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Marine Vetting and Audit Criteria

Manual for Tank Ships and Barges

Document No. GM-PRO-MA-005

Revision No. 7 Revision Date Feb. 29th, 2016


Marine Vetting and Audit Criteria Manual for Tank Ships and Barges
Revision No. 7
Contents
Record of Changes......................................................................................................................................... 5
1. Introduction .......................................................................................................................................... 6
2. Scope ..................................................................................................................................................... 6
2.1. Governed Vessels .......................................................................................................................... 6
2.2. Vessel Types .................................................................................................................................. 7
3. Abbreviations and Definitions..................................................................................................................... 7
4. Responsibilities .................................................................................................................................... 10
4.1. COP Commercial and/or Operational Entities ............................................................................. 10
4.2. Global Marine Assurance ............................................................................................................ 10
4.3. Vessel Owners/Operators ........................................................................................................... 10
5. Tank Ship Submittal Requirements ..................................................................................................... 11
6. Tank Ship Vetting Information ............................................................................................................ 11
6.1. Technical Operator and Vessel Performance History .................................................................. 12
6.2. Vessel Age and CAP Requirements .............................................................................................. 12
6.2.1. Oil Tankers ........................................................................................................................... 12
6.2.2. Gas Ships ............................................................................................................................. 12
6.2.3. New-Build Acceptance Process ........................................................................................... 12
6.3. Classification Society and Status Survey Reports ........................................................................ 13
6.3.1. Class Status Survey Reports................................................................................................. 14
6.4. P&I Club....................................................................................................................................... 14
6.5. Manning and Certification ........................................................................................................... 14
6.5.1. Oil Tankers ........................................................................................................................... 14
6.5.2. Gas Ships ............................................................................................................................. 14
6.6. Sire Inspection ............................................................................................................................. 15
6.6.1. Oil Tankers ........................................................................................................................... 15
6.6.2. Gas Ships ............................................................................................................................. 15
6.7. Vessel History .............................................................................................................................. 15
6.7.1. Port State Control Report .................................................................................................... 15
6.7.2. Casualty History ................................................................................................................... 15
6.8. Requirements for Marine Movements Involving Lightering (Vessel to Vessel Transfers) ........... 16
6.9. Requirements for Cargo Shipped Under Term/ Voyage or COA Contracts.................................. 16
6.9.1. Tanker Management Self-Assessment – Company and Operator ....................................... 16
6.9.2. Tanker Management Self-Assessment – Verification Audit ...................................................16
6.9.3. Vessel Age ........................................................................................................................... 17

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6.9.5. SIRE ...................................................................................................................................... 17
6.9.6. HSE Reporting...................................................................................................................... 17
6.9.7. Additional Required Actions ................................................................................................ 17
6.10. Requirements for Tankers Operating in DP Mode .................................................................. 18
6.10.1. DP ........................................................................................................................................ 18
6.10.2. FMEA ................................................................................................................................... 18
6.10.3. DP Trials............................................................................................................................... 18
6.10.4. Manning Requirements ....................................................................................................... 18
6.10.5. Required DP Documentation to Maintain Onboard Vessel ................................................. 18
7. Tug and Barge Submittal Requirements .............................................................................................. 19
8. Tug and Barge Vetting ......................................................................................................................... 19
8.1. Tug Boats ..................................................................................................................................... 19
8.2. Petroleum Barges ........................................................................................................................ 20
8.3. Operational and Integrity Management...................................................................................... 20
8.4. Vessel Age Requirements ............................................................................................................ 20
8.4.1. New Build Acceptance Process............................................................................................ 20
8.4.2. New Build Requirements ..................................................................................................... 20
8.4.3. Vessels Over 20 Years of Age............................................................................................... 21
8.5. Classification Societies................................................................................................................. 21
8.5.1. Non-IACS Classed Vessels .................................................................................................... 21
8.6. Protection and Indemnity (P&I) Club .......................................................................................... 22
8.7. Crewing and Certification ............................................................................................................ 22
8.8. Drug and Alcohol Policy ............................................................................................................... 22
8.9. Vessel Inspections ....................................................................................................................... 22
8.9.1. Tugs ..................................................................................................................................... 22
8.9.2. Petroleum Barges ................................................................................................................ 23
8.10. STS Transfer Operations .......................................................................................................... 23
8.10.1. Lightering Representative ................................................................................................... 23
8.11. Management Self Assessments ............................................................................................... 23
8.11.1. Verification Audits ............................................................................................................... 23
9. Technical Review ................................................................................................................................. 24
10. Vessel Exceptions ............................................................................................................................ 24
11. Flag State and US Sanctioned Countries.......................................................................................... 24
12. Compliance with Local and International Regulations .................................................................... 24
13. Voyage Route and Risk Mitigation................................................................................................... 25

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13.1. Piracy ....................................................................................................................................... 25
13.2. Terminals ................................................................................................................................. 25
14. Requirements for Terminal Approval .............................................................................................. 25
15. Company Owned and Operated Vessels ......................................................................................... 25
16. Acceptance and Rejection on Status Change .................................................................................. 26
17. Technical Hold and On Notice ......................................................................................................... 26
18. SIRE Inspection Process ............................................................................................................... 26
18.1. Communications ................................................................................................................. 26
18.2. Submitting Inspection Requests .............................................................................................. 26
18.3. Evaluation of Inspection Request ............................................................................................ 27
18.3.1. Rejection of Inspection Request .......................................................................................... 27
18.3.2. Acceptance of Inspection Request ...................................................................................... 27
18.4. Conduct of Inspection ............................................................................................................. 27
18.5. Cancellation of Inspection ....................................................................................................... 28
18.5.1. Cancellation of Inspection by Vessel’s Technical Operator ................................................. 28
18.5.2. Cancellation of Inspection by Inspection Company............................................................. 28
18.5.3. Close out of Inspection ........................................................................................................ 28

