A Methodology for Due Diligence Assessment and Implementation in STS Operations

A Methodology for Due Diligence Assessment and Implementation in Ship to Ship (STS) Oil and Products Operations Stelios G. Perissakis 1), Alexandros J. Glykas 2) 2)

1) National Technical University of Athens, Greece, stelios@central.ntua.gr University of the Aegean, Department of Shipping Trade and Transport, Greece, aglykas@aegean.gr

tankers, is also an STS operation. In general, this practice began in the 60s with the introduction of lightering operations, when the dimensions and particularly the draft of the new, large tanker vessels, the so called super tankers, did not allow them to approach ports in fully laden condition. Nowadays, however, the practice is more often required because of optimization needs of the transshipment and distribution of oil cargo and associated products.

In general, the involved parties of an STS operation are the following:  The two ships and their masters,

Abstract In order for the international community to control and reduce the risk of a serious failure and their consequences regarding human safety and environment, both shippers and ship owners are nowadays forced to exhibit due diligence in all STS operations. In this article, the authors propose a method, which take into account former experience from similar operations and related events, to partially substitute a problematic information flow. A detailed analysis of the required steps is presented, including an integrated credibility assessment of STS operators, which ensure the demonstration of due diligence. The proposed method, developed by the authors, utilizes a digital information management system, which records past event experience accordingly, used supplementary to regulations, directives and guidelines in general of international recognized organizations. As long as the operation incorporates a variety of geographical locations (decision centre location, ships companies locations, STS operation location), the fact that the proposed information system can be accessed from all over the world through internet, is an important advantage. Additionally, the proposed implementation can be easily incorporated into a quality system.

   

The ships owners, The charterers,

The cargo owners and The STS operator company, which normally include the mooring master and the necessary equipment (i.e. fenders, hoses, etc.). Sometimes mooring master agreed to be one of the ship’s captains.

The mooring master assists the approach and mooring of the two ships, using the equipment provided by the STS operator company. The final responsibility is taken by the masters, as always, but all the parties must do their best for the safety of life and environment.

STS of oil or natural gas, is a high-risk undertaking and includes risks with large-scale financial and ecological consequences. This stems mainly from the nature of oil and gas, but also from the fact that the involved ships are exposed to weather conditions with limited maneuverability. Thus, for the safe conduct of STS operations a number of precautions are taken, including the careful selection of the sea area, where STS will take place and the continuous observation of the weather conditions (ICS / OCIMF, 2005; ICS / OCIMF, 1995). Furthermore, other involved parameters, such as the required specialized equipment, the compatibility of participating ships, and the experience of the crew and mooring Master are also decisive factors. The management of this set of parameters, as well as bear the responsibility of proceeding to an STS operation is a critical task.

Keywords STS transfer operations; Due diligence; STS operators; Liquid cargo transshipments; Liquid Cargo Traders; OCIMF

Nomenclature Optional, but do not use unless it is absolutely necessary. If used, place in alphabetical order, followed by any Greek symbols.

1. Introduction The transshipment of oil or gas between seagoing tankers (Ship To Ship transfer, STS) is a common practice.

The lightering process, which takes place when large tankers discharge their load into smaller, more flexible

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account local peculiarities. Based on those studies Administrations develop and adopt local rules governing the STS operations.

As for other STS regions and international waters, statutory regulations addressed towards STS operations are limited. Nevertheless, the responsibilities that arise from a serious accident during an STS operation are clearly defined by international treaties. The international community ensures that the consequences of such accidents will be intolerable and will be allocated to all involved parties. Indeed, the policy followed in order to avoid such accidents, does not establish or impose concrete measures regarding the procedures and equipment, but strengthens the existing guidelines by the requirement for each participating party or company, to ensure as far as possible, the safety and reliability of the whole STS operation. And even more, it is of vital importance for each party to be able to demonstrate that such practice has been standardized and records for this are available. This process is known by the term "due diligence".

