DEVELOPMENT OF A CODE FOR THE TRANSPORT AND HANDLING OF LIMITED AMOUNTS OF HAZARDOUS AND NOXIOUS LIQUID SUBSTANCES IN BULK ON OFFSHORE SUPPORT VESSELS

Transcription

1 E SUB-COMMITTEE ON BULK LIQUIDS AND GASES 17th session Agenda item 12 2 November 2012 ENGLISH ONLY DEVELOPMENT OF A CODE FOR THE TRANSPORT AND HANDLING OF LIMITED AMOUNTS OF HAZARDOUS AND NOXIOUS LIQUID SUBSTANCES IN BULK ON OFFSHORE SUPPORT VESSELS Report of the Correspondence Group Draft OSV Chemical Code and comments received during the work of the Correspondence Group Submitted by SUMMARY Executive summary: This document provides the text of the draft OSV Chemical Code and a collation of comments received during the work of the correspondence group established at BLG 16 under this agenda item Strategic direction: 7.1 High-level action: Planned output: Action to be taken: Paragraph 2 Related document: BLG 17/12 1 BLG 16 established a correspondence group to progress the development of the draft Code for the transport and handling of limited amounts of hazardous and noxious liquid substances in bulk in offshore support vessels (OSV Chemical Code). The report of the correspondence group is presented in document BLG 17/12. This document provides the text of the draft OSV Chemical Code, as prepared by the correspondence group, as well as a collation of comments received during the work of the group. Action requested of the Sub-Committee 2 The Sub-Committee is invited to note the information provided in this document. ***

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3 Annex, page 1 ANNEX DRAFT CODE FOR THE TRANSPORT AND HANDLING OF HAZARDOUS AND NOXIOUS LIQUID SUBSTANCES IN BULK IN OFFSHORE SUPPORT VESSELS PREAMBLE CHAPTER 1 GENERAL 1.1 Application 1.2 Scope 1.3 Definitions 1.4 Equivalents 1.5 Survey and certification CHAPTER 2 SHIP SURVIVAL CAPABILITY AND LOCATION OF CARGO TANKS General 2.2 Freeboard and intact stability 2.3 Shipside discharges below the freeboard deck 2.4 Conditions of loading 2.5 Damage assumptions 2.6 Location of cargo tanks 2.7 Flooding assumptions 2.8 Standard of damage 2.9 Survival requirements CHAPTER 3 SHIP DESIGN 3.1 Cargo segregation Segregation requirements for integral tanks 3.2 Cargo pump rooms 3.3 Accommodation, service and machinery spaces and control stations 3.4 Access to spaces in the cargo area 3.5 Cargo tank construction 3.6 Materials of construction CHAPTER 4 CARGO CONTAINMENT 4.1 Definitions 4.2 Tank type requirements for individual products CHAPTER 5 CARGO TRANSFER 5.1 Piping scantlings 5.2 Piping fabrication and joining details 5.3 Flange connections 5.4 Test requirements for piping 5.5 Piping arrangements 5.6 Cargo-transfer control systems 5.7 Ship's cargo hoses CHAPTER 6 CARGO TANK VENTING 6.1 General 6.2 Types of tank vent systems 6.3 Venting requirements for individual products CHAPTER 7 ELECTRICAL INSTALLATIONS 7.1 General 7.2 Bonding 7.3 Electrical requirements for individual products

4 Annex, page 2 CHAPTER 8 FIRE-FIGHTING REQUIREMENTS CHAPTER 9 ACID SPILL PROTECTION CHAPTER 10 VENTILATION OF SPACES IN THE CARGO AREA 10.1 Spaces normally entered during cargo-handling operations 10.2 Pump-rooms and other enclosed spaces normally entered 10.3 Spaces not normally entered CHAPTER 11 INSTRUMENTATION 11.1 Gauging and Level detection 11.2 Emergency remote shutdown Vapour detection CHAPTER 12 SPECIAL REQUIREMENTS 12.1 General 12.2 Special requirements for the carriage of liquefied gases CHAPTER 13 POLLUTION REQUIREMENTS CHAPTER 14 PERSONNEL PROTECTION 14.1 Decontamination showers and eyewashes 14.2 Protective and safety equipment CHAPTER 15 OPERATIONAL REQUIREMENTS 15.1 Maximum allowable quantity of cargo per tank 15.2 Cargo information 15.3 Personnel training 15.4 Opening of and entry into cargo tanks 15.5 Stowage of cargo samples 15.6 Cargoes not to be exposed to excessive heat CHAPTER 16 TRANSPORT OF LIGUID CHEMICAL WASTE REFERED TO AS 'BACK- LOADING' OF BULK CARGO 16.1 Preamble 16.2 Definitions 16.3 Applicability 16.4 Documentation 16.5 Reporting Requirements CHAPTER 17 APPLICABILITY OF THE GUIDELINES TO EXISTING OFFSHORE SUPPORT VESSELS United Kingdom BLG 15/12 Need a chapter on the IGC Code issues that are currently covered by the guidelines Agree with Agree with Preamble 1 These Guidelines have been developed for the design, construction and operation of offshore support vessels which transport limited amounts of hazardous and noxious liquid substances in bulk for the servicing and resupplying of offshore platforms, mobile offshore drilling units and other offshore installations, including those employed in the search for and recovery of hydrocarbons from the sea-bed. 2 These Guidelines have been developed in accordance with the provisions set forth in regulation 11(2) of Annex II to MARPOL 73/78 and in recognition of the need for standards which provide an alternative to the International Code for the Construction and Equipment of Ships Carrying Dangerous Chemicals in Bulk and the International Code for the Construction and Equipment of Ships Carrying Liquefied Gases in Bulk for these types of vessels.

