VOC Management Plan
Crude-oil vapour emissions: approved VOC plan contents, shipboard responsibilities and separate port requirements.
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
Common Mistakes Mistake Library
| Mistake | Consequence | Prevention |
|---|---|---|
| Generic plan without COW or a responsible person | The instructions omit a relevant operation or do not identify who implements them. | Use the approved ship-specific plan with the four 15.6 components and relevant COW instructions. |
| Language unsuitable for the voyage | Master and officers may lack the plan in the required language. | Check the working language and, on international voyages, the English, French or Spanish translation when required. |
| Confuse VECS with the entire VOC plan | Passage, discharge or COW procedures remain uncovered. | Check the 15.6 plan separately from 15.1–.5 port/terminal requirements. |
| Treat the three-year period as an entitlement | Acceptance is assumed although the port or terminal may not grant it. | Confirm the actual arrangement with the terminal before operating. |
| Modify equipment on the basis of the P/V draft | An amendment still subject to adoption is treated as in force. | Retain approved setpoints and configuration; distinguish the draft from current instructions. |
What the PSCO Checks
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
Related Topics
Certified substantive revision: 17 October 2026 · page fingerprint 51df2eb17e4f