Guidelines for the Development of SOPEP

 The objective of SOPEP:

1. The primary objective of the plan is to stop or minimize oil outflow when there is damage to the ship or when there is an operational spill that occurred more than the quantity than the permitted rate under the MARPOL Convention.
2. Shipboard Oil Pollution Emergency plan shall be prepared based on guidelines developed by the Organization and written in the working language of the Masters and Officers.  
3. The plan shall consist of the following:

• The procedure to be followed by the Master or other persons having charge of the ship to report an oil pollution incident is based on the guidelines developed by the Organization.
  

• The list of Authorities or persons to be contacted in the event of an oil pollution incident.
• 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.
• The procedures and point of contact on the ship for coordinating shipboard action with national and local authorities in combating the pollution.

Mandatory Provisions of SOPEP:

1. The requirement of the SOPEP plan is to ensure that coastal States are informed without delay of any incident giving rise to pollution, or threat of pollution, of the marine environment, as well as of assistance and salvage measures, so that appropriate action may be taken. 
2. When required - The Plan should provide clear, concise guidance to enable the master to determine when 'a report' to the coastal State is required. 
3. It depends on the actual discharge and the probable discharge of Oil.
4. Actual discharge - A report to the nearest coastal State is required whenever there is:
• A discharge of oil above the permitted level for whatever reason including those to secure the safety of the ship or saving life at sea.
• A discharge during the operation of the ship of oil above the quantity or instantaneous rate permitted under the present Convention.
5. Probable discharge - The Plan should give the master guide to evaluate  the situation which, though not involving an actual discharge, would qualify as a probable discharge and thus require a report. In judging whether there is such a probability and whether the report should be made, the following factors, as a minimum should be taken into account:
• The nature of the damage, failure or breakdown of the ship, machinery or equipment
• Ship location and proximity to land or other navigational hazards;
• Weather, tide, current and sea state
• Traffic density
6. It is impracticable to lay down precise definitions of all types of situations involving probable discharge which would warrant an obligation to report. 
7. As a general guideline, the master should make a report in cases of:
• Damage, failure or breakdown which affects the safety of ships; examples of such situations are collision, grounding, fire, explosion, structural failure, flooding, cargo shifting.
• Failure or breakdown of machinery or equipment which results in impairment of the safety of navigation; examples of such incidents are failure or breakdown of steering gear, propulsion, electrical generating system, essential ship-borne navigational aids. 

List of Persons to be contacted:

1. The ship involved in a pollution incident will have to communicate with both coastal State or port contacts and ship interest contacts.
2. When compiling contact lists, due account must be taken of the need to provide 24-hour contact information and to provide alternates to the designated contact. 
3. These details must be routinely updated to take account of personnel changes and changes in telephone, telex, and telefax numbers. 
4. Clear guidance should also be provided regarding the preferred means of communication (telephone, telex, telefax, etc.). 

Coastal State Contacts:

1. To expedite response and minimize damage from a pollution incident, appropriate coastal States must be notified without delay.
2. This process is begun with the initial report as required by the Convention.
3. The Plan should include the list of agencies or officials of administrations responsible for receiving and processing reports as developed and updated by the Organization.
4. In the absence of a listed focal point, or should any undue delay be experienced in contacting the responsible authority by direct means, the master should be advised to contact the nearest coastal radio station, designated ship movement reporting station or rescue coordination centre (RCC) by the quickest available means.

Port Contacts:

1. For ships in port, notification of local agencies will speed response.
2. The variety of trades in which ships engage makes it impractical to specify in these Guidelines a definitive approach to listing these agencies in the Plan. 
3.  Information on regularly visited ports should be included as an appendix to the Plan. 
4. Where this is not feasible, the Plan should require the master to obtain details concerning local reporting procedures upon arriving in port. 

Ship Interest Contacts:

1. The plan should provide details of all parties with an interest in the ship who are to be advised in the event of an incident.
2. This information should be provided in the form of a contact list.
3. When compiling such lists, it should be remembered that in the event of a serious incident, the ship's personnel will be fully engaged in saving life and taking steps to control and minimize the effects of the casualty.
4. The procedure will vary between companies but it is important that the Plan clearly specifies who will be responsible for informing the various interested parties such as cargo owners, insurers and salvage interests.
5. It is also essential that both the ship's Plan and its company's shoreside Plan are co-ordinated to guarantee that all parties having an interest are advised and to avoid duplication of reports. 