5 Annex, page 3 3 The Guidelines are intended to permit limited quantities of these hazardous and noxious liquid substances to be transported in bulk in offshore support vessels with minimum risk to the vessel, its crew and the environment. 4 The basic philosophy of the Guidelines is to apply standards contained in the International Code for the Construction and Equipment of Ships Carrying Dangerous Chemicals in Bulk and the International Code for the Construction and Equipment of Ships Carrying Liquefied Gases in Bulk to the extent that that is practicable and reasonable taking into account the unique design features and service characteristics of these vessels, as well as the limitation placed on amounts to be carried. 5 The Guidelines for the Design and Construction of Offshore Supply Vessels, 2006 (resolution MSC.235(82)) are also applicable to offshore support vessels subject to these Guidelines. United Kingdom 6 It is recognized that the technology of the offshore industry is complex and subject to continued evolution as is evidenced by the growing need for specialized vessels such as well-stimulation vessels. To meet the needs of the industry, the Guidelines should not remain static. Therefore the Organization will periodically review the Guidelines, taking into account both experience and technical development. Amendments to the Guidelines involving requirements for new cargoes will be circulated periodically as new cargoes are proposed for carriage and the requirements are developed. Should leave to the end when the Code is completed. Also references to Guidelines need to be changed to Code, will need to consider and redraft. To be discussed when OSV Code is finalized To be discussed when the Code is finalized To be discussed when the Code is finalized Change Guidelines with Code, and reference to MARPOL needs to be updated proposal United States CHAPTER 1 GENERAL To provide an international standard for the safe carriage, by sea in bulk, of chemicals by laying down the design and construction standards of ships involved in such carriage and the equipment, they shall carry to minimize the risk to the ship, its crew and to the environment, having regard to the nature of the products including flammability, toxicity, asphyxiation, corrosivity, reactivity. Application To be discussed fully once OSV has been finalized also change all reference to Guidelines to Code Agree with position that questions of application need to be re-examined after he derails of the code have been developed To be further discussed when the Code is finalized. The revised Chapter 17 need to be inserted in Chapter 1 To be further discussed when the Code is finalized. Consider inserting Chapter 17 in Chapter 1 To be further discussed when the Code is finalized. Consider inserting Chapter 17 in Chapter 1 Agree with position needs to be addressed after details of codes have been developed The Guidelines apply to offshore support vessels, regardless of size or voyage, that, while not constructed or adapted primarily to carry in bulk cargoes subject to these Guidelines, carry, in limited quantities, the substances identified in The Guidelines apply when these cargoes are carried.

6 Annex, page 4 To be discussed fully once OSV has been finalized also change all reference to Guidelines to Code The guidelines should govern OSVs for carriage of all Chem-code cargoes. The use of the word "bulk" may need to be defined here and elsewhere this has meaning in IBC but was modified to "limited quantities" in A673 The last sentence, in this context does not make sense since the construction and stability requirements should govern regardless of what happens to be on board at any given time. No need to refer to 'limited quantities' The Code applies to offshore support vessels, regardless of size or voyage, that, while not constructed or adapted primarily to carry in bulk cargoes subject to this Code, carry, in restricted quantities, the substances allowed to be carried under this Code For an offshore support vessel the keel of which is laid or which is at a similar stage of construction on or after 00-Month-Year, the requirements in chapters 1 to 6 apply in full. For an offshore support vessel the keel of which is laid or which is at a similar stage of construction prior to 00-Month-Year, the Guidelines apply as indicated in resolution A.673(16) as stated by MEPC.158(55) and later MSC.236(82). For an offshore support vessel the keel of which is laid or which is at a similar stage of construction prior to 19 April 1990, the Guidelines apply as indicated in chapter 7. The Code applies to ships regardless of size, including those of less than 500 gross tonnage, when engaged in the carriage of bulk cargoes of dangerous chemicals or noxious liquid substances (NLS) listed in Chapter 17 of the IBC Code and MEPC.2/Circ. Rather than use a firm date in the text we are more comfortable using the traditional language of acceptance/resolution + time period. In the case of a mandatory Code we would prefer a period that could accommodate design as well as construction so would suggest a minimum of 18 months. The section needs to be expanded to include three groups of vessels 1. OSVs constructed before 19 April OSVs constructed on or after 19 April 1990 but before these Guidelines are applied, and 3. OSVs built on or after the application statement in these Guidelines. 4. The existing vessels may continue using the existing IMO Resolution A.673(16) Guidelines for the Transport and Handling of Limited Amounts of Hazardous and Noxious liquid Substances in bulk on Offshore Support Vessels as amended. The problem area would be the Damage stability requirements in Chapter 2. BLG15/12/1 and For an offshore support vessel the keel of which is laid or which is at a similar stage of construction on or after six months after MEPC-MSC Circular issuance, the requirements in chapters 1 to 6 apply in full. For an offshore support vessel the keel of which is laid or which is at a similar stage of construction prior to six months after MEPC- MSC Circular issuance, the Guidelines apply as indicated in chapter 7. We prefer this with the modification to the time period as noted above Unless expressly provided otherwise, the Code applies to ships, the keels of which are laid or which are at the stage where:.1 construction identifiable with the ship begins; and.2 assembly has commenced comprising at least 50 tonnes or 1% of the estimated mass of all structural material, whichever is less; on or after 1 July Propose to delete this approach BLG 15/ A vessel irrespective of the date of construction, which is converted for the carriage of bulk liquids subject to these Guidelines on or after the date specified in should be treated as a vessel constructed on the date on which such conversion

