the STS Service provider, the Master should have the capacity to check the effectiveness of the provided fenders. Fender selection should be included in the risk assessment of the Master as proposed at section 3.2.2 of the latest OCIMF guidelines. Furthermore, at appendix K fender defect and inadequate fendering are amongst the proposed causal factors. Therefore the Master and/or technical operator should establish procedures for ensuring that the fender selection is according to OCIMF and manufacturer guidelines as per section 9.1 and appendix H of the latest OCIMF guidelines. In Appendix K.3, “Examples of risk mitigation measures” the following is stated: “All equipment used in the STS is fit for purpose and meets appropriate international standards and conforms to accepted industry guidelines” Furthermore, in the process of defining the environmental operating limits, Masters should have the means to define the risk from the operating limits of mooring and fendering systems. Such limitations should be obtained through fender manufacturers. The table at section 9.1 of the latest guidelines is valid for normal STS operations and calm weather conditions. For all other operations, berthing energy calculation should take place in conjunction with fender design characteristics.

Fender location Primary fenders should be positioned along the parallel body of the ship to afford the maximum possible protection while alongside.

50.01. Is there a crucial difference if the fenders are located on the constant heading vessel or anchored vessel, instead of the manoeuvring vessel? Yes, there is a crucial difference which increases the risk of the STS operation. Latest OCIMF guidelines also refer to this. If such a case occurs, then this should be accounted in the risk assessment and risk mitigation measures should be introduced. Risk mitigation measures could include the provision of tugs, a second POAC on the constant heading vessel and/or the decision of underway mooring operation instead of mooring at anchor. 50.02. Is there a greater risk of contact during manoeuvring with this arrangement of fendering? Yes, the risk is bigger in case the fenders are located on the constant heading vessel rather than the maneuvering vessel. OCIMF guidelines also refer to this. If such a case occurs, then this should be taken into account in the risk assessment and risk mitigation measures should be introduced. Risk mitigation measures could include the provision of tugs, a second POAC on the constant heading vessel and the decision of underway mooring operation instead of mooring at anchor. Many operations when fenders were positioned on the constant heading vessel have resulted in a collision. There is always the risk that the maneuvering vessel may land on an unprotected part of the hull.

The role of secondary fenders Secondary fenders are used to protect bow and stern plating from inadvertent contact if the ships get out of alignment during mooring and unmooring.

Standards 52.01. Are there any fender standards? Almost all manufacturers of pneumatic type fenders comply with the requirements of ISO 17357:2002. This is reflected by the fender certificates that must be presented to the Master and/or his operator prior to the commencement of its STS Operation. ISO requirements not only refer to the manufacturing procedures but also stipulate the procedures of fender maintenance. More specifically, the below mentioned is included in paragraph 11 of the relevant ISO publication: “The manufacturer shall provide a maintenance manual, in the format of a logbook, where details could be recorded of all maintenance and repairs carried out on the fender, including safety valves, from new to date. All maintenance and repairs should be carried out in accordance with the manufacturer’s guidelines. The manufacturer shall also provide a handling/ storage/packing recommendation.” If the manufacturer recommends that the safety valve has to be inspected and maintained every 2 years, then such a recommendation should be followed by the fender provider in order to comply with the ISO requirements. If fender owners do not comply with the specified fender manufacturer guidelines, then the provided fender is not in accordance with ISO 17357:2002. In reference to the latest OCIMF guidelines, edition 2013, section 9.1.1, page 72, paragraph 7; it is recommended that primary pneumatic fenders should be maintained according to the ISO 17357 standards. Therefore, although fender providers may adopt other procedures from those denoted by the manufacturer, according to their individual maintenance procedures, those supplied fenders will not be in accordance with ISO 17357:2002 and OCIMF recommendations.