Steps to Control Discharge:

1. Ship personnel will almost always be in the best position to take quick action to mitigate or control the discharge of oil from their ship. 
2. The Plan should provide the master with clear guidance on how to accomplish this for a variety of situations. 
3. The Plan should not only outline action to be taken but should also identify who on board is responsible so that confusion during an emergency can be avoided. 
4. The Plan should outline the procedures for safe removal of oil spilt and contained on deck.
5. In order to have the necessary information available to respond to the situations certain plans, drawings and ship-specific details such as a layout of a general arrangement plan, a tank plan, etc. should be appended.
6. The plan should show where the current cargo, bunker and ballast information, including quantities and specifications, is available. 
7. As a minimum, the Plan should provide the master with guidance to address the following: 
1. Operational spills
2. Spills resulting from casualties

Operational Spills:

• The Plan should outline the procedures for safe removal of oil spilt and contained on deck. 

• This may be through the use of on-board resources or by hiring a clean-up company. 

• In either case, the Plan should provide guidance to ensure proper disposal of removed oil and clean-up materials. 

• The spill that occurred can be due to pipe leakage, Tank overflow and Hull leakage.

Spills resulting from casualties:

• The Plan should include various checklists or other means which will ensure that the master considers all appropriate factors when addressing the specific casualty.

• These checklists must be tailored to the specific ship and to the specific product or product types.

• In addition to the checklists, specific personnel assignments for anticipated tasks must be identified. 

• Personnel responsibilities are identified regarding existing fire control plans and muster lists.

• The following are examples of casualties that should be considered:

1. Grounding 
2. Fire/explosion
3. Collision
4. Hull Failure
5. Excessive list
6. Containment system failure
7. Submerged/foundered
8. Wrecked/stranded
9. Hazardous vapour release

                In addition to the checklists and personnel duty assignments, the Plan should provide the master with guidance concerning priority actions, stability and stress considerations, lightening and mitigating activities. 

Priority Actions:

• The master's priority will be to ensure the safety of personnel and the ship and to take action to prevent escalation of the incident.

• In casualties involving spills, immediate consideration should be given to measures aimed at preventing fire, personnel exposure to toxic vapours, and explosion, such as altering course so that the ship is upwind of the spilt cargo, shutting down non-essential air intakes, etc. 

• If the ship is aground, and cannot therefore manoeuvre, all possible sources of ignition should be eliminated and action should be taken to prevent toxic vapours or flammable vapours from entering accommodation and engine-room spaces.

• When it is possible to manoeuvre, the master, in conjunction with the appropriate shore authorities may consider moving the ship to a more suitable location in order, for example, to facilitate emergency repair work or lightening operations, or to reduce the threat posed to any particularly sensitive shoreline areas. Such manoeuvring may be subject to coastal State jurisdiction. 

• Before considering remedial action, the master will need to obtain detailed information on the damage sustained by the ship. 

• A visual inspection should be carried out and all cargo tanks, bunker tanks, and other compartments should be sounded. 

• Due regard should be paid to the indiscriminate opening of ullage plugs or sighting ports, especially when the ship is aground, as loss of buoyancy could result. 

• Having assessed the damage sustained by the ship, the master will be in a position to decide what action should be taken to prevent or minimize further spillage. 

• When bottom damage is sustained, hydrostatic balance will be achieved fairly rapidly, especially if the damage is severe, in which case the time available for preventive action will often be limited. 

• When significant side damage is sustained in the way of oil tanks, cargo or bunkers will be released fairly rapidly until the hydrostatic balance is achieved and the rate of release will then reduce and be governed by the rate at which oil is displaced by water flowing in under the oil. 

• When the damage is fairly limited and restricted, For example, to one or two compartments, consideration may be given to transferring oil internally from damaged to intact tanks. 

Stability and Strength Considerations:

• Great care in casualty response must be taken to consider stability and strength when taking actions to mitigate the spillage of oil or to free the ship if aground. 

• The Plan should provide the master with detailed guidance to ensure that these aspects are properly considered. 

• Nothing in this section shall be interrupted as creating a requirement for damage stability plans or calculations beyond those required by relevant international conventions. 

• Internal transfers should be undertaken only with a full appreciation of the likely impact on the ship's overall longitudinal strength and stability. 

• When the damage sustained is extensive, the impact of internal transfers on stress and stability may be impossible for the ship to assess. 

• Contact may have to be made with the owner or operator or other entity in order that information can be provided so that damage stability and damage longitudinal strength assessments maybe made.

• The plan should clearly indicate who the master should contact to gain access to these facilities.

Lightening:

• Should the ship sustain extensive structural damage, it may be necessary to transfer all or part of the cargo to another ship. 

• The Plan should provide guidance on procedures to be followed for ship-to-ship transfer of cargo. 

•  Reference may be made in the Plan to existing company guides. 

• A copy of such company procedures for ship-to-ship transfer operations should be kept with the Plan. 

• The Plan should address the need for co-ordinating this activity with the coastal State, as such operation may be subject to its jurisdiction. 