Among a big number of references, Nollkaemper (1991) and Viladrich-Grau (2003) analyze this concept in the marine business.

The introduction of the concept of due diligence leads to two significant achievements:  The prevention of excessively stringent regulations and  The prevention of the transfer of responsibility to third parties Nowadays, technology is evolving at a remarkably intensive rate. The emergence of newer, safer, more economic and more ecological technologies is continuous.

However, implications arise, when the regulations try to validate and then incorporate the new technology: If regulations are too flexible, new technologies, without adequate validation, can be easily implemented, with questionable consequences. On the contrary, stringent regulations can discourage the implementation of better technologies. Due diligence manages a good compromise, by strengthening the relation of the regulations to their true goal, which is the protection of human life and environment, and separating them from the means of achieving this goal.

In addition, the application of due diligence in a consistent way, ensures that all participating parties recognize that they all equally bear the responsibility for the operation. No participating party can solely rely on its own fulfillment of a set of regulations. No participating party can abolish completely the responsibility of a safe operation. In this way the concept of due diligence is a clear step towards the reduction of accidents and their effects on humans and environment.

Furthermore, apart from the regulations, there is an additional reason to demonstrate due diligence. The liability and the sustained damages of an accident will not only be limited to the management of the specific operation, but will also affect the reputation of all the involved parties (i.e. vessel owners, charterers, cargo owners), while company’s reputation is not only essential but necessary. Without good reputation, future de-

2. From the Responsibility of the Involved Parties to the “Due Diligence” Concept So far, there have been no recorded serious accidents during STS operations. Indeed, Maritime and Coastguard Agency of UK mentions inter alia in (MCA, 2008): “Domestically, these transfer operations have a very good record, both in respect of safety and in respect of the environment”. Thus, international organizations have not been forced to adopt and monitor specific regulations for the special case of oil (or products) transshipment. However, this should not be interpreted as weakness of the regulatory board, since the STS operations are currently adequately covered under the general regulations SOLAS and MARPOL. On the contrary, international organizations are on the alert (ICS / OCIMF / IAPH, 2008; IMO MEPC, 2009), and from time to time they issue formal instructions and guidelines for the safe conduct of oil (or products) transshipments. Particularly, these instructions were drawn up by the ICS (International Chamber of Shipping) in cooperation with the OCIMF (Oil Companies International Forum) and they are always on the list of on board library books of tanker vessels (ICS / OCIMF, 2005; ICS / OCIMF, 1995; ICS / OCIMF / IAPH, 2008).

In the last fifteen years, and as a consequence of the accidents of both the Erika and the Prestige, various local authorities; for example in UK (Dorset Coast Forum, 2004; MCA, 2008) have started to implement in their areas of responsibility strict regulations for the transshipment process, while in several areas, STS operations have been completely banned. Despite the lack of serious accidents, this reaction is not unwarranted, since it is an undisputed fact that transshipment of oil or gas is a complex operation that involves a potential risk of large-scale environmental disaster.

The basic logic behind local administration regulations follows the general modern mentality that has prevailed when coping with major environmental disasters. Without doubt, there are some specific prohibitions, arising from the peculiarities of the geographical areas in conjunction with the weather and other conditions. However, the adopted regulations all the same are not limited to those measures. They demand additional vigilance for successful mitigation of the consequences of any possible environmental accident, and claim to be ensured in every single case that all the necessary equipment and specialized support are timely available. This requirement is known by the term "Emergency Contingency Plan" or ECP. Most of the local administration authorities of those regions have carried out a detailed risk assessment study. (i.e. Queensland Transport / Great Barrier Reef Marine Park Authority, 2000) Those studies seek for all possible cases of accidents that may lead to pollution (oil spills) and in each case, both, the probability of occurrence and the extent of the impending disaster are estimated. Then, as environmental and economic impacts are assessed an ECP plan is developed (i.e. Australian Maritime Safety Authority, 2005), taking into

