Regulatory Reminder

Subject: Amendments to MARPOL Annex VI for Volatile Organic Compounds (VOC)

Ship Types: All crude oil tankers engaged in international trade

Applicability: All tank ship owners and operators

Effective Date: 1 July 2010 

Amendments to MARPOL Annex VI, adopted at IMO MEPC 58 on 10 October 2008, enter into force on 1 July 2010. Among the new mandatory requirements, Regulation 15.6 requires all crude oil tankers to carry on board and implement a ship-specific VOC (volatile organic compounds) management plan, approved by the Administration.

The VOC management plan requirement applies to every tanker carrying crude oil regardless of whether it is a new or existing vessel. The purpose of the plan is to verify that the operations of a tanker, to which Regulation 15 applies, prevent or minimize the release of VOC as much as possible during cargo loading, sea voyage and discharge of cargo. The plan is to be prepared in accordance with the guideline provisions laid out in MEPC.1/Circ.680. It should be specific to each ship and at least:

• include written procedures and description of equipment/systems employed for minimizing VOC emissions during the loading, sea carriage and discharge of crude oil cargo;
• follow best management practices for preventing or minimizing VOC emissions;
• give consideration to VOC emission during crude oil washing (COW) operation;
• monitor the extent of VOC release by a system of record keeping;
• identify a person responsible for  the VOC emissions control management; and
• identify a training program which facilitates the adoption of best management practices for the ship to control VOC emissions.

Additionally, if tanker design modifications are made (such as using the method of increased pressure relief settings for VOC emissions control), the strength aspects need to be considered and evaluated in order to verify the ship’s cargo tank integrity is not affected.

Plan approval scheme:
The owner/operator may send the service request letter to the nearest ABS engineering  office, together with a minimum of two copies of the ship-specific VOC management plan. Upon completion of review on behalf of the Administration, approved and stamped copies are distributed as follows:

• One copy to submitter (owner/operator) for placement on board the vessel
• One copy for ABS files

Alternatively:

The ship-specific VOC management plan may be submitted electronically on CD-ROM or as an email attachment to the ABS submittal database login group at the email address:O2Esubmittals@eagle.org. The approved copy of the VOC management plan, appropriately stamped, will be returned to the submitter electronically.

ABS model VOC management plan:
To assist tank ship owners and operators in complying with Regulation 15.6, ABS has made available a model VOC management plan as a reference for general use. This model plan is consistent with MEPC.1/Circ.680 and has the necessary guidance and clarifications, as well as the section templates on the contents of a VOC management plan. Areas where the ship-specific information/data will actually need to be filled in or modified by the user are highlighted.

The model VOC management plan can be downloaded from the ABS website, Regulatory Information, Regulatory Newsroom section.

Downloads:

• ABS model VOC management plan