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Record of Changes
Revision Date Description of Changes Owner Approved by
8.0 02/01/2016 Document number changed from COP-UMA- Director, Manager,
GOV-005 to GM-PRO-MA-005. Marine Global
Gas Ship requirements added. Oil Tanker Assurance Marine
requirements updated. Integration Assurance
Barge and Tug requirements updated.
7.0 05/01/2012 Document name change due to Company split. Marine Manager,
Excellence Marine Ops
Advisor and
Assurance
6.0 10/01/2011 Updated and changed to one document. This Director, Manager
document combines two COP MRM publications: Vetting Marine Risk
Marine Vetting & Audit Criteria Process Summary Management
for Trade Floor and Marine Vetting & Audit
Criteria for Vessel Operators Rev 5.0. Added
Piracy Risk Assessment
Manager,
Director, Marine Risk
5.0 11/30/2009 Updated barge technical criteria Vetting Management
Manager,
Double Hull Criteria updated for US Director, Marine Risk
4.0 09/16/2009 carriers conference Vetting Management
Manager,
Director, Marine Risk
3.0 03/13/2009 Revision for posting through Intertanko publication Vetting Management
Manager,
Updated/edited for external sharing through Director, Marine Risk
2.0 06/2006 SIS link Vetting Management
Manager,
Director, Marine Risk
1.0 08/2003 Original Summary after corporate merger Vetting Management

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1. Introduction
ConocoPhillips (COP) is an exploration and production company utilizing marine equipment for the
movement of hydrocarbons globally. COP participates in several industry organization forums, such as
Oil Companies International Marine Forum (OCIMF) and Society of International Gas Tanker and
Terminal Operators (SIGTTO). COP incorporates the guidelines, r ecommendations and best practices
set forth by these industry forums and regulatory agencies in its vetting criteria.

The “Global Marine Vetting Standard” requires Global Marine Assurance Vetting approval for all Vessels
referenced in this manual, prior to the commencement of the charter party or applicable work under a
service agreement and/or for the full duration of any marine activities performed for COP.

The purpose of this document is to detail the requirements and procedures that will be used to
meet both vetting and audit requirements for Vessels used in the transport of bulk liquid petroleum
products.

The application of this document and associated processes will help ensure that the risks involved
in COP marine activities are being effectively managed, consistent with COP’s vision for safety, health,
environment, reliability and efficiency.

This document is not intended to be an all-inclusive list of requirements. Global Marine Assurance
maintains the right to request information that it deems necessary to make a vetting decision.

COP in partnership with certain other oil companies, owns and utilizes the internet based vetting
system known as SIS3 or the Ship Information System (SIS, found at www.SIS3ng.com) to store and
process technical information regarding Vessels. The SIS database allows certain information to be
shared amongst the Partner companies, thus reducing the workload and redundancy of requests to
the Technical Operators. Acceptance or non-acceptance of Vessels is not shared amongst the Partners
and such information remains private to each individual company.

COP also participates in and supports the OCIMF SIRE program. The scheduling of the SIRE
inspections is achieved through the SIS3 system.

2. Scope
2.1. Governed Vessels
Consistent with the scope of the Global Marine “Marine Vetting Standard,” these processes and
procedures shall be used to assess the safety and suitability of all Tankship Vessels which are described
below:
• All Vessels carrying COP owned bulk liquid commercial cargo (including Vessels carrying
part cargoes).
• All Vessels calling at a COP owned/operated/leased marine terminals for bulk liquid
commercial cargo.
• All Vessels calling at a COP leased terminal with COP titled or owned bulk liquid
commercial cargo, with the exception of vessels calling for COP FOB sold/COP DES

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purchased cargoes at third party terminals where COP leases tankage (unless otherwise
specifically required by contract).
• All Vessels calling at a COP owned/operated offshore field/installation carrying bulk liquid
hydrocarbon or chemical commercial cargoes.
• All Vessels chartered by or on behalf of COP with the purpose of carrying bulk liquid
hydrocarbon.
• All Vessels involved in a STS (ship to ship) transfer of a COP commercial cargo, including
both the discharge Vessel, receiving Vessel and STS service provider company.
• All Vessels carrying bulk liquid cargo for the purpose of bunkering COP owned Tank Ships
• All Vessels carry COP titled or owned bulk liquid and are bound for the United States that are
subject to US Customs requirements upon arrival.

2.2. Vessel Types


The following Vessel types are covered under the procedures in this manual:

• Crude oil tanker, product/chemical tanker


• Petroleum barges (articulated tug barge (ATB), self-propelled, non-self-propelled, etc.)
• Tugs used as propulsion for petroleum barges (tugs used for assist or emergencies are handled in
the “Marine Vetting and Audit Process Manual for Offshore Vessels”).
• Gas Ships, such as LPG & LNG carriers

3. Abbreviations and Definitions


AVRA Automated Voyage Risk Assessment

CAP Condition Assessment Program

CDI Chemical Distribution Institute

Class A recognized Classification Society that is a member or associate of the


International Association of Classification Societies (IACS)

Classification Society Private organizations which issue rules for the construction,
equipment, and maintenance of merchant ships

CMID Common Marine Inspection Document: A recognized offshore Vessel


inspection document that is managed by IMCA

COA Contract of Affreightment

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COD Certificate of Documentation

COI Certificate of Inspection

COP Approved Inspector An inspector that is either accredited by OCIMF to inspect offshore
vessels, or an inspector that has the competencies that match a profile
approved by the COP Manager of Global Marine Assurance

COP Entity Includes all persons or groups within COP; COP subsidiaries; any COP
(As defined for use strictly affiliated company or joint venture for which COP or one or more of its
within the confines of this subsidiaries serve as operator; or any sub-contractor that is hiring a
procedure) Vessel that will work in a COP operated area

COP Operational Entity Includes all COP business units or projects that engage in marine
activity
DP Dynamic positioning

DPO Dynamic positioning officer

FMEA Failure mode effects analysis

Gas Ship A Vessel that is designed primarily for the transport of LNG or LPG

GT Gross Tons

IACS International Association of Classification Societies

IMCA International Marine Contractors Association

New Build Vessel A New Build Vessel is a Vessel recently delivered which has no OCIMF
SIRE report and little operational history, or has not yet completed a
maiden discharge operation and/or the report for this operation has
not yet published.

Non-IACS Classed Vessel Vessels that are not registered with an IACS Class Society

OCIMF Oil Companies International Marine Forum

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OVID A recognized offshore Vessel inspection document (OVID)that is
managed by OCIMF
SIRE

The ship inspection report (SIRE) program is a tanker risk assessment


tool from OCIMF that consists of a database of up-to-date
information about Tank Ships and barges.
SQ

Ship questionnaire

STCW The “International Convention on


Standards of Training,
Certification and Watchkeeping
for Seafarers,” which sets
qualification standards for
masters, officers and watch
personnel on seagoing merchant
ships

Tank Ship A Vessel that is designed primarily for the transport of bulk liquid
petroleum products (oil tankers and Gas Ships)
Technical Operator The company designated by the Vessel owner or Vessel manager to
be responsible for the technical operation and technical
superintendancy of a Vessel.