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velopment and participation to further commercial agreements is difficult or not possible at all, especially with governmental parties. Additionally, the increased cost of insurance agreements should also not be neglected. Thus nowadays, the reputation of a company, is quantified and accordingly managed and evaluated (Reputation Risk Management).

supervising questionable third parties. The application of strict and rigid safety standards results in stringent rules, which lead to forced cancellation or delay of several STS operations, with significant operational and financial costs. However, experience has shown that many of these operations could have been safely executed. Either a not fully prescribed, but relatively safe procedure exists, or the unacceptable risk is raised simply from lack of information rather than of “risky situations”. Those cases, which in some geographic areas are very common, could be coped with success without increasing the real risk whilst providing a supporting flexible way of decision making.

The Achilles heel in this approach is the flow and quality of information, as this remains a fundamental factor for making prudent decisions. And the fact is that, the flow of information is not always sufficient. A very common case, for example, is that certified and accredited means of various types and available alternatives are limited.

A technique to overcome this problem and keep the minimum required flow of information to the lowest level is to support the fair information flow by taking into account prior experience in previous operations.

The use of the experience as a serious indication in case of lack of information is a common and acceptable practice, implemented in many cases. In existing STS guidelines (ICS / OCIMF, 2005; ICS / OCIMF, 1995), the crew prerequisite “good seaman’s practice” is another phrase for “prior experience”.

However, the definition and evaluation of the “prior experience” is not obvious. Usually the experience is accumulated in the mind of particular people, who have participated in the STS operations many times (personnel knowledge). In order to accumulate the experience inside the system itself, rather than the people from which the system consists, certain procedures should be recorded on a database. Especially, when this system is complicated and also operates with an adopted quality system, this mapping of the accumulated experience should be incorporated into the general bureaucracy of the quality system.

3. Implementation of the Due Diligence The implementation of the concept of due diligence, in order to be included in the decision-making of a company is not a straight forward procedure. It requires modifications of the prevailing mentality and procedural logistics. If the decision-making process is not properly adapted, the luck of a clear “to do list” of the regulations will definitely leads to enormous rise in the costs and, most importantly, in the calculated enterprising risk.

Normally, in order for a decision to be taken, all alternatives should be reviewed, and a complete risk assessment should be planned. However, a complete risk assessment in the case of an STS operation requires a complete historical record of local environmental data as well as critical data of past STS events. Thus the burden of preparing risk assessments and consequent contingency plans falls to those who have access to that data, which are mainly local authorities and sometimes small size local companies that undertake the organization of STS operations. It is unrealistic to expect from a worldwide player, such as a charterer, a ship owner, or a cargo owner, to collect and analyze the required data for every STS he wish to perform.

In fact, the demonstration of due diligence does not require a risk assessment to be implemented at each individual case. It would be reasonable for example to perform risk assessment for tasks assigned to partners/affiliate companies; however it would be less time consuming and more essential to assess the credibility of those partners. In such a way, the successful and prudent integration of the due diligence concept in the decision making, would not increase the financial cost of the operation, while it would certainly reduce the risk (for the environment and the success of the operation).

The credibility evaluation of a partner/affiliate company is mainly based on a critical assessment of their procedures and policies. Thus, in order to audit an STS operator, a sufficient quantity and quality of information about the operator and their policies is a required prerequisite. A good knowledge of STS Operation, in order to be able to assess the available information and the overall safety is also necessary. Furthermore, the audit process should be performed bearing in mind that liability does not completely accompany tasks which have been assigned to third parties.

In operations such as STS, the suggested process of credibility evaluation provides further advantage, in addition to the requirement of due diligence. Because of the complexity of the STS operation, difficulties associated with uncertain parameters such as weather conditions or availability of technical resources are effectively encountered by trusted credible specialist rather than

4. Evaluation of the Organizers of STS Operations (STS Operators) A ship to ship transfer operation consists of the following entities:  The discharging ship (Discharge Vessel), 

The ship that receives the cargo (Receiving Vessel),



The location where the STS Operation takes place (STS Location), The experienced Operator (STS Operator), and

 

The required special equipment, such as fenders and hoses, (STS Equipment).