The marking requirements of ISO approved fenders 53.01. What kind of information should be included in the marking of ISO approved fenders? The information that should be provided on the marking of ISO approved fenders is: –– International Standard number, and applicable year, i.e. ISO 17357:2002 –– Size (diameter and length) –– Initial internal pressure –– Date of manufacture or its abbreviation –– Full or abbreviated name of manufacturer –– Individual serial number –– Type of reinforcement layer

Upgrading the fendering system A larger diameter fender is required when additional energy performance is needed or when more distance between ships is required. 54.01. Which are the proposed actions by the Masters in case the service provider delivers inadequate number and size of fenders according to OCIMF? In case the service provider delivers the inadequate number and size of the fenders according to OCIMF, the Master should abort the operation, as this might lead towards an accident and risk the safety of the ship. The Master should request the correct number and size as according to OCIMF.

Fender selection should be included in the risk assessment of the Master as proposed at section 3.2.2 of the latest OCIMF guidelines.

Hoses Transfer rate When agreeing on the cargo transfer rates, the limitations dictated by the cargo hoses and any other limitations imposed by flow velocities in the ship’s fixed cargo piping or venting systems should be taken into account. One other aspect that should be considered is the weather conditions that might cause the hoses to move.

Hose maintenance 57.01. What are the criteria to define whether a hose should be withdrawn from service or not? The criteria that should define whether a hose should be withdrawn from service are: –– The presence of defects detected during visual inspections. Defects could include irregularities in the outside diameter, such as kinking, damaged or exposed reinforcement or permanent deformation of the casing and damage, slippage or misalignment of end fitting –– A prolonged period of use –– When the temporary elongation of the hose, measured during routine pressure tests, exceeds maximum allowable values 57.02. Who is responsible for the intermediate connection of cargo hoses? Tanker operators’ SMS procedures should account for cases where intermediate connections between two hoses take place. A P&I club advice on this issue states:

“In case an intermediate hose connection (2 or more hoses are connected in line to form a longer hose) should be done on board the vessel then a pressure test, prior to the transfer operation begins, to the Master’s satisfaction should be carried out and recorded in the deck log book. The certificate of any pressure test of each of the hoses to be interconnected becomes void. If the hoses come with interconnections then the Master should either be handed over with a statement (dated the same date the operation begins) declaring that the complete length of the hoses is tested as connected and connections are sound, or a pressure test of the complete length should be carried out to his satisfaction. No ship equipment and / or material (gaskets, bolts, spanners, etc) shall be used for the intermediate hose connection.”

Tanker operators’ SMS procedures should account for cases where intermediate connections between two hoses take place.

Other equipment 58.01. Should the main radio be transmitting on either ship involved in an STS operation? No. The main radio should be earthed on both ships and neither ship should use this equipment while alongside one another. 58.02. Which communication equipment is allowed to be used during STS operations? The communication equipment that is allowed to be used during STS operations and will not affect safety measures are satellite communication (except if flammable gas is in the vicinity of the antenna) the VHF/ UHF radios and the Automatic Identification System (AIS). Communication method has to be agreed before commencement of any STS operation 58.03. Should the ICCP be switched off prior to the STS operation? It has to be ensured that the ICCP of both vessels are properly working. Should one of either system not be properly functioning it will result in overloading the participating vesselsâ&#x20AC;&#x2122; ICCP system. For this reason it has to be ascertained that both systems are in good working order. As a measure of precaution, the crew should monitor the potential and current outputs after the mooring operations have been completed. Should the measures be outside the specification of manufacturers, then both ICCP systems should be switched off. As the potential difference between the ships is managed by ensuring that effective electrical isolation is maintained throughout the transfer operation, ICCP systems should remain in operation.

Should one of both systems not properly functioning it will result in overloading the participating vesselsâ&#x20AC;&#x2122; ICCP system.

Safety/security Risk assessment – safety – emergencies Risk assessment A risk assessment form should at least include the following: • Identify the hazards associated with the operation (I.e. collision risks in the vicinity, cargo vapor pressure, H2S content)

• Adequate number of crew assigned to controlling and performing oil transfer operations

• Assess the risks according to the probability and consequence

• Adequate communications between oil tankers or responsible person(s).