Tanker Management Self-Assessment program instituted by OCIMF


TMSA

Valid Inspection An OVID inspection report that is less than 12 months old or SIRE that
Report(s) is less than 6 months old and was performed by a COP Approved
Inspector
- Variant type required is determined by Vessel type and the
scope of work
In certain circumstances, a CDI or a CMID inspection report may be
acceptable
- IMCA M149 (CMID)- Marine Vessels more than 500GT
- IMCA M189- Marine workboats less than 500GT

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Vessel
(As defined for use strictly All seaborne assets greater than 50GT, including but not limited to:
within the confines of this
procedure) - Tug/tow Vessels that may be used as propulsion for barges
- Barges used for transport of bulk liquid petroleum products
- Vessels used for the transport of bulk liquid petroleum products
- Vessels used for the transport of LNG or LPG

Vetting The Global Marine Assurance process for conducting a critical


evaluation of both the suitability and acceptability of marine
assets, Vessels, terminals, Technical Operators and service
providers for use by a COP Entity.

VPQ Vessel Particular Questionnaire

4. Responsibilities
4.1.COP Commercial and/or Operational Entities
• Nominate each required Vessel using Ship Information System (www.SIS3ng.com)
• Once vessel acceptance (normally via e-mail) has been received from Global Marine Assurance,
employ the Vessel consistent with the scope of work to be performed
• Require that all Vessels maintain a valid vessel acceptance status, as required by this document
• Follow the existing Vetting exception process (GM-PRO-MA-006)

4.2.Global Marine Assurance


• Provide Vetting coverage to all COP Entities on a 24/7 basis
• Review a Valid Inspection Report, along with any other information that has been submitted or
otherwise obtained for the nominated Vessel
• Engage other resources in Global Marine for engineering evaluation and technical review when
required
• Determine acceptance or rejection of each nominated Vessel consistent with COP guidelines
and standards
• Shall document and make available to Technical Operators the reason for and Vessel rejection
decision
• Maintain records of all Vessels nominated for Vetting
• Maintain a list of COP Approved Inspectors
• Conduct annual review of the COP Vetting and audit procedures

4.3.Vessel Owners/Operators
• Complete and update the VPQ in the OCIMF database system and/or supply any requested
information required by COP for the nominated vessel
• Complete and maintain a TMSA (which is also applicable to barges) as required
• Maintain the Vessel in the condition of which it was originally accepted

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• Maintain a Valid Inspection Report during the entire term of their contract with COP
• Notify COP of any changes or modifications to a COP contracted or sub-contracted Vessel
• Notify COP of any incidents to Vessel or crew that occur during the Vetting process or while on
charter to COP
• Provide all requested information in a timely matter respective to commercial subjects

5. Tank Ship Submittal Requirements


Prior to contracting, use, and/or periodically when under contract, all Tank Ships shall be nominated
by COP Commercial or Operational Entity into the Ship Information System (www.SIS3ng.com) website
for Vetting assessment by Global Marine Assurance. Only Vessels accepted by Global Marine
Assurance may be used to carry bulk liquid hydrocarbons or to call at COP terminals or installations.
Global Marine Assurance reserves the right to request additional information as required in order to
complete the review. Tank Ships are required to be vetted for each use.

Prior to approval Vessel Operators will be required to submit the following minimum
documentation:
• Completed SIS SQ with a date stamp not exceeding 30 days
• Updated Class status survey report with a date stamp not exceeding 30 days
• Latest port state control inspections records and closeout report of any deficiencies noted
• Open port state control findings from any port state control inspection
• Current officer matrix
• Vessel’s CAP certificates (if applicable)

6. Tank Ship Vetting Information


In determining whether a Tank Ship will be accepted for a marine movement or call to COP
marine terminal, the following minimum factors will be considered:
• Vessel particulars
• Vessel age
• Vessel owner information/Vessel performance history
• Classification Society
• P & I Club
• Manning and certification
• Drug and alcohol policy
• Review of port state control inspections
• Compliance with local and international conventions/regulation
• SIRE inspections
• Flag State
• Type of cargo
• Type of risk profile to COP
• Voyage route and risk mitigation actions (applicable if traversing areas subject to risk of
piracy)
• COP Technical Holds and On Notice messages

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6.1. Technical Operator and Vessel Performance History
COP will review Technical Operator and Vessel performance using the minimum following available
information.

• Completed COP SQ
• Valid SIRE inspection report / CDI report
• Class status survey report
• COP Inspection
• Port state control reports
• Casualty and detention history
• Marine terminal operational feedback
• TMSA
• International Chamber of Shipping (ICS) flag state performance
• COP “Restricted Party and Sanctioned Country Vessel Screening Process”

Additional information may be viewed or requested as determined by COP.

6.2.Vessel Age and CAP Requirements


6.2.1. Oil Tankers
The maximum age of oil tankers acceptable by COP is 20 years. Vessel’s age is not to exceed 20 years at
any point during a time or voyage charter. This applies to both the initial contract period as well as any
optional extensions.

Oil tankers that are 15 years of age or greater must be enrolled in an IACS member’s CAP. A minimum
CAP rating of 2 for hull, machinery and cargo system is required for approval. A CAP rating is not to
exceed 3 years (from first survey or per the reports validity date).

Oil tankers nominated for cargoes shipped under voyage/ term or COA contracts with the Vessel being
15 years old or greater will be subject to an additional technical review by Global Marine Engineering.

6.2.2. Gas Ships


The maximum age of Gas Ships acceptable by COP is 30 years. If operating under a voyage or time
charter a vessel’s maximum acceptable age is reduced and shall not exceed 25 years at any point during
the charter. This applies to both the initial contract period as well as any optional extensions.

Gas Ships that are greater than 15 years of age must be enrolled in an IACS CAP. A minimum CAP rating
of 2 is required for hull, machinery and cargo/containment system is required for approval.

Gas Ships nominated for cargoes shipped under voyage/ term or COA contracts with the Vessel being 15
years old or greater will be subject to an additional technical review by Global Marine Engineering.

6.2.3. New-Build Acceptance Process

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A New Build Vessel will be vetted using the “New Build Acceptance Process”, defined by the
requirements of Section 6.2.3.1 either in whole or part.

