The Indian Directorate General of Shipping (DGS) issued a circular providing clarification on the carriage of fuel oil as cargo by offshore supply vessels (OSVs).
The Directorate had issued Engineering Circular No.4 of 2013 on the applicability of Regulation 2.2, Annex I of MARPOL Convention to Offshore Supply Vessels (OSVs) engaged in carriage of fuel oil as cargo. The circular was an attempt at streamlining the procedures and aimed at avoiding misinterpretation by the stake holders. However, since issuance of the aforesaid circular, the Directorate has received requests from the Ship-owners, Recognised Organisations (ROs), seeking further clarification on the applicability of Regulation 26.4, Annex I of MARPOL Convention and also for providing clarification on the use of fuel oil from the cargo tank for the OSVs own use as ships bunker.
A. As per Regulation 26.4 of Annex I of MARPOL Convention, length of a cargo tank should not exceed 10 m or the values derived as per Regulation 26.4.1, 26.4.2 and 26.4.3, whichever is the greater. It has been brought to the Directorate’s notice, that many of the existing Offshore Supply/Support Vessels have cargo oil tanks for carriage of fuel oil, whose length exceed the length permitted in the above stated regulations, and therefore these tanks cannot be designated as cargo tanks, whereas they can be used as fuel oil bunker tanks on such OSVs.
Taking into consideration, that one of the activity of these vessels, is to supply fuel oil to the offshore installation and on receipt of recommendations from the Recognized Organizations and clarification with respect to non-feasibility for alteration of these tanks to meet the requirement of Regulation 26.4 on the existing OSVs, the Directorate issues the following guidelines to be followed for survey and issuance of International Oil Pollution Prevention (IOPP) Certificate. This arrangement, however, is only applicable for OSVs delivered before 1 August 2010 :
- The aggregate cargo carrying capacity of any such vessel shall not exceed 1000m3 .
- The limitation in the size of the cargo tank, as required by Regulation 26.4, shall be complied by limiting the actual volume of the cargo carried in such tanks to a value proportionate; so as, not to exceed the volume determined by the calculation stated in Regulation 26.4, Annex I of MARPOL.
- The Stability Booklet, Cargo Plan and the IOPP Form ‘B’ shall mention the corrected volume of the Cargo tank and the same need to be suitably approved by the RO. The compliance with this requirement shall be evidenced by the Oil Record Book entries and all such documents of declaration of the vessels cargo carrying capacity.
B. The Directorate has also been requested to clarify, on the permissibility of using the fuel oil from the cargo tank for the OSVs own use as ships bunker. Taking into consideration that the OSV may be away from the base for extended period, the Directorate has ‘no objection’ to the transfer of fuel oil from the cargo tank to the OSVs bunker tank, provided the transfer is documented in the Oil Record Book, as per requirement; and other obligation for Oil pollution prevention, and conforming to the standards in terms of the fuel oil quality, as per Regulation 18, Annex VI of MARPOL are complied with.
The Recognised Organisation undertaking the International Oil Pollution Prevention (IOPP) surveys shall verify the compliance of the above, in addition to that mentioned in the Engineering Circular 4 of 2013. The non-compliance of the above requirements may warrant suitable intervention from the Flag State or Port State, including the detention of the concerned ship.
You may view the circular by clicking below:
Source: Indian Directorate General of Shipping
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