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DOT 2001 Web Site
A Publication of the ABS Project Development Team

IMO SCRUTINIZES FPSOs, FSUs


IMO regulatory deliberations on FPSOs could have an ultimate impact on how rapidly and fully the world’s deepwater oil reserves are developed.


"This issue may have important economic consequences for the operation of FPSOs and FSUs."

Malcolm Sharples, Vice President, ABS Offshore


Debate centers on the extent to which FPSOs and FSOs should be treated as tankers.



s floating offshore installations take on an increasing role in the world’s oil and gas production,
the use of FPSOs and FSUs could be significantly affected by International Maritime Organization (IMO) regulations under MARPOL* Annex I.

"The regulatory debate centers on the extent to which FPSOs and FSUs should be treated as tankers under Annex I," says Malcolm Sharples, Vice President, ABS Offshore.

Although the IMO review could take several years, Sharples says, "This issue may have important economic consequences for the operation of FPSOs and FSUs - as well as influencing their design.

"It could also affect owners' options on whether to convert existing units into FPSOs and FSUs or build new ones. This could influence how rapidly and fully the oil industry can develop the world's deepwater reserves."

ABS is actively involved in the regulatory dialogue, providing technical advisors to national delegations at the IMO subcommittee on Bulk Liquids and Gases.

In addition, ABS participates in industry- and government-level discussion forums on the Annex I issues and is further involved through the International Association of Classification Societies.

FPSOs and FSUs are subject to Annex I, which currently regulates discharges from machinery space bilges. FPSOs that are self propelled are also covered by SOLAS.**

Historically, these units have generally been treated as tankers under Annex I – in line with interpretations developed at IMO – while having certain exemptions allowed by the flag and coastal states involved in each project.

An important issue under discussion is whether Annex I provisions applicable to tankers – such as rules on tank washing, tank sludge control, limits on hypothetical oil outflow in the event of damage, and damage stability – should also be applied to FPSOs and FSUs.

Oil industry representatives generally advocate retaining the Annex I provisions regulating discharges from machinery space bilges, but leaving all other regulation to the relevant coastal state authorities.

Some coastal states have robust rules covering FPSOs and FSUs that equal or surpass anything now under consideration by IMO, while others have little or no regulation addressing these installations. This is one factor driving the parties who seek greater regulation under Annex I.

A further issue is the large number of single-hull vessels now being retired under Annex I tanker rules phasing in double hulls.

Most of the world's existing FPSOs and FSUs are single-hull tanker conversions. These are generally held to be less costly than newbuilds and an attractive field development option for the oil industry where allowed. The final IMO decision may have a significant impact on this practice.

"We can’t predict the outcome at this point," Sharples says, "but our proximity to this entire discussion means that ABS is well positioned to offer clients continuing guidance on FPSO and FSU rules and regulations."


* MARPOL – The International Convention for the Prevention of Pollution from Ships.

** SOLAS – The International Convention on Safety Of Life At Sea.



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