Any Vessel being considered for term charter within six (6) months of delivery from the shipyard may be
subject to the New Build Acceptance Process.

Elements of the New Build Acceptance Process may also be applied to a Vessel nominated for first load
or discharge upon completion of a shipyard period.

6.2.3.1. Required Documents


Technical Operators of a New Build Vessel being considered for business with COP will be required to
submit any or all of the below documents as determined by COP;

• Harmonized VPQ submitted to OCIMF SIRE


• SQ submitted to www.SIS3ng.com
• Vessel performance criteria: design and sea trials
• Any other pertinent information as applicable required by Global Marine Engineering,
taking into account intended contract type
• List of all waivers or dispensations granted by Class or flag state
• Confirmation of technical and operational charter party requirements with the Vessel
documentation (if applicable)
• List of drawings (if applicable)
• Approval history of drawings and manuals including owner, yard, Class and flag state
• Key drawings: general arrangement, deck arrangements including; mooring fittings and
contract specifications for the Vessel as delivered
• Additional drawings or documents may be requested to support the review process
• Technical Operator updated list of builder’s warranty items

During Construction and Delivery, COP may also request:


• List of outstanding items and schedule of test and trials, sea trials and delivery 3 months prior to
delivery
• List of outstanding items and schedule of test and trials, sea trials and delivery 2 months prior to
delivery
• List of outstanding items and schedule of test and trials, sea trials and delivery 1 month prior to
delivery; weekly thereafter until delivery
• A COP representative/inspector or marine advisor may be requested to conduct a pre-
inspection prior to delivery
• A COP SIRE inspection to be performed during first bunkering and/or first discharge

6.3. Classification Society and Survey Status Reports


COP will accept a Classification Society that is a member or associate of the IACS at the time of the
Vessel nomination. The list of current IACS members can be found at www.iacs.org.uk.

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6.3.1. Class Survey Status Reports
Submitted Class survey status reports shall be time stamped with a date that is less than 30 days from
the approval period. A Class survey status report should include the following details:
• Any conditions or recommendations of class
• Status of Class and statutory certificates
• Safety management deficiencies

6.4. P&I Club


Vessels shall be insured with a member of the International Group of P&I Clubs. P&I Clubs/insurers not
included on this list may be reviewed and accepted on a case-by-case basis.

Vessels shall carry P&I insurance coverage (pollution and other third party liabilities) which shall be no
less than the minimum required by the international/ national authorities for the trading area operated
or the minimum required by the COP Insurance Group, whichever is higher.

6.5. Manning and Certification


Technical Operators shall update the “Officer’s Experience Matrix” online on the OCIMF website. The
information entered should be valid for the proposed service being reviewed by COP. In alignment with
the STCW convention, the crew shall be able to communicate between themselves internally in a
common language, as well as be proficient in English for those with job tasks that involve
communicating with shore-based personnel, or the Vessel-shore interface.

Vessel officers will be required to have the minimum sea time requirements below

6.5.1. Oil Tankers


Master /Chief Officer
• 3 years minimum combined sea service in rank.
• 6 years minimum combined sea service on any type of tanker

6.5.2. Gas Ships

6.5.2.1. Master /Chief Officer


• 3 years minimum combined sea service in rank.
• 6 years minimum combined sea service on any type of tanker
• Master must have a minimum 1 year experience (sea time) as a senior officer on LNG or LPG (as
applicable)
• Chief Officer must have a minimum 1 year experience as an officer on watch (OOW) on LNG or LPG
(as applicable)

6.5.2.2. Chief Engineer/1st Assistant Engineer


• 3 years minimum combined sea service in rank.

6.5.2.3. Gas Engineer


Gas Engineers onboard LNG and LPG Vessels, with the exception of fully pressurized LPG, shall meet the
following requirements:
• 1 year minimum sea time on LNG and LPG Vessels
• Maintains a minimum Class 2 certificate of competency

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6.5.2.4. Sea Time Requirement Reduction
Reduction in sea time requirements required in Section 6.5.2.1(Gas Ship Master/ Chief Officer) to 2
years combined sea service in rank and 3 years combined on any type of Tank Ship will be accepted if
the following conditions are met.
• Master and Chief Officer have minimum five years each with current operator
• Master and Chief Officer have completed comprehensive training course for LNG following SIGTTO
guidelines
• All junior deck officers have a minimum sea time on LNG Vessels of 6 months
• Drug and alcohol policy

The Technical Operator shall certify that it has in effect a drug and alcohol policy, complying with OCIMF
“Guidelines for the Control of Drugs and Alcohol Onboard Ship”, unless not permitted by the flag state.

6.6.Sire Inspection
A valid SIRE or CDI report will be required on all Vessels. A report will be considered valid if the following
conditions are met:
• Published in the SIRE or CDI system
• Contains Technical Operator’s comments
• Takes place during either a load or discharge
• Has taken place in the last 6 months
• Was conducted under Vessel’s current Technical Operator or safety management system (SMS)
holder

6.6.1. Oil Tankers


The SIRE or CDI inspection must have been performed within the last 6 months with, at least one
discharge SIRE within the last 12 months.

6.6.2. Gas Ships


Shall have a valid SIRE or CDI inspection that has been performed within the last 6 months.

6.7.Vessel History
In order to review a nominated Vessel’s history, COP will require the minimum following documents:

6.7.1. Port State Control Report


Operators will be required to submit the Vessel’s most recent port state control inspection report. In
addition to:
• List of any outstanding port state inspection findings
• Timeline for closing any outstanding port state control findings

If a port state detention has occurred in the last 2 years, the Vessel’s Technical Operator will be required
to submit the following:
• Root cause analysis
• Corrective action taken
• Proof of acceptance by port state control

6.7.2. Casualty History


Technical Operators shall submit root cause analysis and corrective action reports for incidents that
occurred in the last 2 years. Including but not limited to:

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• Personal injury
• Pollution
• Allision/collision
• Fire/explosion
• Grounding
• Critical operation/ equipment failure
• Security breach

6.8. Requirements for Marine Movements Involving Lightering (Vessel


to Vessel Transfers)
In addition to all other applicable requirements, vessels and/or operators involved in lightering must
meet the following requirements;
• Vessel operator shall meet the guidelines of OCIMF STS recommendations or equivalent
• Overall capability of vessel and staff experience will be considered
• The STS operation must be performed with the support of a ConocoPhillips approved STS
Service Provider company
• All ships preforming a STS must be reviewed and accepted by Global Marine Assurance if any
COP titled cargo is transferred

For the purpose of vessels covered under section 6.8, STS operations do not include vessel bunkering,
barge to ship, or barge to barge operations. Requirements for operations involving transferring cargo
from barge to barge or barge to ship are covered in Section 8.10.

