Date: 2015-05-21Category: DGS CircularState: Union GovernmentCountry: India
Corrigendum 1 to Engineering Circular No. 4 of 2013 - Carriage of oil as cargo in offshore Supply / Support Vessels (OSV) and applicability of the provisions of MARPOL Annex I -reg.
**Executive Summary**
This document is Corrigendum 1 to Engineering Circular No. 4 of 2013, issued by the Directorate General of Shipping, India, dated May 21st, 2015. It clarifies the applicability of MARPOL Annex I provisions regarding the carriage of oil as cargo in Offshore Supply Vessels (OSVs). The corrigendum addresses the use of cargo tanks for fuel oil and provides guidelines for survey and issuance of International Oil Pollution Prevention (IOPP) Certificates for OSVs delivered before August 1, 2010.
**Key Points / Main Content**
* **Regulation 26.4 Clarification:**
* Addresses length limitations of cargo tanks as per MARPOL Annex I.
* Acknowledges existing OSVs may have cargo oil tanks exceeding permitted length.
* Allows these tanks to be used as fuel oil bunker tanks.
* **Guidelines for Survey and IOPP Certificate (OSVs delivered before August 1, 2010):**
* The aggregate cargo carrying capacity of the vessel should not exceed 1000m³.
* Cargo tank size limitations are to be met by limiting actual cargo volume to a value proportionate to the volume calculation stated in Regulation 26.4.
* The Stability Booklet, Cargo Plan, and IOPP Form ‘B' must reflect corrected cargo tank volume and be approved by the Recognised Organization (RO).
* Compliance must be evidenced by Oil Record Book entries and cargo carrying capacity documents.
* **Use of Cargo Tank for OSV's Own Use as Bunker:**
* Directorate has no objection to transferring fuel oil from cargo tanks to OSV bunker tanks.
* Transfer must be documented in the Oil Record Book.
* Obligations for oil pollution prevention and fuel oil quality standards (Regulation 18, Annex VI of MARPOL) must be met.
* **RO Verification:**
* Recognised Organizations (ROs) undertaking IOPP surveys must verify compliance with these guidelines in addition to the requirements in Engineering Circular 4 of 2013.
* **Non-compliance:**
* May warrant intervention from the Flag State or Port State, including detention of the ship.
**Impact Analysis**
**Ship-owners/Shipping Companies:**
* **Impact:** Need to comply with revised guidelines on cargo carrying capacity, cargo tank volume, and fuel oil transfer procedures.
* **Action Required:** Implement necessary changes to cargo operations, documentation (Oil Record Book, Stability Booklet, Cargo Plan, IOPP Form ‘B’), and ensure compliance during IOPP surveys.
**Recognised Organizations (ROs):**
* **Impact:** Must incorporate these guidelines into their survey procedures for IOPP certification of OSVs.
* **Action Required:** Update survey checklists to include verification of compliance with the specified cargo carrying capacity, cargo tank volume limitations, fuel oil transfer procedures, and documentation.
**Mercantile Marine Departments/Surveyors:**
* **Impact:** Need to enforce the new guidelines during inspections and surveys.
* **Action Required:** Ensure compliance with the new guidelines when surveying OSVs and issuing IOPP certificates.
Key Entities Referenced
MARPOL Annex I: International Convention for the Prevention of Pollution from Ships, Annex I, concerning oil pollution.
Offshore Supply / Support Vessels (OSV): Vessels used for offshore supply and support, specifically concerning carriage of oil as cargo.
Directorate General of Shipping: The issuing authority of the circular.
Engineering Circular No. 4 of 2013: Original circular being amended by this corrigendum, related to OSV and MARPOL applicability.
भारत सरकार / GOVERNMENT OF INDIA
पोत पररवहन मंत्रालय
/
MINISTRY OF SHIPPING
नौवहन महाननदेशालय
/
DIRECTORATE GENERAL OF SHIPPING
टेलीफोन: 91-22-25752040 “बिटा बिल्डगं ”, 9 वी मंलिल / “BETA BUILDING”, 9th FLOOR Tele: 91-22-25752040
फैक स्: 25752035 / 29 आय-थ कं टेक ् नो कॅम प् स / I-THINK TECHO CAMPUS Fax: 25752035 / 29
ई-मेल: dgship-dgs@nic.in कांिुर ग वं रोड / KANJUR VILLAGE ROAD E-mail: dgship-dgs@nic.in
कांिुर माग गरेल व् े स् ट ेशन के पास
/
NEAR KANJUR MARG RAILWAY STATION
कािं ुर माग ग(ईस ट् ) / KANJUR MARG (EAST)
वेि: www.dgshipping.gov.in मुंिई - 400 042 / MUMBAI – 400 042 Web: www.dgshipping.gov.in
Corrigendum 1 to Engineering Circular No. 4 of 2013
NO: ENG/RSC/1400 Dated: 21st May, 2015
Subject: Carriage of oil as cargo in offshore Supply / Support Vessels (OSV) and
applicability of the provisions of MARPOL Annex I -reg.
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 :
(1) The aggregate cargo carrying capacity of any such vessel shall not exceed 1000m3.
(2) 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.
Corrigendum1 to Engineering Circular No.4 of 2013 Page 1(3) 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.
This is issued with the approval of the competent authority and comes into effect from the date of
issue of this circular.
sd/-
(Praveen Nair)
Engineer & Ship surveyor cum Dy. DG (Tech.)
To,
1. The Principal Officers/ Mercantile Marine Department, Mumbai/ Kolkata/ Chennai/ Kandla/
Cochin.
2. The Surveyor-in-charge, Mercantile Marine Department, Goa/ Jamnagar/ Port Blair/
Visakhapatanam/ Tuticorin/ Delhi/ Haldia/ Paradip/ Mangalore.
3. All Recognised Organizations.
4. Indian National Shipowners’ Association (INSA), Mumbai
5. All Shipping Companies
6. CS/ NA/ CSS/ Jt.DG
7. Hindi Cell
8. Guard file
9. Computer Cell.
Corrigendum1 to Engineering Circular No.4 of 2013 Page 2