VOC Management Plan
Mandatory for every crude oil tanker: the plan that minimises volatile organic compound emissions during loading, the voyage and discharge.
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”.
Three of those four are the points an inspection verifies in minutes, and also the ones most often missing from a plan adapted from another ship. Crude oil washing: washing with crude generates VOC over and above the three operational phases, and the plan must expressly account for it. The responsible person: the approved plan must identify who answers for implementation, in the manner accepted by the Administration. And the identification must be kept current when personnel or assigned functions change: a plan naming someone who signed off months ago identifies nobody. The language: the plan must be written in the working language of the master and officers, and if that language is not English, French or Spanish it must include a translation into one of the three.
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. The supporting technical information on vapour pressure control systems is in circular MEPC.1/Circ.680 of 27 July 2009.
And the plan is not the only thing Regulation 15 says
15.6 is the paragraph that covers every crude oil tanker, everywhere. Paragraphs 15.1 to 15.5 govern a different thing, often confused with it: the vapour emission collection system in ports that require one. VOC regulation in a port is not decided by IMO: it is decided by the individual Contracting Party (15.1), which must notify the Organization at least six months before the effective date, stating the size of tankers concerned and the cargoes covered (15.2); IMO merely circulates the list of designated ports and terminals (15.4). A tanker calling at one of those ports must have a vapour emission collection system approved by the Administration and use it during loading (15.5), with a transitional period of three years from the effective date. Paragraph 15.7 extends the Regulation to gas carriers, but only where the loading and containment systems allow safe retention of non-methane VOCs on board or their safe return ashore.
A note on a finding received: a review also pointed to a paragraph 15.8. It does not exist: Regulation 15 of the revised Annex VI has seven paragraphs.
Some secondary sources attribute to MEPC 84 an amendment to Regulation 15 introducing a requirement for pressure-vacuum (PV) valves on crude oil tanker cargo tanks. It could not be corroborated: the session summaries from Lloyd’s Register, ABS and Bureau Veritas list only the NOx Code alignment for Annex VI, and none reports an amendment to Regulation 15. Until a resolution number appears, this page does not treat it as a requirement.
Regulatory Reference
MARPOL Annex VI, Regulation 15. 15.6 requires crude oil tankers to carry a VOC Management Plan approved by the Administration, ship-specific, with four minimum contents: written procedures for the three operational phases, consideration of the VOC generated by crude oil washing, identification of the person responsible for implementation, and drafting in the working language of the master and officers with a translation into English, French or Spanish where that language is another. Guidelines: res. MEPC.185(59) of 17 July 2009, to be applied from 1 July 2010; supporting technical information in circular MEPC.1/Circ.680 of 27 July 2009. Paragraphs 15.1–15.5 instead cover the vapour emission collection system in ports designated by a Party, with notification to the Organization at least six months in advance; 15.7 extends the Regulation to gas carriers where the loading and containment systems safely allow it. Regulation 15 has seven paragraphs: there is no 15.8.
Scope of Application
Every crude oil tanker, regardless of age or build date.
Procedure / How to Complete It
- Verify that the VOC Management Plan on board is ship-specific and approved by the flag Administration.
- Apply the operational procedures set out in the plan during the loading phase, minimising vapour release.
- Maintain the containment procedures set out in the plan during the sea voyage.
- Apply the specific procedures for the discharge phase, coordinating with the terminal on the management of return vapours where applicable.
- Train the crew on the VOC Management Plan's specific operational procedures, distinguishing them from general loading/discharge procedures.
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 | How to avoid it |
|---|---|---|
| VOC Management Plan treated as a generic document rather than ship-specific | Procedures not calibrated to the ship's actual technical characteristics | Verify the plan is ship-specific and consistent with the vessel's actual technical configuration |
| Crew not specifically trained on VOC procedures, confused with general loading procedures | Incomplete application of emission minimisation measures | Train the crew specifically on the VOC Management Plan's procedures, distinct from general ones |
| Coordination with the terminal for vapour recovery not verified before operations | Failure to apply the minimisation measures intended for the discharge phase | Always verify coordination with the terminal on vapour management before operations begin |
What the PSCO Checks
Operational Tips
- Verify that the VOC Management Plan is specific to your ship, not a generic document adapted from another unit.
- Train the crew specifically on VOC procedures, distinguishing them from general loading/discharge procedures.
- Always coordinate return vapour management with the terminal before loading/discharge operations begin.
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 VOC Management Plan verified and approved by the Administration
- Loading procedures applied per the plan to minimise vapour release
- Containment procedures maintained during the sea voyage
- Coordination with the terminal on vapour management verified before discharge
- Crew specifically trained on the VOC Management Plan procedures
FAQ
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Last substantive revision of this page: 28 August 2026 · page fingerprint d5db84b5d48f