6.9. Requirements for Cargo Shipped Under Term/ Voyage or COA Contracts
All Vessels on contract are required to maintain an approved vetting status. In the event Global Marine
Assurance Vetting approval is withdrawn, operational activities must cease or may be limited to the
minimum activities deemed appropriate using procedures found in the “Vetting Exception Request
Process Manual” GM-PRO-MA-006. The use of an unapproved Vessel will be considered a COP non-
conformance. In addition to specific Vetting criteria, the requirements listed in Section 6.9 apply to all
Vessels operating on a term/ voyage or COA charter.

6.9.1. Tanker Management Self-Assessment – Company and Operator


Every Vessel owner/Technical Operator being considered for term/ voyage or COA charter work with
COP must participate in the TMSA program and self-attest to a minimum Level 2 rating, with the
intention of improvement in all areas.

6.9.2. Tanker Management Self-Assessment – Verification Audit


Any Vessel owner/Technical Operator of a Vessel being considered for term contract of 6 months or
more shall undergo a TMSA verification audit initiated by COP. If the charter exceeds a term contract of
more than 24 months, an additional audit may be conducted twice in any five year period.

Any Vessel owner/Technical Operator of a Vessel being considered for term contract of less than 6
months with potential to extend on a consecutive basis, shall undergo a TMSA verification audit initiated
by COP prior to the contract extension/renewal being approved.

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A COP verification audit shall verify all elements of the TMSA prior to the owner/operator acceptance
for term use; selected elements may be reviewed as required by the Manager of Global Marine
Assurance.

The reporting of this assessment shall be completed within 2 weeks of the audit’s last visit day, and shall
include a listing of all observations, as well as a comparison between the COP assessment and the
Technical Operator’s TMSA. The COP verification audit, reviewed and approved by the Manager of
Global Marine Assurance, shall be provided to the Technical Operator, as well documented internally for
approval/or other.

An audit may also be initiated at any time, including new business review, accident investigation, or if
COP records a negative trend of HSE statistics.

6.9.3. Vessel Age

6.9.3.1. Oil Tanker


Vessel’s age is not to exceed 20 years at any point during charter period. This applies to both the initial
contract period as well as any optional extensions.

Vessels greater than 15 years old shall be subject to an additional technical review by Global Marine
Engineering.

6.9.4. Gas Ship


Gas Ship’s age is not to exceed 25 years at any point during charter period. This applies to both the
initial contract period as well as any optional extensions.

Vessels greater than 15 years old shall be subject to an additional technical review by Global Marine
Engineering.

6.9.5. SIRE
A COP SIRE report is required for any Vessel to be approved for greater than a 6 month time charter.
Thereafter one SIRE is required every six months. A COP sponsored SIRE may be required.

6.9.6. HSE Reporting


Incidents, near incidents, accidents, equipment failures and other circumstances that might impact the
operation of the Vessel, shall be reported to Global Marine Assurance without unnecessary delay.
Details to be sent to TankerVetting@COP.com

6.9.7. Additional Required Actions


The following items should be completed at one month intervals during the contract period.
• Nominated for vetting approval in www.SIS3ng.com
• A SQ completed in www.SIS3ng.com
• An updated Class status survey report to be submitted
• Operators shall update the “Officer’s Experience Matrix” online on the OCIMF website.
• Operator shall submit any new port state control inspection reports along with a list of any open
port state control deficiencies

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6.10. Requirements for Tankers Operating in DP Mode
In addition to all other requirements for tankers, Vessels operating in DP Mode at any time during the
nominated period must meet the below requirements;

6.10.1. DP
All Vessels operating in DP mode will be certified by their Classification Society as DP class 2 or 3.

6.10.2. FMEA
All DP Vessels class 2 and 3 shall be required to have a DP FMEA report or equivalent. The original report
or latest revision must be less than five (5) years old to be considered valid as specified in IMO
MSC/circ/645. Reference should be made to IMCA M178 for FMEA management including guidance that
FMEA`s must be updated with any modifications to DP hardware or software. A systematic FMEA review
through life cycle and experience must be an ongoing process.

6.10.3. DP Trials
DP Trials shall be required on an annual basis (within 3 months prior or after the anniversary date of the
FMEA) or after any modifications to the DP system regardless of DP class (2 or 3). DP Annual trials and
FMEA proving trials are a system and operational test in accordance with IMCA M139 and 113. These
tests should be carried out annually by a Global Marine Assurance approved qualified third party. Class
is not defined as a third party.

6.10.4. Manning Requirements


All Vessels must have 2 DPO`s on the bridge at all times while conducting DP operations inside the 500
meter zone of COP Entity.
• One DPO must be certified with an Unlimited DP certificate
• The second DPO must have completed an approved simulator course (phase 3) of IMCA
Guidance document M 117 (“Training and Experience of Key DP Personnel”). DPO`s holding a
limited DP certificate satisfy this requirement as they have completed past phase 3.

All DPO`s must be capable of assuming responsibilities of navigable watch stander.

6.10.5. Required DP Documentation to Maintain Onboard Vessel


• Vessel FMEA or equivalent
• Annual DP trials/FMEA proving trials
• DP capability plots
• DP operations manual
• DP incident reports
• DP audits and inspections reports
• DP related drills and emergency response drills
• DP location and watch keeping checklists
• DP Familiarization and competency records
• DP maintenance
• DP critical spares list
• DP equipment servicing report

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7. Tug and Barge Submittal Requirements
Prior to contracting, use, and/or periodically when under contract, all petroleum barges and their
tugs used for propulsion shall be nominated into the Ship Information System (www.SIS3ng.com)
website for Vetting assessment by COP’ commercial or operations staff. Only Vessels accepted by
Global Marine Assurance may be used to carry bulk liquid hydrocarbons or to call at COP terminals or
installations. Global Marine Assurance reserves the right to request additional information as required in
order to complete the Vetting assessment.

