1 The Marine Environment Protection Committee, at its
forty-ninth session (14 to 18 July 2003), recognizing the necessity to provide
appropriate guidance for the application of MARPOL Annex I requirements to floating
production, storage and offloading facilities (FPSOs) used for the offshore
production and storage of oil, and floating storage units (FSUs) used for the
offshore storage of produced oil, approved the Guidelines for application of MARPOL
Annex I requirements to FPSOs and FSUs. The Guidelines were issued as MEPC/Circ.406
on 10 November 2003.
2 The Committee,
recognizing that similar guidelines would be needed for the revised MARPOL Annex I,
agreed to their adaptation to the new layout and numbering system of the revised
MARPOL Annex I. Thus these Guidelines are intended to replace the Guidelines issued
as MEPC/Circ.406 and it is recommended that contracting Governments give effect to
their provisions as soon as the revised MARPOL Annex I enters into force.
3 The purpose of these Guidelines is to
provide for uniform application of the revised MARPOL Annex I adopted by resolution
MEPC117(52) to Floating Production, Storage and Offloading facilities (FPSOs) and
Floating Storage Units (FSUs) that are used for the offshore production and storage
or for offshore storage of produced oil.
4 The Marine Environment Protection Committee, at its forty-ninth session
(14 to 18 July 2003), noted the complex issues involved in applying the requirements
of MARPOL Annex I to FPSOs and FSUs, whose arrangements, functions and operations
fall under the over-riding control of coastal States.
5 In addition, the Committee found that the role of FPSOs and
FSUs in operation does not include transport of oil. Accordingly, FPSOs and FSUs are
a form of floating platform and do not lie within the definition of oil tanker in
regulation 1.5 of the revised MARPOL Annex I. They are therefore subject to the
provisions of the revised Annex I that relate to fixed and floating platforms,
including regulation 39.
6 The Committee
noted that the environmental hazards associated with the quantities of produced oil
stored on board operational FPSOs and FSUs are similar to some of the hazards
related to oil tankers and that relevant requirements of the revised MARPOL Annex I
in relation to oil tankers could be adapted to address those hazards in an
appropriate manner. Based on the above and recognizing that these floating platforms
are stationary when operating, the Committee recommends that coastal States, flag
States and others associated with the design, construction and operation of FPSOs
and FSUs apply the relevant revised MARPOL Annex I regulations referred to in annex
1 to the Guidelines. References contained in annex 1 relate to the revised MARPOL
Annex I up to and including the amendments contained in resolution MEPC.117(52).
7 These guidelines have been prepared with
a view to providing the necessary guidance and interpretation information which may
be specifically applicable to FPSOs and FSUs, and accordingly represents a single
document describing the application of the revised MARPOL Annex I to these floating
platforms.
8 The provisions of these
Guidelines are for application to FPSOs and FSUs when located at their operating
station. However they also take into account the abnormal and rare circumstances of:
.1 voyages for drydocking, repair or maintenance work; or
.2 disconnection of the platform in extreme
environmental or emergency conditions. In either case, the FPSO/FSU should not
transport oil to a port or terminal except with the specific agreement of the flag
and relevant coastal States, obtained on a voyage basis. When undertaking any voyage
away from the operating station, for whatever purpose, FPSOs and FSUs will be
required to comply with the discharge provisions of the revised MARPOL Annex I for
oil tankers.
9 In order to avoid
development of an entire new text from the revised MARPOL Annex I attending to such
terminology matters and notwithstanding the basis for these Guidelines outlined
above, in any regulation indicated to apply to FPSOs and FSUs by the Guidelines at
annex, the following interpretation of terminology should be used:
.1
”oil tanker” should be read as ”FPSO or FSU”;
.2 ”carry” should be read as ”hold”;
.3 ”cargo” should be read as ”produced oil and oily mixtures”; and
.4 ”voyage” should be read to include
”operations”. 10 Oil tanker requirements that are extended by the Guidelines
to apply to FPSOs/FSUs are identified through the phrase ”recommend application” or
similar, while ”applies” is used for requirements to be implemented irrespective of
the contents of this circular.
11 The
requirement for oil tankers to undergo the enhanced survey programme (resolution
A.744(18)) was deleted from regulation 13G of MARPOL Annex I by resolution
MEPC.95(46) and its provisions have subsequently been solely given effect through
chapter XI-I of SOLAS. Since SOLAS does not apply to the vast majority of FPSOs and
FSUs, which are permanently moored at their operating stations, the relevant oil
tanker requirements of resolution A.744(18) have been included as one of the
provisions of the Guidelines in order to ensure a satisfactory standard of
structural integrity for FPSOs and FSUs. Reflecting the operational characteristics
of FPSOs and FSUs, the Guidelines also make provision for limited departure from
A.744(18) in respect of acceptance of in-water surveys under conditions which do not
compromise safety and pollution prevention.
12 In implementing the provisions of these Guidelines, Member Governments
are invited to use and recognize the Record of Construction and Equipment for FPSOs
and FSUs at annex 2 in place of Forms A and B appended to the revised MARPOL Annex
I.
13 The Committee noted that most
operations of FPSOs and FSUs are different from other ships covered by Annex I and,
recognizing that the coastal State has jurisdiction over fixed and floating
platforms operating in waters under its jurisdiction, Member Governments may find it
necessary to depart from the provisions of these Guidelines. Accordingly, the
Committee invites Member Governments to advise the Organization of their experience
in applying these Guidelines so that it can be taken into account if future
amendments to these Guidelines are deemed necessary.