(www.MaritimeCyprus.com) OCIMF recently published the new VIQ-7 questionnaire which will be in effect from 17 September 2018 onward. With respect to Ship to Ship transfer Operations a radical update took place, incorporating requirements of MARPOL as well as best practice processes referring to record keeping, beyond to the checklists used until now. The new requirements (Section 8.54 of new VIQ) need from SIRE inspectors to review the following records:
- STS Checklists as per latest ICS/OCIMF/SIGTTO/CDI guidelines edition 2013
- The JPO (Joint Plan of operations) as provided by the service provider
- Risk assessment as submitted by the Service Provider
- Detailed Mooring Plan of participating vessels.
- Copies of certificates of fender and hoses
- Notification to coastal authorities
- Details of Drills associated with the specific STS Operation
- Records of Crew Experience
- Post feedback/ assessment by the Master
Indirectly the request for availability of such records has the following purposes:
- To direct/instruct Masters to request from STS Service Providers the necessary documentation prior to an STS operation, in line with ICS/OCIMF/SIGTTO/CDI guidelines edition 2013, rather than relying on the willingness or promptness of the STS Service providers to provide same and
- To drive tanker operators towards a self regulatory framework for Ship to Ship transfers.
To our understanding, records are being maintained in order to have them post assessed for lessons learned and extract of best practices that may apply in future STS operations. Therefore, behind the necessity of record keeping a lesson for integrated and efficient "safety culture" is being conveyed, which adds on to the necessary due diligence actions. This makes sense from an operational perspective, since all STS operations require "proper and detailed planning" on the basis of objective evidence, such as the past STS records which can be verified.
"Objective evidence" as per IMO definition, [IMO A.788(19)] refers to quantitative or qualitative information, records or statements of fact pertaining to safety or to the existence and implementation of a SMS element, which is based on observation, measurement or test and which can be verified.
We believe that the collection/ assessment of STS records, in the way proposed by OCIMF at the new VIQ, should consist of a standardised process under company's SMS. Such process should be transparent, documented, verifiable and above all easy to be maintained with minimum burden. Otherwise the STS records can not be considered as objective evidence and cannot be utilised in a form that allows to the tanker operator to extract beneficial results.
The new requirements of VIQ will be applicable to vessels that undergo vetting inspections that are logged into SIRE. This provides a level of assurance that such vessels will comply.
What happens with vessels that do not pass SIRE inspections when their trading pattern does not require it? How can a tanker operator be assured that a nominated vessel without a recent SIRE inspection, has its STS records according to industry best practices?
Recent Statistics (2017) from OSIS database© of DYNAMARINe onlineSTS.net service, conveys some useful findings regarding such vessels. For this purpose the following two pie graphs are presented below:
According to the graph of figure 1, the percentage of incidents for vessels with recent vetting inspection is roughly 2%. On the other hand, this figure increases considerably for operations where the participating vessel had no vetting inspection or the date of last inspection was greater than 6 months, as shown at figure 2. More specifically, according to OSIS© database, 10% of the STS operations with such vessels ended up with a minor or major incident.
It is evident from the statistical data, that vessels without a recent SIRE inspection, pose higher percentages in being engaged in an STS incident, either minor or major.
The existence of a recent SIRE inspection is not a prerequisite for accepting a nominated vessel for an STS operation. Its absence though, triggers various concerns with respect to the absence of positive evidence. Tanker operators with a safety culture and transparent STS policies need to ensure safety, by all means. Although this is contrary to the commercial, tanker operators should not delegate their responsibility towards ensuring safety to third parties and they have the right to request and scrutinise all necessary information for nominated vessels, that will enable them in doing so. There are means in place to access records of positive evidence some of which is inline with the recent developments in the new VIQ introduced by OCIMF. Charterers, on the other hand, should co-operate and make timely available, all requested information by tanker operators, while they assess a nominated vessel, STS service provider or STS location.
We believe that the industry moves towards a self regulation scheme on Ship to Ship transfer operations, which will allow prudent Tanker Operators to gain total control over safety aspects.
This makes sense from an operational perspective, since there is no direct contract between the involved parties. The only common prerequisite is that the STS operation should take place with requirements not less than those included in the relevant OCIMF STS guidelines along with the fact that the Master is always responsible and should ensure that his responsibility is not compromised by actions of others.
The new VIQ in sections 8.51-8.55 includes various requirements for STS operations. Such requirements are not new for onlineSTS.net client tanker operators since relevant processes have been incorporated in their "detailed planning" ever since their enrolment. DYNAMARINe put forward such processes ever since the ratification of MARPOL chapter 8 of Annex 1. The processes required by OCIMF through the new VIQ is just an interpretation of MARPOL along with best practices that are justified through the retention of records for 3 years as well as KPI's for the TMSA.