Last Updated on Tuesday, 03 March 2009 13:46 Wednesday, 04 February 2009 12:32
Issue: At the fall 2008 NOSAC meeting, the Coast Guard indicated that it is close to completing guidance on complying with IMO rules covering Noxious Liquid Substances. There is a great deal of concern in the offshore industry that the rules will be impossible for workboats to meet. This is a complex topic, so some background is necessary to help understand this issue.
BACKGROUND: Globally, the International Maritime Organization (IMO) implemented a marine environmental protection treaty called the “International Convention for the Prevention of Pollution from Ships, 1973, as modified by the Protocol of 1978 relating thereto” or MARPOL 73/78. MARPOL has six annexes to protect the oceans. Annex I covers pollution from oil and Annex II covers pollution by noxious liquid substances (NLS). Annex III covers packaged cargo, Annex IV covers sewage, and Annex V covers garbage. The newest part is Annex VI which covers air pollution primarily from diesel engines. Annex II was recently updated and the changes came into international effect on January 1, 2007 (over 22 months ago). The major changes were that about 250 substances were evaluated and included in the list of regulated NLS cargos and the NLS categories were changed from categories A, B, C, & D to categories X, Y, Z and “Other Substances”. Category X cargos are deemed the most harmful to the marine environment and Category Z the least harmful. The category “Other Substances” are those substances considered to present no harm to the marine environment.
Concurrently the “International Code for the Construction and Equipment of Ships Carrying Dangerous Chemicals in Bulk” (or IBC code) was also amended as needed to accommodate the MARPOL II changes. The IMO also has a resolution A.673(16) titled “Guidelines for the Transport and Handling of Limited Amounts of Hazardous and Noxious Liquid Substances in Bulk on Offshore Support Vessels”. According to a 1999 USCG letter to OMSA, A.673 was not binding on the United States at that time. As part of the MARPOL II and IBC changes, A.673 is now applicable to vessels needing to operate on an International Voyage.
To implement these changes, the USCG published NVIC 03-06, which is available at: http://www.uscg.mil/hq/cg5/nvic/pdf/2006/NVIC%2003?06%20Final.pdf and currently applies to non-US flag ships in US waters and all US ships whose keel was laid on or after January 1, 2007. The USCG is now working on Change 1 to this NVIC to cover newly built OSV’s. Once Change 1 is complete, the USCG intends to start working on Change 2 to cover existing OSV’s.
ISSUES: Many substances now categorized as NLS are regularly carried on OSV’s, especially on well stimulation boats. These rules as a whole place challenging new requirements on builders and operators of OSV’s such as:
- A limit of 800 cubic meters of NLS – most large OSV’s carry much more drilling mud than 800 cubic meters;
- A requirement for full length wing tanks of 30 inches width to protect the NLS cargo tanks in the event of a collision;
- Redefining operations from a non-US port as an International Voyage vice the past term foreign-domestic voyage;
- Access hatches in the main deck into all NLS cargo tanks? a deck strength & hatch weight issue;
- Increases in cargo segregation and fire protection requirements.
Status: The OMSA staff and many OMSA members have been actively engaging the USCG through NOSAC and a NOSAC MARPOL II subcommittee led by Nicki Candies. This subcommittee has met multiple times to craft a method of meeting MARPOL without killing the OSV industry. OMSA is working hard to minimize the impact of these international rule changes as well as ensuring the NVIC does not all any new burdens. We have scheduled a meeting with key Coast Guard policy makers for early 2009 to solve this issue. OMSA will keep our members informed as these important decisions are made by the USCG.
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