8. Tug and Barge Vetting


In determining whether a tug and barge will be accepted for a marine movement or call to COP
marine terminal, the following minimum factors will be considered:
• Vessel particulars
• Vessel age
• Vessel owner information/Vessel performance history
• Classification Society
• P & I Club
• Crewing and certification
• Drug and alcohol policy
• Review of port state control inspections
• Compliance with local and international conventions/regulation
• SIRE inspections
• Flag state
• Type of cargo
• Type of risk profile to COP
• Voyage route and risk mitigation actions (applicable if traversing areas subject to risk of
piracy)
• COP Technical Holds and On Notice messages

8.1. Tug Boats


Prior to approval of a Tug boat used as propulsion for any petroleum barge (i.e. crude, lubes, or fuel) the
Technical Operator will be required to submit the minimum following information:
• Valid SIS SQ with a date stamp not exceeding 30 days
• Vessel Technical Specifications
• Updated Class status survey report with a date stamp not exceeding 30 days
• USCG COI if applicable
• USCG COD if applicable
• Latest port state control Inspections records and closeout report of any deficiencies noted
• Open port state control findings from any port state control inspection
• Current crew matrix
• Proof of insurance (including but not limited to)
o Hull & Machinery (H&M)
o P&I
o Employer’s liability
• Approved stability letter
• Drug and alcohol policy

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8.2.Petroleum Barges
Prior to approval of any petroleum barge (i.e. crude, lubes, or fuel) the Technical Operator will be
required to submit the minimum following information:
• Valid SIS SQ with a date stamp not exceeding 30 days
• Vessel technical specifications
• Updated Class status survey report with a date stamp not exceeding 30 days
• USCG COI if applicable
• USCG COD if applicable
• Proof of Insurance (including but not limited to)
o H&M
o P&I
o Employer’s liability
• Approved stability letter
• Drug and alcohol policy
• For US flagged barges confirmation that full perimeter spill rails have been installed.

8.3. Operational and Integrity Management


Tug and barges covered under this Section will be assessed to verify they are being managed, operated
and maintained to acceptable standards and Technical Operator has established a suitable safety
management system onboard. Data to support this can be obtained through Vessel inspection reports,
owner inspection reports, audits, casualty data or feedback from prior operations.

All tug and tank barges must be operated under a safety and/or quality management system structured
and adhering to practices identified in Standards such as International Safety Management Code (ISM)
if applicable or the American Waterways Operators (AWO) “Responsible Carrier Program” (RCP) or a
similar COP accepted program. Certification must remain valid at all times during contract.

If a barge participates in the USCG “Tank Barge Streamlined Inspection Program”, the Technical
Operator will comply with all USCG requirements associated with the “Tank Barge Streamlined
Inspection Program.”

8.4.Vessel Age Requirements


8.4.1. New Build Acceptance Process
A New Build Vessel will be vetted using the “New Build Acceptance Process”, defined by the
requirements of Section 8.4.2 either in whole or part.

Any Vessel being considered for term charter within six (6) months of delivery from the shipyard may be
subject to the “New Build Acceptance Process” in whole or part.

A New Build Vessel being nominated on the maiden voyage shall be evaluated on a case by case
basis.

8.4.2. New Build Requirements


For New Build Vessels the following additional documents and inspections may be required:

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• Global Marine Assurance approved representative attendance at sea trials
• Pre operational DP testing/drills
• Assessment of crew familiarization/competencies including emergency preparedness

8.4.3. Vessels Over 20 Years of Age


Any tug or barge that is over twenty (20) years of age prior to contracting, or that will become twenty
(20) years or older during the contract period (either in firm or optional years) shall be subject to the
following additional requirements:
• Additional assessment or inspection by Global Marine Assurance or its appointed representative
• Technical review by Global Marine Engineering

Vessels over thirty (30) years old will not be accepted without going through the COP “Vetting Exception
Process” set out in the “Vetting Exception Request Process Manual” GM-PRO-MA-006.

8.5.Classification Societies
All Vessels are required to be certified by a Classification Society.

COP will accept a Classification Society that is a member or associate of the IACS at the time of the
vessel nomination. The list of current IACS members can be found at www.iacs.org.uk.

8.5.1. Non-IACS Classed Vessels


Where a tug or barge does not meet the requirement of being classed with an IACS member society, it
will be subject to additional scrutiny and will require a Vetting exception, as detailed in Section 9.0 of
this manual. In order to be considered for a general Vetting exception, the following must be agreed to
by the Vessel owner/Technical Operator and completed both prior to and throughout the entire
contract period.

It is recognized that COP operates in certain markets where the number of available IACS Vessels is
limited. Where deemed appropriate by the Manager of Global Marine Assurance, additional Vetting
requirements may be implemented to increase the level of oversight. As a minimum, the additional
requirements should include Global Marine Assurance approval of all owner/Technical Operator audit
schedules and all vessel inspection schedules

8.5.1.1. Non-IACS Classed Vessels less than 5 years old


• Initial inspection prior to hiring to be done by Global Marine Assurance
• Required annual audit of the owner/Technical Operator by Global Marine Assurance
• SIRE, CMID or OVID inspection required every 12 months by a COP Approved Inspector

8.5.1.2. Non-IACS Classed Vessels more than 5 years old, but less than 20 years
old
• Initial inspection prior to hiring to be done by Global Marine Assurance
• Required annual audit of the owner/Technical Operator by Global Marine Assurance
• SIRE, CMID or OVID inspection required every 12 months by a COP Approved Inspector
• Review of dry docking records, machinery history/maintenance/overhaul records, tank
inspection/coating records by Global Marine Assurance

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• Annual physical inspection of the vessel by Global Marine Assurance, including safety system
testing (engine shutdowns, fire detection, fire pumps, alarms, etc.), which shall take place as
close as possible to the midway point between the required CMID, SIRE or OVID inspection

For Non-IACS Classed Vessels over 20 years old, additional specific requirements may be developed on a
case-by-case basis.

8.6.Protection and Indemnity (P&I) Club


Tug and barges shall be insured with a member of the International Group of P&I Clubs. Clubs not
included on this list may be reviewed and accepted on a case-by-case basis.

Vessels shall carry P&I insurance coverage (pollution and other third party liabilities) which shall be no
less than the minimum required by the international/ national authorities for the trading area operated
or the minimum required by the COP Insurance Group, whichever is higher.

