Operational guide · Operational procedure

VOC Management Plan

Crude-oil vapour emissions: approved VOC plan contents, shipboard responsibilities and separate port requirements.

VOCMARPOL Annex VIRegulation 15tankers

Operational Explanation

Volatile Organic Compounds (VOCs) are released from crude oil during loading, the voyage and discharge operations, contributing to air pollution and tropospheric ozone formation. Regulation 15.6 of MARPOL Annex VI requires every crude oil tanker to carry and implement a VOC Management Plan approved by the flag Administration.

The plan is ship-specific and provides written procedures to minimise VOC emissions during the three critical operational phases: crude oil loading, the sea voyage and cargo discharge. The requirement applies to every crude oil tanker, whether newly built or already in service.

What the plan must contain, in writing

Regulation 15.6 lists the mandatory content of the plan, and it is four things. The text, in the revised Annex VI (res. MEPC.328(76)), reads: “A tanker carrying crude oil shall have on board and implement a VOC management plan approved by the Administration. Such a plan shall be prepared taking into account the guidelines developed by the Organization. The plan shall be specific to each ship and shall at least: .1 provide written procedures for minimizing VOC emissions during the loading, sea passage and discharge of cargo; .2 give consideration to the additional VOC generated by crude oil washing; .3 identify a person responsible for implementing the plan; and .4 for ships on international voyages, be written in the working language of the master and officers and, if the working language of the master and officers is not English, French or Spanish, include a translation into one of these languages”.

Check that the plan accounts for additional VOC from crude oil washing and identifies the person responsible for implementation in the form accepted by the Administration. Keep the assignment current. For ships on international voyages, regulation 15.6.4 requires the master’s and officers’ working language, with an English, French or Spanish translation where necessary.

The guidelines invoked by the reference to “guidelines developed by the Organization” are resolution MEPC.185(59), “Guidelines for the development of a VOC management plan”, adopted on 17 July 2009, which IMO invited Governments to apply from 1 July 2010. Supporting technical information on systems and operations is in circular MEPC.1/Circ.680 of 27 July 2009.

And the plan is not the only thing Regulation 15 says

Regulations 15.1–15.5 concern vapour collection at Party-designated ports/terminals, with IMO notification at least six months beforehand. An approved VECS is used during loading under the applicable conditions. The port or terminal may accept unequipped ships for three years from effectiveness: this is not an automatic ship entitlement. Regulation 15.7 covers gas carriers only where cargo/containment systems safely permit retention or shore return of non-methane VOC.

Future development: the pressure/vacuum-device proposal is a draft approved at MEPC 84 for subsequent adoption, not an in-force retrofit obligation or an onboard setpoint.

Evidence: IMO, PPR 13 and Liberia session report, page 7. Verify the final amendment text and dates after adoption; current regulation numbering does not establish that the draft does not exist.

Regulatory Reference

In-force basis: Annex VI/15, MEPC.328(76); guidelines MEPC.185(59) and technical information MEPC.1/Circ.680 linked above. Separate the 15.6 plan, port VECS under 15.1–15.5 and the future draft.

For specific information on the vapour pressure control system, also see MEPC.1/Circ.719, listed in the IMO Annex VI index. Technical guidance does not authorize changes to approved-plan setpoints.

Scope of Application

Every crude oil tanker, regardless of age or build date.

Procedure / How to Complete It

Check the ship-specific approved plan and four elements: loading/passage/discharge procedures, additional COW VOC, responsible person and required language. For international voyages use the master/officers’ working language plus an English/French/Spanish translation if needed.
Follow plan sequences and pressures: limit generation/release without disabling safety vents or importing another ship’s setpoints. Inert gas and COW may increase vapour generation/expulsion; do not indiscriminately increase inert-gas flow.
Separately check VECS, terminal conditions and vapour coordination where applicable; do not presume three-year acceptance.
Train operators, keep the responsible-person identification current and check implementation in all three phases and during COW.

Practical Example

Example application: during crude oil loading, the crew applies the loading sequence set out in the VOC Management Plan to minimise vapour release, coordinating with the terminal for any vapour recovery under the approved plan's specific procedures.

What Typically Goes Wrong

Managing VOC emissions from tankers is a significant environmental challenge for the industry, given the inherently volatile nature of crude oil during loading and discharge operations: the VOC Management Plan addresses this challenge with ship-specific, verifiable and formally approved procedures, rather than generic operational guidance.

Common Mistakes Mistake Library

Avoid a generic plan without COW or a responsible person, language unsuitable for the voyage, confusing VECS with the whole plan, treating three-year acceptance as a right, or turning the P/V proposal into an instruction to modify equipment.

What the PSCO Checks

A PSCO may check the plan’s presence and approval, responsible person, relevant language and operator familiarity, comparing procedures with implementation during loading, sea passage, discharge and COW. Terminal VECS compliance remains a separate check.

Operational Tips

Use only ship-approved procedures and pressures.
Check COW, responsibility, language and training.
Coordinate vapours with the terminal where required, separately from the plan check.

Preparation checklist

Educational checklist. This summary supports learning and preparation only. It does not replace the vessel’s approved procedures, manuals, statutory documents, company SMS, or applicable official requirements. Completing it demonstrates neither compliance nor readiness for an inspection: it shows that a list has been read, not that the ship is in order. Always verify the current documents carried on board.

Ship-specific plan approved and implemented
Loading, passage, discharge and COW contribution covered
Responsible person identified and current
Working language and international-voyage translation where required
Pressure, inert gas and vents managed under plan/manuals
VECS and terminal acceptance checked where applicable

FAQ

Which ships need the plan?

Every tanker carrying crude oil under 15.6. The plan also covers COW, responsibility and language, beyond the three operational phases.

Do I automatically have three years without VECS?

No: the port/terminal may accept unequipped ships during the specified period; the ship cannot substitute its own decision.

Do future P/V amendments already require work?

No. The approved draft still needs adoption; meanwhile follow the plan, manuals and in-force requirements.

VOC Management Plan

Operational Explanation

What the plan must contain, in writing

And the plan is not the only thing Regulation 15 says

Regulatory Reference

Scope of Application

Procedure / How to Complete It

Practical Example

What Typically Goes Wrong

Common Mistakes Mistake Library

What the PSCO Checks

Operational Tips

Preparation checklist

FAQ

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