In order to safely proceed to the transfer operation, the compatibility of all parties ought to be prior ascertained.

The compatibility compliance as well as the supply of the appropriate equipment, is usually taken over by the

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organizer of the operation (STS Operator), according to data supplied to him by the ships or the ship owners/managers. However, despite the fact that STS operator organizes and supervises the entire enterprise, ship owners, charterers and cargo owners still bear part of the responsibility of the operation. The STS operator does not undertake ultimate responsibility of the task, nor substitute due diligence of the ship owners, charterers and cargo owners. So a minimum compatibility compliance analysis is necessary to be performed by all parties.

The most difficult part of the compatibility verification, for all involved parties apart the STS operator lies with the assessment of the framework upon which the STS operation will be based. This includes the assessment of the weather condition, the STS equipment, the mooring master and the procedures that the STS operator follows. In some cases, when the discharging ship is a local tanker, without an IACS Classification, the assessment of the condition of this ship is highly questionable. Thus, in supplement to the strict compatibility check, it is crucial, that the STS operator, who has the ability to thoroughly assess this gray zone, should be audited for his ability, credibility and later performance.

Indeed, apart from some basic information about his intended way of action, another important factor is its performance in past operations. This could be named as “prior experience with this operator”.

In general it is commonly accepted that any documentary assessment is based on a specific set of data. Provided that this information is given, the adopted evaluation scheme is also important. This scheme must be sufficiently detailed to produce an objective picture, and also clear enough and easy to use, in order to assist the administration to make decisions. One way that meets these restrictions and binds well with the due diligence concept is the following suggested three-letter code scheme: All necessary data of an STS operator is divided into four categories each one representing a set of questions related to General details, safety, reliability and efficiency. In each of those categories apart from the general details set, the STS operator is assigned a letter, according to the detailed data of the questionnaire. The letter represents the following three cases: A for good, B for satisfactory and C for insufficient. The final score in this assessment is a three-letter code (i.e. ABB, BCB ...). This code is a way of quantifying the quality of the operator while enabling management to split its performance into the three aforementioned key areas.

The assignment of the letter in each category arises as the final result from a number of factors, which are evaluated respectively. The basic rule is that the final score should be the smallest of the scores of each one individual factor, rather than as an average. This kind of rule is critical, as it does not cover unsatisfactory features with fair performance in other characteristics and thus compliance with all requirements is ensured. A proposed questionnaire and its associated evaluation scheme are shown in ANNEX A.

Fig. 1:

The performance of the STS Operator grading policy should be always shown in the selection lists. Thus, the user is always aware of the general quality of the available operators. The three letter code is a handy and efficient indication methodology. (The figure is part of a screenshot of DataMax v1.0 during developing stage, thus the data shown in this figure are fictional and incomplete.)

Another advantage of this approach is that it shows to STS operators the correct way towards improvement. In order for the rating to be upgraded, the improvements should start from the most problematic characteristics rather than from the modest but satisfactory ones.

Supplementary to the three letter code, the total assessment of the STS operator must be accompanied by its performance in practice, which means its performance in previous operations. This supplementary evaluation can follow a similar “ABC” formation, as of the proposed three letter code.

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A

Three letter code Performance on the last two operations

B

Fig. 2:

A “ABC” code can also be utilized in order to rate the overall performance of the operator, after the each operation. This can be supplementary shown along with the three letter code.

(The figure is part of a screenshot of DataMax v1.0 during developing stage, thus the data shown in this figure are fictional and incomplete.)

C

5. Digital Information Management System The aim behind the development of a digital information system, that serves the implementation of due diligence on STS, is to provide all of the necessary information regarding compatibility of the vessels and credibility of the STS operators. The digital implementation through web-based applications, ensure the real time access of the information by all involved parties simultaneously with the decision makers, where everyone can be located anywhere in the world. Furthermore, such a system can efficiently integrate a policy, like the one formerly mentioned, for evaluating STS operators, which is an extremely critical point in the whole operation.

