Which ships carry a shipboard oil pollution emergency plan and the four things it must contain (MARPOL Annex I Regulation 37)

Regulation 37 of MARPOL Annex I deals with the shipboard oil pollution emergency plan (SOPEP). Which ships carry it, what must go into it, which language it is written in, and whether it may be merged with another plan sit in four paragraphs.

This plan is a document read after an incident. So a shortfall in its content does not show before one. A missing reporting point or an outdated contact becomes known after the oil has spread. That is why regulation 37 fixes four items with at least.

This article starts with the ships covered, takes the four items two at a time, and ends with the condition for combining plans and the extra requirement on large tankers.

The threshold matches the Oil Record Book and approval rests with the Administration

1 Every oil tanker of 150 gross tonnage and above and every ship other than an oil tanker of 400 gross tonnage and above shall carry on board a shipboard oil pollution emergency plan approved by the Administration.

There are two thresholds. Oil tankers from 150 gross tonnage, other ships from 400. They are the same thresholds as for Oil Record Book Part I. A ship that carries the book carries the plan.

There is one more condition: approved by the Administration. A plan drawn up by the company becomes a plan that may be carried only once the Administration has approved it. When the plan is amended the approval has to be revisited.

The plan follows the Organization’s guidelines and is written in the working language of the master and officers

2 Such a plan shall be prepared based on guidelines developed by the Organization and written in the working language of the master and officers. The plan shall consist at least of:

There are two standards for drafting. One is the guidelines developed by the Organization (IMO). The company does not set the frame of the plan from scratch. The other is language: the working language of the master and officers. Not the flag State’s language and not the company’s. The language the master and officers use at work on that ship.

When the master and officers change and the working language changes with them, the language of the plan has to follow. So this paragraph is tied to the crewing of the ship.

The first two items face outward

.1 the procedure to be followed by the master or other persons having charge of the ship to report an oil pollution incident, as required in article 8 and Protocol I of the present Convention, based on the guidelines developed by the Organization; .2 the list of authorities or persons to be contacted in the event of an oil pollution incident;

The first is the reporting procedure. It names who reports: the master or another person in charge of the ship. The basis for the report is article 8 and Protocol I of the Convention. The plan holds the order in which that report is made.

The second is the contact list. The authorities and persons to be contacted when an incident occurs. This list changes with the route. When the authorities at the ports of call change, the list has to change too. This is the part of the plan that ages first.

The third and fourth items work inside the ship

.3 a detailed description of the action to be taken immediately by persons on board to reduce or control the discharge of oil following the incident; and .4 the procedures and point of contact on the ship for co-ordinating shipboard action with national and local authorities in combating the pollution.

The third is immediate action. The words are detailed description. Not one line saying close the valve, but who does what and where. The purpose is twofold: to reduce or to control the discharge.

The fourth is coordination with authorities. When national and local authorities join the response, the plan says who on board is the point of contact and by what procedure the two sides are aligned. The third is what the ship does alone; the fourth is what the ship does with the authorities.

Item	Content	Direction
.1	Procedure for reporting the incident	Ship to outside
.2	List of authorities and persons to contact	Ship to outside
.3	Immediate action to reduce or control the discharge	Inside the ship
.4	Procedures and point of contact for coordinating with authorities	Between ship and authorities

A ship also subject to Annex II regulation 17 may combine the two plans into one

3 In the case of ships to which regulation 17 of Annex II of the present Convention also apply, such a plan may be combined with the shipboard marine pollution emergency plan for noxious liquid substances required under regulation 17 of Annex II of the present Convention. In this case, the title of such a plan shall be “Shipboard marine pollution emergency plan”.

A ship carrying noxious liquid substances also carries the plan under Annex II regulation 17. The two plans may be merged. The words are may be combined. Combining is optional.

If they are combined, the title is fixed: Shipboard marine pollution emergency plan. Kept separate, each plan uses its own title; combined, this title is used. An inspector reads from the title whether there is one plan or two.

Oil tankers of 5,000 tons deadweight or more need prompt access to shore-based calculation programs

4 All oil tankers of 5,000 tons deadweight or more shall have prompt access to computerized, shore-based damage stability and residual structural strength calculation programs.

Oil tankers carry one more condition. At 5,000 tons deadweight or more they must have prompt access to shore-based programs that calculate damage stability and residual structural strength. The text does not say the program has to be on board. It says the program ashore has to be reachable at once.

So this paragraph connects back to the contact list. Access becomes prompt only when the plan says whom to call to run the calculation.

Worth confirming

The passages above come from regulation 37 of the revised Annex I adopted by resolution MEPC.117(52). The Organization’s guidelines followed when drawing up the plan are a separate document and are not covered here. They are amended, so the current edition has to be checked.

What the report under article 8 and Protocol I of the Convention has to contain is not covered here either. What the plan under Annex II regulation 17 holds has to be read in that Annex. The procedure by which an Administration grants approval differs from flag to flag.

You can consult the cited source documents

These links lead to the official publishers of the documents discussed here. Match the edition and provisions cited in the article, and check subsequent amendments and flag-state implementation before applying them.

• IMO · MEPC.117(52)

Continue with the related operational guidance

• Oil Record Book Part I operations to be entered and the signature and retention rules (MARPOL Annex I Regulation 17)
• The conditions that open a machinery space oily mixture discharge and the ones that close it in special areas and the Antarctic (MARPOL Annex I Regulation 15)