Transport Canada shared guidance on how to comply with domestic regulations for transporting oil, fuels, and oil or fuel by-products, such as waste oil. The guidance is intended for authorized representatives, owners and operators, masters and crew of oil tankers and vessels carrying oil and fuels in tanks on deck (including cargo barges), and suppliers and receivers of oil and fuels.
What you need to know
-Transportation of oil in bulk
- Transportation of oil in bulk includes its loading, carriage and unloading. In other words, bulk oil is pumped into a tank located on the vessel, carried from point A to point B, then pumped off from the tank located on the vessel to somewhere ashore or another vessel (oil terminal, portable tank, barge, etc.). Since transportation of oil in bulk, categorizes the vessel when constructed or adapted primarily to carry oil in bulk in its cargo spaces or integrated tanks as an oil tanker or an oil barge; and such vessels are required to comply with all the applicable regulations for oil tankers. A complete guide to the requirements can be found here.
- It is important to note that a vessel or barge used for transportation of oil in an integrated tank mounted on its deck into which bulk oil is loaded and/or from which bulk oil is unloaded while the tank remains on board, shall require compliance with applicable regulatory requirements for an oil tanker. However, since the term oil tanker has broad usage, it is recognized that some of the requirements for such regulatory compliance when transporting fuel within the coastal waters of Canada, could be different from the requirements for oil tankers on international voyages. Since the transportation of bulk oil in integrated tanks on vessels or barges can be done in many different and unique ways, Transport Canada may consider applications for alternatives or exemption from some regulatory requirements through the MTRB process. Guidance on this process can be obtained by contacting any Transport Canada Marine Safety office.
-Transportation of oil in packaged form in portable tanks
- Transportation of oil in packaged form includes the loading, carriage and unloading of a package (e.g., a portable tank filled with oil). In other words, a package, such as a portable tank filled with oil, is driven or loaded by a crane onto a vessel, carried from point A to point B, and then driven off or unloaded by a crane from the vessel.
- Approved portable tanks as per the Transportation of Dangerous Goods Regulations can be used for the transportation of packaged oil as part of the deck cargo carried on vessels or barges. However, segregation of packaged dangerous goods will be required as per the IMDG Code, in accordance with the Cargo, Fumigation and Tackle Regulations.
- Portable tanks cannot be filled or discharged when on the deck of a cargo vessel or barge, as per the IMDG Code in accordance with the Cargo, Fumigation and Tackle Regulations. The filling and emptying of portable tanks has to be done ashore.
- It is possible in some cases that either the filling or discharging of oil from portable tanks such as tanker trucks cannot be done off-barge. This could be the case when a shallow draft vessel or barge has to deliver fuel to remote communities, dredgers, aquaculture farms etc., where approach from the water is the only means of access. In such cases, TC may look into the possibility of issuing appropriate MTRB decisions to establish necessary conditions designed to ensure the safe transfer of bulk oil to or from a portable tank installed on the deck of the vessel or barge.
-Transportation of oil in integrated as well as portable tanks (hybrid model)
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Operators can, for commercial reasons, elect to adopt a dual-mode of carriage, whereby oil is simultaneously transported in both integrated tanks as bulk cargo, as well as in portable tanks as packaged dangerous goods. In such cases, the conditions cited under both the above subject headings will apply.
-Some additional cautions and requirements
- Barges transporting bulk oil in integrated tanks are considered oil barges and are required to comply with the regulations, inspections and certification requirements that apply to oil tankers.
- Barges carrying oil in packaged form in portable tanks are cargo barges and are currently not required to be inspected or certified. However, they are required to comply with the Transportation of Dangerous Goods Regulations and the Cargo, Fumigation and Tackle Regulations.
- Crew and personnel are not permitted on the deck of an oil barge or a cargo barge when in transit. Barges carrying crew are termed ‘Manned Oil or Manned Cargo Barges’ and require compliance with an additional set of regulatory requirements.
- Crew attending to any kind of oil transfer operation are required to have appropriate Supervisor of Oil Transfer Operation certification (SOTO).
- A risk analysis may be required when carrying packaged oil and other dangerous goods (such as explosives or propane) along with general cargo on a barge.
- Where it is impossible to comply with the applicable regulatory requirements due to the nature of the operation, the authorized representative may apply to Transport Canada Marine Safety for a MTRB decision under Section 28 of CSA 2001. The MTRB may grant an exemption from or a replacement of the applicable requirement if the Board is satisfied that the exemption or replacement would result in an equivalent or higher level of safety. The authorized representative remains responsible to maintain an equivalent level of safety and comply with the conditions of the MTRB decision.
-Finals conditions to achieve an equivalent level of safety, shall consider at a minimum but are not limited to the following:
- Guidance for training of crew, instead of crew carrying a SOTO CoP;
- Safety procedures in place for safe transportation and usage of oil and fuels, in a portable tank, or in an integrated tank;
- Means to ensure an adequate ventilation of the portable tank or integrated tank;
- Minimum equipment for pollution prevention (SOPEP);
- Minimum Fire safety and life-saving equipment;
- Means to ensure an Emergency towline or a safe way to evacuate the crew in case of emergency (fire, explosion etc.);
- Procedures to ensure means of safe cargo transfer; It is the responsibility of the authorized representative of the vessel to ensure compliance with regulatory requirements.