7 Annex, page 5 commences. An existing offshore support vessel which transports a cargo subject to these Guidelines and undergoes modification for the transport of additional cargoes falling under these Guidelines should not be considered as a vessel which has undergone a conversion. We would prefer inclusion of a caveat that includes Flag Administration acceptance of equivalencies in this article. Change 'these Guidelines' to 'this Code' Brazil United States For the purpose of these Guidelines, "limited quantities" means that the quantity of cargo required to be carried identified in shall not exceed 350 m in any one tank. For ships referred to in , such as well-stimulation vessels, the Administration may permit carriage of more than the maximum amount specified above. Strongly support to keep both this paragraph and the next below in the Code, having view they approach different questions, although connected When damage stability requirements are finalized further consideration should be done regarding introducing a limit of each tank or keeping a total limit or both. No need to refer to 'limited quantities' The carriage of all other cargos identified in paragraph must not exceed a total aggregate volume in cubic meters equal to 20% of the vessel's deadweight, calculated at a cargo specific gravity of 1.0. If the damage stability requirements of paragraph are not met, an OSV may not carry more than the limited quantities specified in paragraph above (i.e. the lesser of 800 m3 or a volume in cubic meters equal to 40% of the vessel's deadweight). 1) Is there a maximum amount that the Administration may permit? Why are well stimulation vessels etc. allowed more? 2) There is no limit now for the amount. However, a maximum limit of cargo on board should be established. BLG 15/12/1 and Brazil For the purpose of these Guidelines, "limited quantities" means that the aggregate quantity of bulk liquids identified in that is carried is any amount not exceeding a volume in cubic meters equal to 40% of the vessel's deadweight calculated at a cargo density of 1.0, excluding Exploration and Production (E&P) fluids which may be carried limited only by stability limitations. For ships referred to in , such as well-stimulation vessels, the Administration may permit carriage of more than the maximum amount specified above. Strongly support to keep both this paragraph and the above in the Code, having view they approach different questions, although connected or reword after finalizing stability issues etc. Prefer this definition of limited quantities No need to refer to 'limited quantities' United States See above 1) Is there a maximum amount that the Administration may permit? Why are well stimulation vessels etc. allowed more? 2) There is no limit now for the amount. E&P Fluids should comply the same as the other chemicals. 3 BLG 15/12/6 paragraph 5.3 OSVs may carry unlimited quantities of drilling muds with a closed cup flashpoint of greater than 24 o C (75 o F). The United States recommends adoption of a similar requirement, in addition to a limit on the percentage of NLS that the mud may contain. or not relevant Do not agree Do not agree

8 Annex, page 6 1) Is there documentation to support 24 o C as the cut off? 2) IMO standard is 60 o C BLG 15/12/1 and United States The Administration may permit carriage of more than the relevant maximum amount specified above, provided that the survival capability requirements of chapter 2 of the International Bulk Chemical Code or the International Gas Carrier Code are complied with. or reword after finalizing stability issues etc. Agree with We support this Agree with Agree It should be maintained BLG 15/ The Guidelines apply only in the case of bulk carriage involving transfer of the cargo to or from its containment which forms part of the vessel or remains on board. Amend to: This Code applies to any bulk carriage involving bulk transfer to or from its containment while on board the ship. Makes no sense - delete For provisions regulating the transport of dangerous goods and marine pollutants in packaged form, including transport of dangerous goods in portable tanks, refer to the International Maritime Dangerous Goods (IMDG) Code. We would suggest that the OSV Chem Code offers the possibility of addressing this for deck cargoes carried on support vessels. To that extent we recommend further discussion, since IMDG is, like IBC is designed for other service models. 1) Requirements from SOLAS II-2/19 should be added for the carriage of DG in packaged form. 2) Reference should also be made to MARPOL Annex III These Guidelines apply in addition to the Guidelines for the Design and Construction of Offshore Supply Vessels. Where the present Guidelines set forth alternative safety standards, the standards in the present Guidelines should be followed and SOLAS Chapter II-2, regulation 19. As mentioned in 1.1.6, OSV Chem-code should be able to develop "Dangerous Goods" carriage requirements that address SOLAS Ch.II-2 Reg 19 requirements. Since most of these are on deck this would streamline requirements for OSVs. 1) Reference to SOLAS II-2/19 should be deleted. 2) Change 'these Guidelines' to 'this Code' Change 'the present Guidelines' to 'this Code' Change 'should' to 'shall BLG 15/12/1 and BLG 15/ These Guidelines apply in addition to the Guidelines for the Design and Construction of Offshore Supply Vessels. Where the present Guidelines set forth alternative safety standards, the standards in the present Guidelines or Administration Offshore Support Vessel standards should be followed. 1.2 Scope To be discussed when OSV Chemical Code is finalized