In order to have a flexible and still safe decision-making system, there should be clear policies and standards for recording and evaluating a set of data, including the prior experience, as mentioned before. It is also important to preserve a sufficient flow of information. In order to fulfill these requirements, the authors have developed a web-based application, as part of a digital information system. The use of a digital information system in this case, proved to be an excellent choice and can function with the policies such as:  For each ship involved in the STS operation, a minimum amount of information should be valid and available. This information is associated with the required certificates of ships and with key ships particulars and its associated outfit (Mooring and Manifold Arrangement). The minimum amount and type of information required will be prescribed by ship owners, cargo owners, charterers and STS operators, always taking into account the involved insurers.

Fig. 3:



The specific regulations, if any, of the coastal country, where STS operation is taking place should be examined. The contact information of the local authorities should be always available.

Fig. 4:



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Part of the STS control Panel (DataMax v1.0).

(A): Main particulars of the selected vessels for STS are shown. (B): A summary of the available data for STS. (C): Should all data are completed the background of the cell becomes green. (The figure is part of a screenshot of DataMax v1.0 during developing stage, thus the data shown in this figure are fictional and incomplete.)

Part of the STS control Panel (DataMax v1.0); details of the STS Location. (The figure is part of a screenshot of DataMax v1.0 during developing stage, thus the data shown in this figure are fictional and incomplete.)

The selection of the STS operator is critical and is perhaps the most significant decision, since he is the one who coordinates the whole operation and

also supply the necessary equipment such as fenders and hoses. Additionally, the choice of STS operator affects largely the cost of the operation, which is a main factor that concerns charterers, who usually bear the cost. Thus the decision should balance the cost without degrade the necessary safety of the operation. Safety issues, as well as credibility and efficiency are under consideration.

Additionally, the online application also allows the remote use anywhere in the world and the simultaneous access by all involved parties. The use of the database provides information beyond the needs of the STS operations to activities related to operation and chartering of ships.

The scoring system quantifies the performance of STS operators and justifies the choice of the less expensive STS operator, in combination with due diligence policy.

At same time, competition between STS operators is controlled in the right direction to increase safety and efficiency.

In response to due diligence requirements, a digital application for information management and evaluation, which improves information flow, enhanced with the experience was developed. This method enables the administrators to make objective assessments and more efficient decisions regarding the management of the STS operations of oil or products.



Finally, guidelines from International bodies should also be taken into account and, depending on the selected ships and the adopted safety policies, the minimum requirements on equipment should also calculated.

The completion of this procedure corresponds to the due diligence policy. The decision of performing an STS is based on facts and safety policies, according to the specific situation. At the same time, alternatives can be considered and in some cases of unsatisfactory safety conditions, measures can be addressed by the STS operator on the spot, instead of cancelling the process. The reliability of those measures is relative to the level of the credibility of the STS operator, already assessed.

The suggested information management system could be integrated into the company's quality system and can serve the charterer, the ship owner or the owner of the cargo to perform the due diligence. With the support of appropriate software the simultaneous use from all the involved parties is feasible. Additionally the operation history is recorded, together with comments, notes and evaluations of both the ships and the operators. Thus the experience is traced and utilized by the system.

It is also important that the system is continuously updated as the policies are modified. The system though does not make any decision itself. On the contrary it provides all the necessary information, consistent to the quality system and allows to the administration to make the decisions. In this way administration can make flexible decisions, and effectively manage situations should information is incomplete and time pressure exists. The important point is that administration has at hand and by default, all the available information in a consistent way.

Finally such a management information system is supported by a database, with the various data relating to ships and technical specifications, companies of STS Operators and STS locations. These data can be used in many other applications, or to join an existing computerized system.

4. Acknowledgements The Authors would like to thank Falcon Navigation Corporation and Trafigura Behear B.V for their support in our research with respect to this paper.