8.7.Crewing and Certification


The current Global Marine Assurance requirements for crew competency are aligned with the STCW
Convention, international regulations, and industry best practices. Vessel owners/ Technical Operators
shall ensure:
• The vessel is manned according to its safe manning COI
• That all personnel are properly licensed for the position / rank that the crewmembers might
hold in regards to all International, STCW, or Regional licensing requirements
• That the crewmembers are qualified to operate the equipment for which they are responsible
• That all crewmembers will operate the vessel in a safe manner and maintain the ability to
respond to an emergency in a timely fashion
• The crew shall be able to communicate between themselves in a common language, as well as
be proficient in English (where required) for those with job tasks that involve communicating
with shore-based personnel, vessel to shore and/or STS

8.8.Drug and Alcohol Policy


The Technical Operator shall certify that it has an STCW acceptable Drug and alcohol policy in effect,
unless the Technical Operator is not permitted by the flag state to have such policy.

8.9.Vessel Inspections
All Vessels must maintain a current, valid, accepted SIRE or OVID report. COP defines a report as
“current” if it meets the below requirements;

8.9.1. Tugs
Tugs used for petroleum barge propulsion are to have an OVID or SIRE report less than 12 months old. If
SIRE inspection is to be used, the proper variant, as determined by Global Marine Assurance, must be
used.

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8.9.2. Petroleum Barges

8.9.2.1. Crude, Condensate and Certain Refined Products


All barges used for transporting petroleum products, other than those specified in 8.9.2.2, are to have
an acceptable SIRE report less than 6 months old.

8.9.2.2. Bunkers
All petroleum barges used to transfer bunkers to COP owned Vessels are to have an acceptable SIRE
report less than 12 months old.

8.10. STS Transfer Operations


Barge to barge cargo transfer operations or transfer of cargo between a Tank Ship and a barge do not
require the attendance of a COP Approved STS service provider. However, the Technical Operator will
be required to verify the following:

• Confirmation that the vendor has lightering procedures in place.


• A lightering representative may be required to attend as deemed necessary by Global
Marine Assurance

8.10.1. Lightering Representative


A lightering representative i s a direct representative of the person (individual, company, corporation,
association or partnership) conducting the lightering operations who serves as an on scene advisor to
each master/Technical Operator and person in charge. A Global Marine Advisor may also undertake
this role.

8.10.2. Bunkering
Barge to barge or barge to Tank Ship bunkering operations are not considered lightering operations at
this time.

8.11. Management Self Assessments


Every Technical Operator must participate in either TMSA or Offshore Vessel Management Self-
Assessment (OVMSA), with the clear intention of improvement in all areas.

8.11.1. Verification Audits


At least once every 3 years COP may conduct a verification audit. A COP verification audit shall verify all
elements of the TMSA, or OVMSA. Selected elements may be reviewed as required by the Manager of
Global Marine Assurance.

The reporting of this assessment shall be completed within 2 weeks of the audit’s last visit day, and shall
include a listing of all observations, as well as a comparison between the COP assessment and the
Technical Operator’s TMSA. The COP verification audit, reviewed and approved by the Manager of
Global Marine Assurance, shall be provided to the Technical Operator, as well documented internally for
approval/or other.

An audit may also be initiated at any time, including new business review, accident investigation, or if
COP records a negative trend of HSE statistics.

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9. Technical Review
A technical review will be required for any Vessel that has undergone a conversion, major modifications,
extensive repairs, that meets the applicable Vessel age requirements, or exceeds listed maximum age in
order to assess Vessel structural integrity. The following is a minimum list of documents that will be
required:

• Class status survey report


• Ultra-sonic thickness measurement (UTM) report if not included as part of survey report (must
be less than 5 years old)
• All Class Survey reports from present back to and including the most recent special survey
• Enhanced Survey Program Executive Hull Summary.
• Reports of latest repairs to main hull structures including tank coating/anode installation carried
out.
• Type of cargo containment system
• Last internal examination report and tightness test of cargo tanks
• Tank Ship's staff latest internal tank inspection reports for each cargo & ballast tank
• CAP assessment report
• Plan of tank layout and midship section

Additional documents may be requested as determined by COP Global Marine Engineering.

10. Vessel Exceptions


Any COP Entity seeking to use a Vessel covered by this manual that fails to meet all applicable
requirements must follow the procedures found in the “Vetting Exception Request Process Manual”
GM-PRO-MA-006. This includes any Vessel that cannot meet the requirements due to local cabotage
rules.

Any Tank Ship exceeding maximum age requirements that is nominated for a Vetting exception will
require:
• Technical review by Global Marine Engineering
• Meet CAP requirements listed in Section 6.2

11. Flag State and US Sanctioned Countries


Global Marine Assurance shall follow COP corporate compliance process regarding trade with flag state
and US sanctioned countries.

12. Compliance with Local and International Regulations


The Technical Operator must certify, through completion of the on-line SIS SQ Statement,
compliance with all Local and International Conventions and Regulations. Tank Ships trading
internationally must have a valid shipboard oil pollution emergency response plan (SOPEP/SMPEP). In
addition, Tank Ships trading to the United States must have a valid Vessel response plan (VRP)
accepted in accordance with all applicable United States laws and regulations. The VRP and SOPEP
may be incorporated into one document.

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13. Voyage Route and Risk Mitigation
13.1. Piracy
Vessels operating under contract to COP (other than COP FOB sales) that are planning to
traverse areas subject to risk of piracy must have in place sufficient anti-piracy operational plans and
countermeasures in accordance with current best management practices for piracy as per OCIMF
guidelines, flag state directives, and Vessel owner/Technical Operator’s applicable insurance
provider’s directives in order to mitigate the risk from piracy.
COP utilizes the BIMCO AVRA in order to ensure that individual voyage risks due to piracy are
evaluated against the most detailed and timely information possible.
Vessels traversing areas subject to piracy risk are expected to submit a current AVRA report, complete
an AVRA information form, or complete a detailed high risk assessment report for the V essel’s anti-
piracy practices and route, and submit to COP for review.

Vessels with risk assessments scores or results above and acceptable level as determined by the COP
Vetting team may be either rejected for that voyage, or the Technical Operator may revise its available
anti-piracy measures and update the AVRA risk assessment to provide additional Best Management
practices and counter-measures in order to lower the risk assessment score to an acceptable level prior
to entering areas subject to risk of piracy.

13.2. Terminals
When Vessels are nominated for contract to COP (other than COP FOB sales) to call at COP non-
operated terminals, Global Marine Assurance shall require Terminal information such as MTMSA in
order to measure risk exposure. Where Global Marine Assurance determines there is an elevated safety
or security risk, Global Marine Assurance shall involve COP Corporate Insurance, Legal, Senior
Management, and Compliance Experts to further evaluate use of the Vessel prior to any contracts being
put in place.