9 Annex, page 7 United States BLG 15/12/7 Paragraph 9 BLG 15/12/1 and United States Support To be further discussed when the Code is finalized Agree with and Agree with and The provisions of this Code have been developed so that restricted quantities of cargoes regulated under this Code may be carried in bulk with minimum risk to the offshore support vessel, its crew, and to the environment The provisions of the Guidelines have been developed so that limited quantities of cargoes regulated under these Guidelines may be carried in bulk with minimum risk to the offshore support vessel, its crew, and to the environment Products which may be carried subject to the Guidelines are:.1 only those offshore related cargos which are listed as hazardous and noxious liquids listed in Chapter 17 or Chapter 18 of the International Bulk Chemical Code and their related references to Chapters 15 and 19 based on the following criteria: Need to discuss this in more detail Recommend delete Considering the intention to allow the vessels to carry ST2 and ST3 cargoes, we propose to delete the reference to "only those offshore related cargoes." the reference to offshore related cargoes needs further consideration. Offshore related cargoes not necessary to mention Need to discuss this in more detail Agree with No need for further discussions No need for further consideration based on the above proposal.1 those hazardous and noxious liquids listed in appendix 1 and those other products which may be assigned to appendix 1 based on the following criteria: We need to reword once Code finalized Need to discuss this in more detail Those hazardous and noxious liquids listed in appendix 1, MEPC.2/Circ. Annex 12 and those other products which may be assigned to appendix 1 based on the following criteria: Already covered by above paragraph - delete BLG 15/12.1 products which for safety reasons may be assigned for carriage on a type 2 ship as defined by the International Bulk Chemical Code and which are not required to meet the requirements for toxic products in section of that Code Need to discuss this in more detail United States Recommend delete 1) With the addition of the requirements in other chapters, the toxic products restriction should be reviewed. 2) Toxic cargoes are requested to be carried. BLG 15/12/1 and.1 products which for safety reasons may be assigned for carriage on a type 3 ship as defined by the International Bulk Chemical Code and which are not required to meet the requirements for toxic products in section of that Code Need to discuss this in more detail

10 Annex, page 8 BLG 15/12.2 noxious liquid substances which would be permitted for carriage on a type 2 ship Need to discuss this in more detail United States Recommend delete BLG 15/12/1 and.2 noxious liquid substances which would be permitted for carriage on a type 3 ship; Need to discuss this in more detail BLG15/12.2 flammable liquids. Need to discuss this in more detail BLG 15/12/1 and.3 cargoes requiring vessels to meet the standards of the IBC Code for Ship Type 2 and Ship Type 3 when carried on deck in independent (fixed or portable) tanks. Need to discuss this in more detail BLG 15/12/1 and United States.4 The return or "backhaul" of used or "spent" cargoes regulated under these Guidelines may be carried under the same requirements as the original product. The return or backloading of used or contaminated cargoes regulated under this Code shall be carried under the same requirements as the original product or in accordance with the relevant section of this Code Need to discuss this in more detail Agree with Agree with Agree with The return or backloading of used or contaminated cargoes regulated under this Code shall be carried under the same requirement as the original product or in accordance with the relevant section of this Code. 1) More information is needed in order to determine if an explicit exclusion should be included in these Guidelines. 2) There is a separate Chapter for this, so requirements should be there and not here. BLG 15/12/7 Paragraph 8 United States (if) it (is) proposed to delete reference to appendix 1 of resolution A.673(16) and instead refer to offshore related cargoes in chapters 17 and 18 of the IBC Code. In general we agree to this principle since the IBC Code is revised every four years, while there is no mechanism to update appendix 1 on a regular basis. also sees a need to allow the transport of tripartite agreement products listed in the MEPC.2/Circulars. Reference to IBC Code Chapter 17 and 18 and also MEPC.2/Circ Need to discuss this in more detail MEPC.2/Circ. Annex 12 will be a way to add cargoes to appendix 1 after the Code has been published. It will need to be decided if it will use the same process that is used for new cargoes in the IBC Code or a simplified version. Agree, provided that offshore related cargoes are defined BLG 15/ Additives which are considered to fall outside the scope of products in may be carried in limited amounts in accordance with requirements acceptable to the Administration. The aggregate amount of such additives which may be transported should not exceed 10% of the vessel's maximum authorized quantity of products subject to these Guidelines. An individual tank should contain not more than 10 m 3 of these additives. The discharge of these additives into the sea from offshore support vessels is prohibited.

11 Annex, page 9 United States BLG 15/12/7 Paragraph 10 BLG 15/2 Confusing, when considering cleaning additives, so delete Need to discuss this in more detail Further discussion needed Do we have a definition and examples of these? Are these Cleaning additives? [a definition of additives needs to be developed if transport of such products should be included in the Code.] [See also below] Need to discuss this in more detail No need for a definition No need for a definition Agree with comment 1.3 Definitions The following definitions apply unless expressly provided otherwise. (Additional definitions are given in individual chapters). We can go through quickly but will need to come back to this once Code is completed To be further discussed when the Code is finalized Need to come back Accommodation spaces are those spaces used for public spaces, corridors, lavatories, cabins, offices, hospitals, cinemas, games and hobbies rooms, barber shops, pantries containing no cooking appliances and similar spaces Public spaces are those portions of the accommodation spaces which are used for halls, dining rooms, lounges and similar permanently enclosed spaces. Need to separate out Need to discuss this in more detail Should be divided into two different definitions: Accommodation spaces are those spaces used for public spaces, corridors, lavatories, cabins, offices, hospitals, cinemas, games and hobbies rooms, barber shops, pantries containing no cooking appliances and similar spaces. Public spaces are those portions of the accommodation spaces which are used for halls, dining rooms, lounges and similar permanently enclosed spaces. Support and Public spaces should be shown as a separate definition Do we need Public spaces as part of this on an OSV? BLG 15/12/1 and Additives means cleaning additives (detergent products) and other non-marpol II regulated products added to Appendix 1 products to improve well completion or production process effectiveness., as covered under MARPOL Annex II Need to discuss this in more detail United States Further discussion needed There is Cleaning Agents in MARPOL Annex II Regulation 13.5 What percentage? Need clarification or deletion