References Australian Maritime Safety Authority, (2005). "National Marine Oil Spill Contingency Plan", version 2.0 Dorset Coast Forum, (2004). "Ship to Ship Oil Transfer; An issue in Lyme Bay", Briefing note prepared for the Dorset Coast Forum ICS / OCIMF, (2005). "Ship to ship transfer guide (petroleum)", 4th edition ICS / OCIMF, (1995). "Ship to Ship transfer guide (Liquefied Gas)", 2nd edition IMO / MEPC, (2009). "Prevention of pollution during transfer of oil cargo between oil tankers at sea", Resolution MEPC.186(59) ICS / OCIMF / IAPH, (2008). "International Safety Guide for Oil Tankers and Terminals (ISGOTT)" MCA, (2008). "Impact Assessment of the Merchant Shipping (Ship-to-Ship Transfer)", Regulations 2008, version 1.3 MCA, (2008). "Consultation on draft Merchant Shipping (Ship-to-Ship Transfer)", Regulations 2008 Nollkaemper, A, (1991). "Deep sea-bed mining and the protection of the marine environment", Marine Policy Journal, January 1991 Queensland Transport / Great Barrier Reef Marine Park Authority, (2000). "Oil spill risk assessment for the coastal waters of Queensland and the Great Barrier Reef marine park" Viladrich-Grau, M, (2003). "Monitoring policies to prevent oil spills; lessons from the theoretical literature", Marine Policy Journal 27

6. Conclusions The performed analysis introduces a flexible way of implementing the due diligence, based on the assessment and management of information, taking also into account prior experience. All the operations are evaluated and recorded in the system in order to be utilized in subsequent operations. It utilizes the experience supplementary to the available information, ensuring due diligence policy. The approach can be perfectly integrated into an existing quality system.

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Contact Details

X X X X

INSURANCE

OPERATION RANGE

X

QUALITY MANAGEMENT POLICY (QM)

X X X X X

X X X ENVIRONMENTAL X PROTECTION X MANAGEMENT X POLICY (EPM) X

HEALTH AND SAFETY MANAGEMENT POLICY (HSM), DRUG AND ALCOHOL ABUSE POLICH (DAA)

STS MANUAL

EQUIPMENT

X X X X X X X X X X X

Efficiency

Reliability

Safety

ANNEX - 1 STS - OPERATOR'S GRADING POLICY

VESSELS

3RD PARTY TARIFS TRADER

A

CORPORATE NAME CERTIFICATE OF INCORPORATION MAILING ADDRESS CITY / STATE COUNTRY TELEPHONE (S) COMMENTS ON TELEPHONE (S) FAX (S) COMMENTS ON FAX (S) WEB ADDRESS COMMENTS ON WEB ADDRESS e-MAIL (S) CONTACT PERSON (S) COMMENTS ON CONTACT PERSON (S) EMERGENCY CONTACT WITH COMMENTS CERTIFICATE OF INSURANCE INSURANCE COMPANY List A INSURED VALUE x DEDUCTABLE VALUE OF INSURANCE x LIST OF STS LOCATIONS IS THERE ACREDITATION AVAILABLE FOR EACH ONE OF THE STS LOCATIONS OF THE LOCAL AUTHORITIES? Acreditations from local Authorities for each STS Location X OPERATOR IS ABLE TO ORGANIZE ANY TYPE AND SCALE OF STS OPERATIONS ?

IS A QM POLICY AVAILABLE? YES TYPE OF QM POLICY ISO 9000 family CERTIFICATE OF QM POLICY CERTIFICATION BODY OF QM POLICY Default IS CERTIFICATION BODY OF QM POLICY ACCREDITED? X DOCUMENTATION ISSUED AND FORWARDED TO OCIMF cheklist or CONTRACTORS? eqiv., Final Report IS A EPM POLICY AVAILABLE? YES TYPE OF EPM POLICY ISO 14000 family CERTIFICATE OF EPM POLICY CERTIFICATION BODY OF EPM POLICY Default IS CERTIFICATION BODY OF EPM POLICY ACCREDITED? ARE KEPT LOGS OF OIL POLLUTION DRILLS? YES ARE THERE CONTINGENCY PLANS AVAILABLE FOR EACH ONE OF THE STS LOCATIONS? CONTINGENCY PLANS for each STS Location.