• Identify the means by which to prevent and/or mitigate the hazard • Contain procedures for dealing with unanticipated events • Adequate training, preparation or qualification of the oil tanker’s personnel • Suitable preparation of oil tankers for operations and sufficient control over the oil tankers during operations • Proper understanding of signals or commands

• Suitability of the agreed STS operations plan

• Proper attention given to the differences in freeboard or the listing of the oil tankers when transferring cargo. • The condition of transfer hoses • Methods of securely connecting hose(s) to the oil tanker(s) manifold(s) • Recognition of the need to discontinue oil transfer when sea and weather conditions deteriorate • Adequacy of navigational processes

60.01. Does the risk assessment developed prior to the STS operation identifies the potential sources and consequences of risk not less than those depicted at section 3.2.2 and Appendix K of the latest OCIMF guidelines? The STS Risk assessment as developed, should account for the hazards outlined at section 3.2.2 and Appendix K. If the risk assessment does not consider those, then suitable justification should be provided. Such justification could be attributed to the nature and type of STS operation, as well as the experience of your organization and the management of information attained from past STS operations. Attention is drawn to generic risk assessments. In case your organization has adopted a generic form, this should be revised at each STS Operation, depending on its nature and involved elements.2 60.02. When is risk at its highest with respect to a wave’s force and direction, during an STS operation? The highest risk during the commencement of an STS operation, with respect to a wave’s direction is when the wave moves from a beam direction. The optimum wave direction to control the mooring loads is when the waves meet the vessels on the port bow, with the STBL (Ship to be lightered) to windward. Higher weather thresholds or mooring loads can be more tolerable when the STBL is at or close to fully loaded displacement. 60.03. Is there an assessment in place with respect to the crew experience and relevant requirements for training?

The ship owner should establish procedures to record crew experience with respect to the elements that are relative to the risk assessment. Indicatively, such elements are the number of STS operations with respect to the STS location under consideration, weather conditions, type of operation, participating vessel size and type etc. Certain standard tanker c/p also include warranties/ representations upon crew competency for STS. 60.04. Is there a required procedure to assess the rolling effect during an STS? Large Rolling angles or different roll periods are recognized as examples of causal factors at Appendix K of the latest OCIMF guidelines. Abnormal rolling angles have been identified as the primary cause of mooring lines breakdown with subsequent low energy collision of vessels. The rolling effect should be examined in conjunction with the fender type and size, vessel freeboard and swell height. Master and technical operators should consider the development of a procedure to allow for the evaluation at the risk from the rolling effect, especially at STS operations that take place while at anchor and with vessels with different rolling periods. Rolling period of a vessel depends on her displacement, breadth, draft and any stabilizer fittings.

At section 1.8 of the latest OCIMF guidelines the following is mentioned: “It is important that any additional roles and responsibilities are identified and that suitable training is provided prior to the operation. The training requirement for each ship will differ depending on the recent experience of the individuals on board.” Crew experience plays a vital role for the proper planning of a safe STS operation. It is of critical importance that the organization has a procedure in place to record the crew experience from past STS operations in order to adopt their risk assessment to each STS requirement.

2. Participating vessel type, Cargo Type, STS location, Experience of Service Provider and POAC, Weather conditions, Coastal State rules

Abnormal rolling angles have been identified as the primary cause of mooring lines breakdown with subsequent low energy collision of vessels. 49

Safe Practices and mitigation measures 61.01. During vessel approaching and manoeuvring, which safe practices are highly recommended? Prior to the operation both vessels are recommended to complete the OCIMF Ship to Ship Transfer Guide Checklist number 3. If either of the Masters of the ships or the STS Superintendent has the slightest doubt about the safety of the maneuvre, the berthing operation should be aborted. At all times each ship is responsible for maintaining a proper lookout. During the planning phase, when the JPO (Joint plan of Operations) is agreed by the POAC and both masters, careful examination of weather forecast, sea state and wind conditions, should take place. Generally, during maneuvering, the wind and sea are kept on the port bow of the larger constant heading ship. However, local conditions or knowledge of area may indicate an alternative approach. The angle of approach adopted by the maneuvering ship should not be excessive. A common method of berthing is for the maneuvering ship to approach the constant heading ship from the quarter on the side of berthing. On closer approach the maneuvering ship should parallel the course of the constant heading ship at a safe distance that is appropriate to the conditions, before positioning itself relative to the constant heading ship. Contact is made by the maneuvering ship reducing the distance by appropriate rudder and engine movements until the fenders touch. The two ships should preferably make parallel contact at the same speed with no astern engine movements being necessary. Attention is drawn to the fender selection by the Service provider and subsequent confirmation by the Master, since the parallel contact exerts higher energy on fenders as noted at ANNEX I of the latest OCIMF guidelines. No engine movement on the constant heading ship should be made without prior advice of the POAC or Master of the maneuvering ship.

