REPUBLIC OF Marine Guideline
THE MARSHALL ISLANDS
No. 2-13-8
MARITIME ADMINISTRATOR
Jan/2023
TO: ALL SHIPOWNERS, OPERATORS, MASTERS AND OFFICERS OF
MERCHANT SHIPS, AND RECOGNIZED ORGANIZATIONS
SUBJECT: Application of MARPOL, Annex II to Offshore Support Vessels
References: (a) MARPOL Convention, International Convention for the Prevention of
Pollution from Ships, Consolidated Edition 2022
(b) IBC Code, International Code for the Construction and Equipment of Ships
Carrying Dangerous Chemicals in Bulk, 2020 Edition
(c) 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offshore support vessels, adopted 19 October 1989, as amended (superseded
by A.1122(30))
(d) IMO Resolution A.1122(30), Code for the transport and handling of
hazardous and noxious liquid substances in bulk on offshore support vessels
(OSV Chemical Code), adopted 6 December 2017
(e) IMO Circular MEPC.2/Circ.28, Provisional categorization of liquid
substances in accordance with MARPOL Annex II and the IBC Code, issued
1 December 2022
PURPOSE
This Guideline explains how Offshore Support Vessels (OSVs) certified in accordance with IMO
Resolution A.673(16) may meet the requirements to transport and handle hazardous and liquid
substances in bulk. This revision incorporates MEPC.2/Circ.28, and supersedes Rev. Jul/2022.
APPLICABILITY
This Guideline applies to OSVs constructed before 1 July 2018 that are transporting and handling
hazardous cargoes.
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Inquiries concerning the subject of this Guideline should be directed to the Republic of the Marshall Islands Maritime Administrator, c/o
Marshall Islands Maritime and Corporate Administrators, Inc., 11495 Commerce Park Drive, Reston, VA 20191-1506 USA. The most
current version of all Republic of the Marshall Islands Marine Guidelines may be found at www.register-iri.com.
MI-03, Rev. Apr/2016
BACKGROUND
IBC Code
The IBC Code amendments in IMO Resolution MEPC.318(74)1 entered into force on 1 January
2021. They imposed revised, and in many cases, stricter carriage requirements for products listed
in IBC Code Chapter 17 and in MEPC.2/Circ.28. This created an issue for those OSVs:
• with keels laid or were at a similar stage of construction on or after 19 April 1990, and
before 1 July 2018; and
• that carry a Certificate of Fitness for the carriage of cargoes listed in Appendix 1 of IMO
Resolution A.673(16).
Many products previously assigned a pollution hazard (P) were reassigned to safety hazard (S)
and, in some cases, they were categorized as toxic products. Some product names also changed.
To allow for full compliance with the new requirements, the Administrator provided for a
transition period in accordance with MARPOL Annex II/ 4.4.1. This transition period expired 31
December 2021.
As a result, OSVs certified in accordance with IMO Resolution A.673(16) are no longer permitted
to carry many of the products listed in Appendix 1 of that resolution. They are permitted to carry
only:
• products which for safety reasons may be assigned for carriage on a type 3 ship, as defined
in the IBC Code, and which are not required to meet the requirements for toxic products in
section 15.12 of that Code;
• noxious liquid substances which would be permitted for carriage on a type 3 ship; and
• flammable liquids.
To carry a broader range of the products in IBC Chapter 17 and MEPC.2/Circ.28, an OSV must
now comply fully with either the IBC Code or the OSV Chemical Code.
OSV Chemical Code
The OSV Chemical Code, which superseded IMO Resolution A.673(16), is applicable to OSVs
with keels laid on or after 1 July 2018, or were at a similar stage of construction. Section 1.1.9
permits the carriage of the following products:
• those listed in chapters 17 or 18 of the IBC Code and the latest edition of the
MEPC.2/Circ.28 and their related references to chapters 15 and 19; or
• oil or water-based mud containing mixtures of products listed in chapters 17 and 18 of the
IBC Code and the MEPC.2/Circ.28; or
1. 2019 Amendments to the International Code for the Construction and Equipment of Ships Carrying Dangerous
Chemicals in Bulk.
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• liquid carbon dioxide (high purity and reclaimed quality) and liquid nitrogen; or
• contaminated backloads.
GUIDANCE
1.0 OSVs with keels laid before 1 July 2018 can choose to:
1.1 comply fully with the OSV Chemical Code; or
1.2 be restricted to carrying a revised products list under IMO Resolution A.673(16) as
indicated in a newly issued Certificate of Fitness.
2.0 Shipowners and operators of A.673(16) compliant OSVs are advised to:
2.1 contact the relevant coastal State authority to discuss the requirements for operating
in its jurisdiction;
2.2 consult their Class Society for vessel-specific requirements; and
2.3 immediately implement the training in IMO Resolution A.1122(30).
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