ARE ALL THE REQUIRED POLLUTION PREVENTION MEANS YES IS A HSM POLICY AVAILABLE? YES TYPE OF HSM POLICY OHSAS 18000 family CERTIFICATE OF HSM POLICY CERTIFICATION BODY OF HSM POLICY Default IS CERTIFICATION BODY OF HSM POLICY ACCREDITED? IS DAA POLICY AVAILABLE? YES ARE KEPT LOGS OF PERSONNEL INJURY INCIDENTS? YES NUMBER OF SEA POLLUTION INCIDENTS INVOLVED DURING 0 THE LAST 5 YEARS COMMENTS ABOUT THE LAST 5 YEARS SEA POLLUTION INCIDENTS X X X X X X X X X

PERSONNEL

Indirect Question Filled by Trader according to Past Data Entries Filled by Traders' STS Administrator Gradeable Question QUESTIONS

X X

X X X X

IS THERE AN STS MANUAL AVAILABLE? DOES STS MANUAL FULFILL OCIMF/ICS GUIDELINES? IS THERE A FENDER SELECTION POLICY? DOES FENDER SELECTION POLICY FULFILL OCIMF/ICS GUIDELINES? STS MANUAL INCLUDING FENDER SELECTION POLICY ARE KEPT LOGS OF EQUIPMENT BREAK DOWN INCIDENTS? DOES THE STS OPERATOR HIRES EQUIPMENT AND PERSONNEL IN ORDER TO MAKE AN STS OPERATION? TEST CERTIFICATES FOR APPROVED STS EQUIPMENT CURRICULUM VITAE OF STAFF ATTENDING STS OPERATIONS INCLUDING ANY PREVIOUS EXPERIENCE MINIMUM TRAINING OF STS SUPERINTENTED IS THE OPERATOR AND STS SUPERINTENDED AWARE OF THE LOCAL ADMINISTRATION REGULATIONS FOR STS OPERATIONS? ARE OWNED LIGHTERING VESSELS? CAPACITY OF BIGER LIGHTERING VESSEL CAPACITY OF SMALLER LIGHTERING VESSEL IF ANY SERVICES ARE CONTRACTED BY 3RD PARTY (AFFILIATE, PARTNER OR SUBCONTRACTOR) COMPANY RELEVANT CERTIFICATES ARE REQUESTED WHERE APPLICABLE

X TARIFS FREQUENCY OF COOPERATION WITH TRADER ( N per Year) COST OF PAST YEAR BUSSINESS Test of emergency contact COMMENTS BY TRADER

B NO GRADE NO GRADE NO GRADE NO GRADE NO GRADE NO GRADE NO GRADE NO GRADE NO GRADE NO GRADE NO GRADE NO GRADE NO GRADE NO GRADE NO GRADE NO GRADE Default x x NO GRADE

C

Black List x x

NO GRADE NO GRADE NO GRADE not applicable ANY NO GRADE Black List NO GRADE Final Report

NO not applicable

not applicable ANY NO GRADE Black List NO GRADE not applicable

NO not applicable

not applicable none

not applicable NO

NO GRADE NO GRADE not applicable not applicable ANY NO GRADE Black List NO GRADE not applicable NO 1

NO NO not applicable not applicable NO not applicable >1

NO GRADE

YES YES YES YES

NO NO NO NO

not applicable not applicable not applicable not applicable

YES

NO GRADE NO NO GRADE

not applicable

NO GRADE NO GRADE

YES

NO GRADE not applicable

NO

NO GRADE NO GRADE NO GRADE NO GRADE

YES

NO GRADE NO GRADE NO GRADE not applicable NO GRADE

NO