61.02. What should be done in order to eliminate the potential for incendive arcing between two ships when presenting the hose string for connection? In order to eliminate the potential for incendive arcing, a single insulating flange should be fitted within each hose string or at one ship’s manifold. Furthermore, one length of electrically discontinuous hose should be fitted in each hose string. Also, hoses should be used that are specially constructed to prevent static build-up or electrical currents transferring between ships. 61.03. In which areas of the ship should extra care be considered in order to avoid low resistance Ship to Ship electrical contact? The areas of the ship where extra care should be considered in order to avoid low resistance Ship to Ship electrical contact include the non-insulated metallic ladders or gangways between the ships, derrick or crane wire runners and hooks and unprotected bare wires and chains within fender support nets or cages. 61.04. What actions are to be considered by the Master during an emergency situation? The actions that art to be considered by the Master during an emergency situation include the following: –– Abort the transfer –– Sound the emergency signal –– Inform crews on both ships of the nature of the emergency –– Man emergency stations –– Implement emergency procedures –– Drain and disconnect cargo hoses –– Send mooring gangs to stations –– Confirm the ship’s main engine is ready for immediate use –– Advise standby boat of the situation and any requirements

61.05. What kind of arrangements should be made on both ships during the state of readiness for an emergency? During the state of readiness for an emergency the main engines and steering gear shall always be ready for immediate use. Cargo pumps and all other equipment, relevant to the transfer, need to be tested. The crew has to be readily available and all systems have to be prepared to drain and disconnect hoses at a moment’s notice. Oil spill containment equipment has to be prepared and ready for use. Mooring equipment also has to be ready for immediate use and extra mooring lines must be available at mooring stations as replacements in case of breakage. Finally, fire-fighting equipment must be ready for immediate use. 61.06. Under which conditions should an STS operation be suspended? The conditions under which an STS operation should be suspended include:

61.07. In which circumstances should night STS Mooring operations be aborted/ postponed? Night mooring and un-mooring STS operations should fulfil the minimum industry guidelines and STS plan requirements. In case the technical Operator has restricted night mooring operations, this should be evident to the STS plan as a policy. If night-time berthing and un-berthing operations are expected a Risk Assessment must be prepared by the vessel’s team. Should manager’s policy require reviewing the risk assessment, then this should be transmitted to the relevant department with the request for review and approval of such night time mooring and un-mooring operations. In case night berthing operation is planned, this should be prior agreed with the POAC and service provider. Confirmation of relevant POAC experience should be ascertained by the Master.

–– If electrical storms are present

Portable spotlights, which should be flameproof, and bridge wing spotlights are useful for night mooring and unmooring operations.

–– When the movement of the oil tankers alongside reaches the maximum permissible and there is a high risk of excessive tension on hoses

If the transfer is to take place at night, check availability of search lights and flood lights, as this is also included in the risk assessment for personnel transfer.

–– Under adverse weather and sea conditions

61.08. What are the precautions for STS operations with same size vessels?

–– Excessive cargo vapor accumulation around the deck

–– When either tanker experiences a power failure or failure in the main communication system between the oil tankers and the standby communications are not in operation –– When there is an escape of oil or leakage from hoses, couplings or deck piping into the sea or an unexplained pressure drop in the cargo system or any other damages that could result in oil leakage

Same size (similar) vessels are with a LOA difference less than 10%. The risk assessment should include provisions in order to mitigate risk such as those outlined in the latest OCIMF guidelines.