12 Annex, page 10 BLG 15/ Administration means the Government of the State whose flag the ship is entitled to fly. For Administration (Port) see Port Administration Anniversary date means the day and the month of each year, which will correspond to the date of expiry of the International Certificate of Fitness for the Carriage of Dangerous Chemicals in Bulk. Lloyds Should be amended to: Anniversary date means the day and the month of each year, which will correspond to the date of expiry of the International Certificate of Fitness. Same as Specific certificate for the OSV Chemical Code and reference should be added and reference to the IBC Code deleted Boiling point is the temperature at which a product exhibits a vapour pressure equal to the atmospheric pressure Breadth (B) means the maximum breadth of the ship, measured amidships to the moulded line of the frame in a ship with a metal shell and to the outer surface of the hull in a ship with a shell of any other material. The breadth (B) shall be measured in metres Cargo area is that part of the offshore support vessel where cargo and cargo vapours are likely to be present and includes cargo tanks, cargo pump-rooms, hold spaces in which independent tanks are located, cofferdams surrounding integral tanks and the following deck areas:.1 within 3 m of a cargo tank installed on deck;.2 within 3 m of a cargo tank outlet in case of independent tanks installed below deck;.3 within 3 m of a cargo tank outlet in case of integral tanks installed below deck and separated from the weather deck by a cofferdam;.4 the deck area above an integral tank without an overlaying cofferdam plus the deck area extending transversely and longitudinally for a distance of 3 m beyond each side of the tank; and.5 within 3 m of any cargo liquid or vapour pipe, flange, cargo valve, gas or vapour outlet or entrance or ventilation opening to a cargo pump-room. Add portable tanks, also added wording in Chapter 4 regarding independent tanks on deck and cross reference to Portable tank chapter..1 3 May need to re-visit after discussion on stability and running of tank vent lines etc..4 Is this section still valid and can we delete.4 May be an idea to consider the issue of wooden deck cladding and water as an equivalent to A60. This doesn't address direct OSV conditions; we either need to discuss further in detail or use the next article instead Must be further considered in connection with the ventilation requirements. Portable tanks should be included. Should amended to: Cargo area is that part of the offshore support vessel where cargo and cargo vapours are likely to be present and includes cargo tanks, portable tanks used as deck tanks, cargo pump-rooms, hold spaces in which independent tanks are located, cofferdams surrounding integral tanks and the following deck areas:.1 within 3 m of a cargo tank installed on deck;.2 within 3 m of a cargo tank outlet in case of independent tanks installed below deck;.3 within 3 m of a cargo tank outlet in case of integral tanks installed below deck and separated from the weather deck by a cofferdam;.4 the deck area above an integral tank without an overlaying cofferdam plus the deck area extending transversely and longitudinally for a distance of 3 m beyond each side of the tank; and

13 Annex, page 11 BLG 15/12/6 Paragraph within 3 m of any cargo liquid or vapour pipe, flange, cargo valve, gas or vapour outlet or entrance or ventilation opening to a cargo pump-room. Agree with and that portable tanks should be included The underlined section should be added: Cargo area is that part of the offshore support vessel where cargo and cargo vapours are likely to be present and includes cargo tanks, portable tanks used as deck tanks, cargo pump-rooms, hold spaces in which independent tanks are located, cofferdams surrounding integral tanks and the following deck areas: [use of the term "cargo area", while more closely aligned with that of the IBC Code, is not appropriate for application to all OSVs, particularly if NLSs are carried in only a small number of the vessel's tanks.] We need a definition of a cargo area so may need to reword Prefer this approach or rework Do not agree because the term cargo area is associated with the cargo tank regardless of the number of tanks onboard Cargo pump room is a space containing pumps and their accessories for the handling of the products covered by the Code Cargo service spaces are spaces within the cargo area used for workshops, lockers and store-rooms of more than 2 m2 in area, used for cargo-handling equipment. Not needed delete Written for Tankers, not needed for OSVs This is covered by SOLAS and the IBC Code. Not applicable in this Code, since not used in the Code - delete Cargo tank is the envelope designed to contain the cargo Chemical tanker is a cargo ship constructed or adapted and used for the carriage in bulk of any liquid product listed in chapter 17 of the IBC Code. Offshore Support Vessel constructed or adapted and used for the carriage in bulk of any liquid product listed in chapter 17 of the IBC Code is a cargo ship adapted to carry these products. as wrong relevance This is covered by SOLAS and IBC Code. Not applicable in this Code, since not used in the Code. Propose to delete Cofferdam is the isolating space between two adjacent steel bulkheads or decks. This space may be a void space or a ballast space. 'steel', to allow alternative arrangements Amend as follows: Cofferdam is the isolating space between two adjacent bulkheads or decks. This space may be a void space or a ballast space. 'steel' 'steel' Why only steel? this covers small vessels as well