14. Requirements for Terminal Approval


Each COP terminal and installation has site specific operating guidelines and policies. In some cases these
policies require a Vessel calling at the terminal or installation to have terminal approval in addition to
Global Marine Assurance approval. In these cases, data submitted to Global Marine Assurance for the
purpose of Vetting will be made available via the SIS website to the terminal or installation
representative. If the representative rejects a Vessel it shall be automatically rejected by Global Marine
Assurance.

15. Company Owned and Operated Vessels


Vessels that are owned and directly operated by COP will be operated using COP’s HSE Standards and
Governances and will not require Global Marine Assurance Vetting approval. Global Marine Assurance
will provide assistance as needed in meeting the HSE standards and with SIRE and TMSA reviews.

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16. Acceptance and Rejection on Status Change
Vessel Vetting acceptance may become invalid with any change of ownership, Classification Society, P&I
Club, technical or operational management, or due to significant technical or procedural changes on
board the Vessel, or defects that may be deemed to affect meeting the designated factors.

When a casualty, incident, port state detention, unsatisfactory report from a marine terminal, or any
other factor negatively impacts COP’ ability to use the Vessel while under contract, Global Marine
Assurance reserves the right to withdraw Vetting acceptance.

17. Technical Hold and On Notice


In certain circumstances COP will place a Vessel and/or Technical Operator either “Technical Hold or “On
Notice”.
Definitions:

“On Notice” A warning given by COP to the Technical Operator due to concern caused
by negative operational or HSE trends or a one-off event; this is generally
used to notify the Technical Operator and assure corrective and
preventative actions are taken.

“Technical Hold” A temporary rejection given by COP of a Vessel(s) and/or Technical Operator
for continued use of their fleet, due to an extraordinary event or significant
negative trends or cause. A Technical Hold is effective until corrective actions
and/or answers acceptable to COP Assurance and Vetting are received and
deemed satisfactory by the Manager Global Marine Assurance.

In the event a Vessel nominated for COP service is deemed unacceptable or below standard on more
than one occasion, a COP SIRE inspection may be warranted. If the results of this inspection indicate
no improvement to the Vessel’s status, the Vessel may be placed ‘on Technical Hold’ and will require a
COP re-inspection.

However, the Vessel may not be eligible for re-inspection until after 3 months from the date of original
inspection. This period of time is necessary in order to allow the Technical Operator and staff sufficient
time to develop, implement and verify the effectiveness of corrective actions taken.

18. SIRE Inspection Process


The following procedure and guidelines applies to the SIRE inspections of Tank Ships requested by
Technical Operator or as required by COP.

18.1. Communications
All correspondence related to conducting SIRE inspections shall be done using the dedicated email
address of VesselInspection@COP.com .

18.2. Submitting Inspection Requests


Technical Operators requiring a COP’ SIRE inspections shall submit all requests online at
www.SIS3ng.com keeping in mind the following

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• The inspection request shall be submitted a minimum of 4 working days prior to the desired
inspection date in order to allow for logistical arrangements.
• All incurred expenses will be invoiced at cost to the Technical Operator when the Technical
Operator has canceled any requested inspection
• Upon successful submission of a request, the Technical Operator shall receive an automated
email acknowledging the successful submission.
• In certain, rare, circumstances where a Technical Operator is unable to complete an online
submission a request may be submitted via email using the VesselInspection@COP.com address.

18.3. Evaluation of Inspection Request


Global Marine Assurance will evaluate all inspection requests using OCIMF and COP’s guidelines.

18.3.1. Rejection of Inspection Request


Generally, Vessel inspection request will not be accepted if:
• Vessel does not meet COP hull and age criteria
• Vessel or Vessels’ Technical Operator is considered unsuitable for COP business
• Concerns regarding possible ethics or sanction compliance issues
• Inspection location is in a sensitive area

18.3.2. Acceptance of Inspection Request


For Vessels with inspections less than 3 months old the following will apply.

18.3.2.1. Current SIRE Inspection 1-3 Months Old


Inspection requests for Vessels whose SIRE is between 1-3 months old may be considered if:
• COP business need
• Last SIRE was conducted during idle or loading operation and is the only one in previous 6
months
• Technical Operator requests a new inspection upon completion of corrective actions from
previous unsatisfactory SIRE
• Deemed justifiable by Manager of Global Marine Assurance

18.3.2.2. Current SIRE Less Than 1 Month Old


Inspection request for Vessels whose last SIRE is less than 1 month old may be considered if:
• COP business needs
• New-build Vessel whose last SIRE was conducted during idle or loading operation
• Deemed justifiable by the Manager of Global Marine Assurance

18.4. Conduct of Inspection


COP will provide the Vessel’s Technical Operator with the appointed inspection company contact
information. The Technical Operator shall contact the inspection company to arrange inspection specifics.

Upon completion of inspection, the SIRE Inspector shall provide a list of observations to the master of
the Vessel.

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18.5. Cancellation of Inspection
18.5.1. Cancellation of Inspection by Vessel’s Technical Operator
If an inspection is canceled, the Technical Operator must cancel this inspection in SIS3ng
(www.SIS3ng.com). In addition, the Technical Operator must advise concerned parties of
cancellation (including Inspection Company) via email correspondence.

COP will advise the Technical Operator of applicable cancellation charges.

Note: A delayed or postponed inspection due to berthing schedule is not considered a cancellation.

18.5.2. Cancellation of Inspection by Inspection Company


If due to unavoidable circumstances, the assigned inspection company is unable to inspect the Vessel,
the inspection company shall notify concerned parties (including COP) so alternate arrangements may
be made.

Where possible, COP will attempt to re-assign the inspection to another Inspection company.

COP will advise the Vessel’s Technical Operator if alternate arrangements are unavailable. The
inspection will be deemed cancelled.

18.5.3. Close out of Inspection


Upon completion of the SIRE inspection, Technical Operators shall utilize the OCIMF website to provide
responses to the Inspector’s observations.

Global Marine Assurance shall review the findings/responses and will contact the Technical Operator
should any additional information be required.
Once the review is complete and the all information related to the Inspector’s finding has been received
and approved by Global Marine Assurance, a closeout letter shall be sent to the Technical Operator.

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