–– If there is an overflow of oil at the deck caused by cargo tank overfilling –– Under the threat of fire –– Under a significant, unexplained difference between the quantities of cargo delivered and received

TMSA Self assessment Although there is no explicit STS assessment within the TMSA (Tanker Management Self Assessment) procedures of OCIMF, STS Operations are governed by statutory requirements under the new Regulation which indicates procedures that have to be implemented by Tanker Operators who are involved in STS operations. The quality of services offered by ships, crews and their managers depend a great deal on the level and competency of exercised due diligence prior, during and after each STS transfer. Preservation of high safety standards by Tanker Operators supports their reputation as well as the reputation of cargo owners and their charterers.

Stage 4

Stage 3

Stage 2

Stage 1

Knowledge improvement

Master support records on due diligence

Enhanced risk assessment quality assurance of 3rd parties

Rules and standards

Due Diligence in STS Operations is easy to be described, difficult to be recorded and challenging to provide proof that is being followed. Tanker Operators may develop their procedures as outlined in these guidelines. Adopted Procedures should support the necessary actions for the four phases, PLAN, ACT, MEASURE and IMPROVE. The Self-assessment for STS Operations is being implemented through policies and procedures in 4 stages. Procedures are prioritized on the basis of importance in controlling the risk exposure as well as exercising due diligence in order to establish the STS knowledge gained from the entire fleet as an â&#x20AC;&#x153;assetâ&#x20AC;? within the organization. This is the final target as shown on stage 4.

Stage 1

1.1

Key performance indicator

Best practices

Operational procedures in STS plan have been developed according to Statutory Requirements.

STS plan should include procedures for approaching, mooring, cargo operation and unmooring according to the latest SIGTTO /CDI ICS/OCIMF guidelines and Manual on oil Pollution section I chapter 6. Procedures for notification to the costal authority and past 3 years STS record keeping, according to the MEPC 86(59), should be also included to STS plan. STS plan should also mention that the selection and maintenance of STS Equipment is required to fulfill manufacturers recommendations, latest SIGTTO /CDI ICS/OCIMF guidelines and Manual on oil Pollution section I chapter 6. These requirements should be verified by the Master. STS plan, mooring arrangement and relevant required information is available to the POAC for review prior establishing the joint plan and commencement of the STS operation.

1.2

There is a policy in ascertaining POAC qualifications prior to the STS Operation.

POACâ&#x20AC;&#x2122;s should be qualified and experienced according to Manual on oil Pollution section I chapter 6.

There is a policy in ascertaining POAC qualifications prior to the STS Operation.

STS related courses and/or familiarization material are available prior to embarkation of the deck crew and/or during service.

Key performance indicator

Best practices

There Is a clearance policy for screening of nominated vessels prior providing clearance.

Ship particulars and main certificates are examined in order to ensure compatibility and safety.

2.2

There is a policy for ascertaining quality criteria for STS service providers.

As mentioned at the latest ICS/OCIMF guidelines, quality criteria of Service Providers should exist on the basis of Safety, Reliability and Efficiency. Nominated Service providersâ&#x20AC;&#x2122; details should be requested and evaluated prior to the commencement of the STS Operations.

2.3

Risk assessment dedicated for STS operations has been established and being implemented in each STS operation

Risk assessment should take place prior to each STS operation, taking into account the risks related to STS operations. Risk mitigation measures should also be prescribed according to the outcome of risk assessment.

1.3

Stage 2

2.1

Evaluation of POAC qualifications and experience, regardless on which ship he will embark, should take place prior to the commencement of the STS Operation. According to manual on oil Pollution section I chapter 6, oil tanker operators should agree and designate the POAC, who should have specific qualifications.

The parameters, thresholds and procedures incorporated in the vessel clearance policy are clearly defined.

Stage 3

3.1

Key performance indicator

Best practices

Responsible personnel are adequately trained for clearing purposes.