14 Annex, page 12 United States BLG 15/12/1 and Control stations are those spaces in which ship's radio or main navigating equipment or the emergency source of power is located or where the fire-recording or firecontrol equipment is centralized. This does not include special fire-control equipment which can be most practically located in the cargo area. Change to Cargo Control station and reword to take account of pump controls etc. We need to develop more OSV-relatable definition of control stations Amend as follows: [Control stations are those spaces in which ship's radio or main navigating equipment or the emergency source of power is located or where the fire-recording or firecontrol equipment is centralized.] Include definition of Cargo Control Station: [Cargo Control Station is a location used in controlling the cargo handling operations.] Reword Ships radio equipment etc. should not be included in this definition. It should be related to cargo handling: Control station is a location used in controlling the cargo handling operations. Further discussion needed Propose to delete the last sentence: 'this does not cargo area.' Add new paragraph: Cargo Control Station is a location used in controlling the cargo handling operations Conversion means a vessel in an un-related service is modified for use as an offshore support vessel. Special Purpose Ships (operated under the SPS Code) in support related service configurations are not considered "in an unrelated service". Is this relevant to this Code, delete We support retention of this definition Propose to delete Dangerous chemicals means any liquid chemicals designated as presenting a safety hazard, based on the safety criteria for assigning products to chapter 17 of the IBC Code. We are adding in different definition for the same NLS product. Covered by MARPOL Annex II This is not used in this Code, covered by IBC Code paragraph Deadweight means the difference in metric tons between the displacement of an offshore support vessel in water of a density of at the load waterline corresponding to the assigned summer freeboard and the lightweight of the ship. With the removal of the 40% criteria this is no longer required Density is the ratio of the mass to the volume of a product, expressed in terms of kilograms per cubic metre. This applies to liquids, gases and vapours. Is this needed Is this needed

15 Annex, page 13 Is this needed BLG 15/12/ Drilling Fluids Engineer is person on an offshore facility designated as responsible for maintaining the E&P Fluids properties. Not needed Needed for discussion of backloading Does not appear to be used in the new Code. See below about E&P Fluids BLG 15/12/ Exploration and Production (E & P) Fluids means those Liquid Muds (Water based, oil based and synthetic oil based), Drilling Brines and salt solutions identified in Appendix 1 table of permitted products, OR that are listed In the IBC Code chapter 17 or 18 as (P) pollutant only without an (S) safety hazard notation and meet the following carriage requirements: Tank type 2G (Internal Gravity) Open venting No tank environment requirements Flash point > 60 degrees C (closed cup test) Open gauging No vapour detection required. We need to delete as it is confusing, how would they be assessed to ensure they are OK to carry Retain since this is written in the language of the OSV industry, not tanker 1) Confirmation that E&P are pollution hazard only should be sought from ESPH WG. 2) Clearer definition of which cargo can be classified as (E & P) is necessary. 3) Information will need to be supplied by Industry. 4) We will need to generate generic entries in the IBC Code for Oil Based muds and water-based muds. 5) Also the question what does Base Oils come under? BLG 15/ Explosive/flammability limits/range are the conditions defining the state of fuel oxidant mixture at which application of an adequately strong external ignition source is only just capable of producing flammability in a given test apparatus. Un-necessarily vague Flammable liquid is any liquid having a flashpoint not exceeding 60 C (closed cup test). Need to look at and clarify Must be further considered. Is it necessary to include this definition? Not included in the IBC Code or SOLAS. Clarify This entry causes confusion since the IBC Code has three categories Non-Flammable, Flashpoint below 60 Deg C, Flashpoint above 60 Deg C. This will need to be looked at after the Fire Fighting arrangements are sorted.

16 Annex, page 14 BLG 15/12/1 and Flammable Cargo Area is that portion of the cargo area where flammable cargo is carried. Move to and amend We can support further discussion, but do not necessarily agree with a move to This is not used in the draft, so could be deleted BLG 15/ Flashpoint is the temperature in degrees Celsius at which a product will give off enough flammable vapour to be ignited. Values given in the Code are those for a "closed cup test" determined by an approved flashpoint apparatus. Flashpoint is the temperature in degrees Celsius (closed cup test) at which a product will give off enough flammable vapour to be ignited, as determined by an approved flashpoint apparatus. Use the same definition as SOLAS II-2/3.24: Flashpoint is the temperature in degrees Celsius (closed cup test) at which a product will give off enough flammable vapour to be ignited, as determined by an approved flashpoint apparatus. Use SOLAS definition Use SOLAs definition There is an alternative definition in SOLAS II-2 3/24: Flashpoint is the temperature in degrees Celsius (closed cup test) at which a product will give off enough flammable vapour to be ignited, as determined by an approved flashpoint apparatus. BLG 15/12/5 Hazardous Product Area is that part of the offshore support vessel where hazardous cargo and hazardous cargo vapours are likely to be present and includes hazardous cargo tanks, hazardous cargo pump-rooms, hold spaces in which independent hazardous cargo tanks are located, cofferdams surrounding integral hazardous cargo tanks and the following deck areas:.1 within 3 m of a hazardous cargo tank installed on deck;.2 within 3 m of a hazardous cargo tank outlet in case of independent tanks installed below deck;.3 within 3 m of a hazardous cargo tank outlet in case of integral tanks installed below deck and separated from the weather deck by a cofferdam; and.4 the deck area above an integral hazardous cargo tank without an overlaying cofferdam plus the deck area extending transversely and longitudinally for a distance of 3 m beyond each side of the hazardous product tank. Is this a definition of a cargo area, and is duplicated above so delete This was written to be OSV specific and we would submit, need further discussion. This is intended as an alternative to IBC Code language in Cargo area. Definition of cargo area is sufficient As all cargoes listed in chapter 17 present a hazard (e.g. pollution, safety and pollution/safety), we do not consider this definition necessary to make a distinction from "Cargo Area". Propose to be deleted. BLG 15/ Hazardous substance is any substance either listed in chapter 17 of the International Bulk Chemical Code or having a hazard more severe than one of the minimum hazard criteria given in criteria for hazard evaluation of bulk chemicals as approved by the Organization.