Mitigating Activities:

• When the safety of both the ship and personnel has been addressed, the master can initiate mitigating activities according to the guidance given by the plan.

• The plan should address the following:

1. Assessments and monitoring requirements
2. Personnel protection issues such as
1. Protective equipment
2. Threats to health and safety
3. Containment and other resources techniques (e.g. dispersing, absorbing)
4. Isolation procedures
5. Decontamination of personnel
6. Disposal of removed oil and clean-up materials

Non-Mandatory Provisions:

• In addition to the provisions required by Regulation 37 of MARPOL Annex I of the Convention, local requirements, insurance company, or owner/operator policies, etc., may dictate that other guidance be provided in the Plan. 

• These topics may include the provision of diagrams and drawings, ship-carried response equipment, public affairs, record-keeping, and reference materials. 

Plans and Diagrams:

• In addition to the plans required by the provisions, other details concerning the ship's design and construction may be appended to the Plan or their location identified.

Response Equipment:

• Some ships may carry onboard equipment to assist in pollution response. The type and quantity of this equipment may vary widely. 

• The Plan should indicate an inventory of such equipment if carried. 

• The Plan should also provide directions for safe use and guidelines to assist the master in determining when such use is warranted. 

• Care should be exercised to ensure that the use of such equipment by the crew is practical and consistent with safety considerations. 

• When such equipment is carried, the Plan should establish personnel responsibilities for its deployment, oversight, and maintenance. 

• To ensure safe and effective use of such equipment, the Plan should also provide for crew training in the use of it. 

• The Plan should include a provision that no chemical agent should be used for response to pollution on the sea without authorization of the appropriate coastal State and that such authorization should also be requested, when required, for use of containment. 

Shoreside Spill Response coordinator or Qualified Individual:

• Guidance for the master for requesting and coordinating initial response actions with the person responsible for mobilizing shoreside response personnel and equipment.

• Some coastal states require ships to have contracts with "response contractors" when ships enter into such States' ports. 

• When ships sail toward such States, it is recommended that response resources (personnel and equipment) and capabilities are identified in advance for each potential port State.

Public affairs:

• The owners may want to include in the Plan guidance for the master in dealing with the distribution of information to the news media.

• This guidance should be fashioned to reduce the burden on ship's personnel already busy with the emergency at hand.

Record-keeping:

• As with any other incident that will eventually involve liability, compensation and reimbursement issues, the owner may want to include in the Plan guidance on keeping appropriate records of the pollution incident. 

• Apart from detailing all actions taken on board, records might include communications with outside authorities, owners, and other parties, as well as a brief summary of decisions and information passed and received.

• Guidance on the collection of samples of spilt oil, as well as oil carried on board, may also be provided.

Plan Review:

• Regular review of the Plan by the owner, operator or master is recommended to ensure that the specific information contained therein is current.

• A feedback system should be employed which will allow quick capture of changing information and incorporation of it into the Plan.

• This feedback system should include the following:

• Periodic review - The Plan should be reviewed by the owner or operator at least yearly to capture changes in local law or policy, contact names and numbers, ship characteristics, or company policy
• Event review: after any use of the Plan in response to an incident, its effectiveness should be evaluated by the owner or operator and modifications made accordingly.

Plan testing: 

• The Plan will be of little value if it is not made familiar to the personnel who will use it. 

• Regular exercises will ensure that the Plan functions as expected and that the contacts and communications specified are accurate. 

• Such exercises may be held in conjunction with other shipboard exercises and appropriately logged. 

• Where ships carry response equipment, hands-on experience with it by crew members will greatly enhance safety and effectiveness in an emergency situation. 

• Procedures for training and exercise maybe defined.

Salvage:

• The plan should contain information on what the crew's responsibilities are in a casualty where a vessel is partially or fully disabled and what constitutes dangerous conditions.

• A decision process should be outlined in the plan that will aid the master in determining when salvage assistance should be obtained. 

• The decision process should include, but not be limited to the following:

1. Nearest land or hazard to navigation
2. The vessel's set and drift
3. Location and time of impact with hazard based on vessel's set and drift
4. Estimated time of casualty repair; and
5. Determination of the nearest capable assistance and its response time (i.e. or tug assistance, the time it will take to get on scene and secure the tow). When a casualty occurs to a vessel underway that reduces its manoeuvrability, the master needs to determine his window of opportunity considering the response time of assistance, regardless of the estimated time of repair. It would not be prudent to hesitate in calling for assistance when the time needed to repair something goes beyond the window of opportunity. 

Summary Flowchart of SOPEP Plan:

Reference: IMO Publications & Documents - Guidelines - SOPEP - Guidelines for the Development of SOPEP