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 MEPC.117(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.