17 Annex, page 15 What does this mean, should be deleted Support deletion - nonsense Does not appear to be used Hold space is the space enclosed by the ship's structure in which an independent cargo tank is situated. Is this correct Not correct Independent means that a piping or venting system, for example, is in no way connected to another system and that there are no provisions available for the potential connection to other systems. Needs to be considered again when Code is finalized Agree with Agree with This relates to independent tanks. Is this applicable for tanks for liquids or tanks for gases? Needs to be looked at later since does not seem to cover such things as Independent tanks International Bulk Chemical Code means the International Code for the Construction and Equipment of Ships Carrying Dangerous Chemicals in Bulk (resolutions MSC.4(48) and MEPC.19(22) as amended) International Gas Carrier Code means the International Code for the Construction and Equipment of Ships Carrying Liquefied Gases in Bulk (resolution MSC.5(48), as amended) Intrinsically safe means, if electrical equipment or instrument is fitted or used in such spaces, that it shall be of a certified safe type for use in the dangerous environments to which it may be exposed. Is this needed If reference is made to chapter 17 in this revised Code, then, this definition should include also reference to the Apparatus Group Length (L) means 96% of the total length on a waterline at 85% of the least moulded depth measured from the top of the keel, or the length from the foreside of the stem to the axis of the rudder stock on that waterline, if that be greater. In ships designed with a rake of keel, the waterline on which this length is measured shall be parallel to the designed waterline. The length (L) shall be measured in metres. We need to refer to Load Line Convention to ensure we have the correct wording Refer to Load Line Convention regulation 3 Refer to Load Line Convention Refer to Load Line Propose to cross refer to the Load Line length in the Load Line Convention Lightweight means the displacement of an offshore support vessel in metric tons without cargo, fuel, lubricating oil, ballast water, fresh water and feed water in tanks, consumable stores, and passengers and crew and their effects. Is this relevant, can we delete Covered in other instruments, delete Relevance?

18 Annex, page Machinery spaces of category A are those spaces and trunks to such spaces which contain:.1 internal-combustion machinery used for main propulsion; or.2 internal-combustion machinery used for purposes other than main propulsion where such machinery has in the aggregate a total power output of not less than 375 kw; or.3 any oil-fired boiler or oil fuel unit or any oil fired equipment other than boilers, such as inert gas generators, incinerators, etc. Need to ensure same wording as SOLAS Same wording as SOLAS Same wording as SOLAS Follow SOLAS Should be the same as in SOLAS II-2/ Machinery spaces are all machinery spaces of category A and all other spaces containing propelling machinery, boilers, oil fuel units, steam and internal-combustion engines, generators and major electrical machinery, oil filling station, refrigerating, stabilizing, ventilation and air-conditioning machinery, and similar spaces, and trunks to such spaces. Need to ensure same wording as SOLAS Same wording as SOLAS Same wording as SOLAS Follow SOLAS Should be the same as in SOLAS II-2/ MARPOL means the International Convention for the Prevention of Pollution from Ships, 1973, as modified by the Protocol of 1978 relating thereto, as amended. MARPOL Ref to update MARPOL reference MARPOL reference MARPOL reference Noxious Liquid Substance means any substance indicated in the Pollution Category column of chapter 17 or 18 of the International Bulk Chemical Code, or the current MEPC.2/Circular or provisionally assessed under the provisions of regulation 6.3 of MARPOL Annex II as falling into categories X, Y or Z. Should be the same as IBC Should be the same as IBC Offshore support vessels are:.1 vessels which are primarily engaged in the transport of stores, materials and equipment to and from mobile offshore drilling units, fixed and floating platforms and other similar offshore installations Further discussion on this definition Need further considerations. As a starting point suggest to modify as follows: Offshore support vessels are:.1 vessels which are primarily engaged in the transport of stores, materials and equipment to and from mobile offshore drilling units, fixed and floating platforms and other similar [subsea]offshore installations; or

19 Annex, page 17 Further consideration 'similar offshore installations' need to be discussed. Use 'similar subsea offshore installations'? 1) Considering that these Guidelines provide the requirements to carry HNLS in addition to the requirements in MSC.235(82), which is for Offshore Supply Vessels, it therefore would seem appropriate to replace "support" by "supply". This would also alleviate the need to comply with SOLAS II-1/4 in light of footnote "4" which refers to Supply Vessels. " 2) "Support" would allow a wider range of vessels such as deep diving vessels, well stimulation vessels, etc. 3) After 'floating platforms' add in 'subsea offshore installations,' to reflect changes in the industry. 4) It must be clear that only voyages to and from offshore installations are permitted. Port to port operations should be strictly prohibited. BLG 15/12/1 and and has the same meaning as Offshore Supply Vessels (OSVs); or 'Support' not 'Supply' BLG 15/12.2 vessels, including well-stimulation vessels, but excluding mobile offshore drilling units, derrick barges, pipelaying barges and floating accommodation units, which are otherwise primarily engaged in supporting the work of offshore installations. Would be better to use 'operation' instead of 'work'.2 vessels, including well-stimulation vessels, but excluding mobile offshore drilling units, derrick barges, pipelaying barges and floating accommodation units, which are otherwise primarily engaged in supporting the operation of offshore installations. Agree with Agree with United States Does this mean: vessels including well stim, but excluding MODU/pipelaying barges/ accommodation units which are otherwise engaged in supporting? Or does it mean: vessels including well stim which are otherwise engaged in supporting, but excluding MODU/pipelaying barges/ accommodation units? It is noted that today's OSVs, including sel-propelled barges, OSV/pipelaying vessels and floating accommodation units are more multifunctional and often carry NLS. If the ships continue to be exempted under the proposed Code, then, what standards should be applied. BLG 15/12/1 and BLG15 Plenary comments For the purposes of this Code we submit that the definition of OSV be made to conform to all vessels operating in support of exploration, exploitation, or production of offshore mineral or energy resources that are designed to carry NLS products in support of those activities. We prefer this definition This would widen the application to other vessel types than at present such as MODU [ comment in plenary we need a clear definition of OSV.] Agree this needs to be clear and we need to understand what these vessels and how they are operating Agree