Qualified personnel are appointed and aware of: –– The company clearance Policy –– Due diligence issues –– Guidelines and rules –– Liability issues –– Assessment of STS operations

3.2

Each clearance request is well recorded.

All clearance requests should initiate clearance procedure, which should be well recorded. Records should be available for benchmarking and for reviewing the clearance procedure and minimum criteria.

3.3

Clearance procedure takes into account past STS records when available for the nominated vessel.

Past STS records and experience should be taken into account. External sources for past performance in STS operations of nominated vessels, if available, should also be considered.

3.4

The Master is supported with technical and risk information associated with each specific STS Operation.

Master has to take decisions on the spot in order to ensure safety. It is important to have available technical information regarding: –– Characteristics of participating vessel –– Compatibility issues –– Joint plan –– Fender selection related to the STS type and weather condition –– Hazards –– Weather conditions –– Cargo information –– Past performance of participating vessel and 3rd parties if available –– Local regulations

Stage 4

4.1

Key performance indicator

Best practices

Records of STS Operations include critical parameters of the operation and performance assessment of involved parties.

Records should include condition of both vessels, weather conditions, incident and/or near misses information. Records should also include performance assessment of participating vessel, POAC, STS equipment and support vessels. Records should be consistent and uniform. Officers should be trained to assess 3rd parties in a uniform and objective way.

4.2

4.3

Evaluation of records and lessons learned in case of an incident or near miss.

Records should be evaluated in order to contribute to the clearance procedure and improvement of all related STS policies and procedures.

Key personnel training include real examples from past operations.

Findings and lessons learned from evaluation of STS records are being distributed amongst key crew and shore personnel. Past STS record evaluations are part of the existing crew training and familiarization process.

Lessons learned should be drafted for all incidents and near misses.

Record keeping

Post processing

Record keeping is a highly important process for all operations, including STS operations. Particularly for STS operations, records are a primary source for information that supports the clearance process of future STS operations. Thus, STS records should be regularly reviewed.

Assessment of records

Record keeping on board 65.01. What records are necessary to be kept on board? (See 15.03) According to the Regulation, records should be kept on board for 3 years. Records are not explicitly specified by the rule; however, these records should include checklists, copies of certificates of fenders and hoses, statement of acts and any relevant reports prior to and after the operation. In case of incidents and near misses, lessons learned should also be available. 65.02. Should incidents and near misses be included in STS records? Incidents and near misses should always be recorded and lessons learned should be extracted. Apart from the obvious improvement of safety standards and transparency concept towards safety, this process supports also the due diligence practices of the company in future STS operations. The knowledge gained from incident and near misses investigation, highly support the definition of the STS policies of the company and consequently the screening process of future nomination of participating vessels.

66.01. Is the assessment of STS records necessary? YES, the assessment of STS records is necessary. Since the STS plan is part of the SMS system, then the assessment of the STS records is mandatory as a prerequisite procedure for the RISK ASSESSMENT that has to be developed according to SOLAS requirements. Furthermore, the assessment of STS records is commercially recommended as per TMSA practices, in order to extract key performance indicators and associated goals. 66.02. Do technical operators have a procedure in place to collect past STS experience from their fleet, incident and near miss management for training purposes for senior deck officers? At Appendix K.2 of the latest OCIMF guidelines, a large number of examples of causal factors are associated with the assessment and management of information from past STS operations. Such causal factors are the following: –– Inadequate fendering –– Inadequate watch keeping –– Inadequate training –– Inadequate procedures –– Inadequate experience –– Failure to follow procedures –– Inadequate site selection –– Inadequate tug/ support vessel –– Inadequate operational planning and control –– Inadequate equipment inspection, testing and maintenance –– Equipment not fit for purpose –– Equipment unapproved/not fit for purpose –– Inadequate contingency planning –– Inadequate incident management –– Technical operators should have a management system in place which would allow for the dissemination of experience/ knowledge from past STS operations to the entire fleet. Furthermore such knowledge would establish the STS experience, as an asset of the organization

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