20 Annex, page 18 BLG 15/ Open deck is defined as an open or semi-enclosed space on cargo deck or in cargo rail. Need to double check the wording to ensure consistent with SOLAS and last section unclear Recommend deletion potentially has adverse tonnage implications BLG 15/12/1 and United States Oil fuel unit is the equipment used for the preparation of oil fuel for delivery to an oil fired boiler, or equipment used for the preparation for delivery of heated oil to an internal combustion engine, and includes any oil pressure pumps, filters and heaters dealing with oil at a gauge pressure of more than 0.18 MPa. Why do we need this as already in SOLAS Covered in other instruments - delete Organization is the International Maritime Organization (IMO) Pollution hazard only substance means a substance having an entry only of "P" in column d in chapter 17 of the International Bulk Chemical Code. Do we need these, this should be in IBC Code Do we need these, this should be in IBC Code Do we need these, this should be in IBC Code No need, refer to IBC Code Reference to MEPC.2/Circ. should be included Pollution hazard only substance means a substance having an entry only of "P" in column d in chapter 17 of the International Bulk Chemical Code. This specifically includes "Exploration and Production Fluids" as defined in section Prefer this definition Recommend delete Clearer definition of which cargo can be classified as (E&P) is necessary BLG 15/ Propeller shaft tunnel is a compartment where the stern tube bulkhead seal is exposed to open sea. A propeller shaft tunnel is defined as a narrow enclosed space/room with the primary purpose of containing the propeller shaft with associated equipment, but it could also contain limited amounts of other equipment. A full size room, e.g., where the propeller shaft is carried below the floor but above the top of the tank, is not regarded as a propeller shaft tunnel. In case of open seawater lubricated stern tube, the compartment containing the stern tube bulkhead seal should also be considered as a propeller shaft tunnel. Do we need this, has caused problems with the current Guidelines Permeability of a space means the ratio of the volume within that space which is assumed to be occupied by water to the total volume of that space. Do we need this

21 Annex, page 19 United States BLG 15/12/1 and BLG 15/ Port administration means the appropriate authority of the country in the port of which the ship is loading or unloading Products is the collective term used to cover both Noxious Liquid Substances and Dangerous Chemicals Pump room is a space, located in the cargo area, containing pumps and their accessories for the handling of ballast and oil fuel This is a tanker definition; needs work Further discussion needed Recognized standards are applicable international or national standards acceptable to the Administration or standards laid down and maintained by an organization which comply with the standards adopted by the Organization and which are recognized by the Administration Reference temperature is the temperature at which the vapour pressure of the cargo corresponds to the set pressure of the pressure-relief valve Safety hazard substance means a substance having an entry of "S" or "S/P" in column d in chapter 17 of the International Bulk Chemical Code. Do we need this, should be in IBC Code Separate means that a cargo piping system or cargo vent system, for example, is not connected to another cargo piping or cargo vent system. Prefer this to definition of independent Service spaces are those spaces used for galleys, pantries containing cooking appliances, lockers, mail and specie rooms, store-rooms, workshops other than those forming part of the machinery spaces and similar spaces and trunks to such spaces SOLAS means the International Convention for the Safety of Life at Sea, 1974, as amended Vapour pressure is the equilibrium pressure of the saturated vapour above a liquid expressed in Pascals (Pa) at a specified temperature Void space is an enclosed space in the cargo area external to a cargo tank, other than a hold space, ballast space, oil fuel tank, cargo pump room, pump room, or any space in normal use by personnel Well-stimulation vessel means an offshore support vessel with specialized equipment and industrial personnel that deliver products and services into a well-head. Need to add in Deck spread from portable tank We need to add this Should it be a ship type designation in the certificate? 1.4 Equivalents When these Guidelines require that a particular fitting material, appliance, apparatus, item of equipment or type thereof should be fitted or carried in an offshore support vessel, or that any particular provision should be made, or any procedure or arrangement should be complied with, the Administration may allow any other fitting, material, appliance, apparatus, item of equipment or type thereof to be fitted or carried, or any other provision, procedure or arrangement to be made in that ship, if it is satisfied by trial thereof or otherwise that such fitting, material, appliance, apparatus, item of equipment or type thereof or that any particular provision, procedure or arrangement is at least as effective as that required by the Guidelines. However, the Administration may not allow operational methods or procedures to be made an alternative to a particular fitting, material,