Fuel and Oil Transfer: the Declaration of Inspection, the PIC, and Keeping It Out of the Water

What the rule requires

Fix the start point first, because it is the operative trigger the exam most often hangs a question on. A transfer begins when the person in charge on the transferring vessel or facility and the person in charge on the receiving facility or vessel first meet to begin completing the declaration of inspection 33 CFR §156.120. Not when the valve is cracked. Not when the hose is coupled. From that meeting forward, everything in §156.120 governs you.

The declaration of inspection

No person may transfer oil or hazardous material to or from a vessel unless each person in charge has filled out and signed the DOI 33 CFR §156.150. Both ends sign — vessel and facility, or both vessels — and neither may sign until he or she has determined by inspection that the vessel or facility meets §156.120, indicating that determination by initialling the appropriate space on the form.

The form itself may be in any form, but it must carry at least the identification of the transferring and receiving vessel or facility; the address of the facility, or the location of the transfer if it is not at a facility; the date and time the transfer is started; a list of the §156.120 requirements with a space to initial each one; a space for date, time of signing, signature and title of each PIC certifying that all tests and inspections are complete and that both are ready to begin transferring product; and the date and time the transfer is completed.

During the transfer, the vessel and facility PICs must each have a signed copy available for inspection by the COTP. Afterwards, the operators retain a signed copy aboard the vessel or at the facility for at least 1 month from the date of signature.

The person in charge

There must be a PIC on the transferring vessel or facility and on the receiving vessel or facility, except as otherwise authorized under §156.115 . Each of them is at the site of the transfer operation and immediately available to the transfer personnel, has a copy of the most recently examined facility operations manual or vessel transfer procedures readily available in the marine transfer area, and conducts the transfer in accordance with it.

Presence is not passive. The PIC must supervise connecting or disconnecting a hose, topping off a tank, and any other critical procedure; no one may start the flow of oil or hazardous material unless instructed to do so by either PIC; and no transfer may be conducted unless each PIC is in the immediate vicinity and immediately available to transfer personnel 33 CFR §156.160.

For the vessels a 100 GT candidate will actually work, the qualification is in one paragraph. For any fuel-oil transfer requiring a DOI, on an inspected vessel required to have an officer aboard and on any uninspected vessel, the PIC either holds a valid merchant mariner credential endorsed as master, mate, pilot, engineer or operator aboard that vessel, or an MMC endorsed as Tankerman-PIC; or carries a letter meeting §155.715 designating him or her as PIC, unless equivalent evidence is immediately available aboard or at the place of employment 33 CFR §155.710. The Tankerman-PIC endorsement requirements in paragraphs (a) through (d) attach to tankships and tank barges, not to taking bunkers on a small passenger vessel.

Whatever the credential, the PIC's required training and experience expressly includes the procedures for reporting pollution incidents.

You are mate of an uninspected 68-foot passenger vessel and you are about to take on 400 gallons of diesel at a fuel dock. The captain is ashore. Can you act as PIC?

Yes, if you hold a valid MMC endorsed as master, mate, pilot, engineer or operator aboard that vessel — or an MMC endorsed as Tankerman-PIC, or a §155.715 designation letter . A Tankerman-PIC endorsement is not the only route for a fuel-oil transfer on an uninspected vessel. You must also be at the site of the transfer with the vessel's transfer procedures readily available .

Hoses, connections and the transfer system

The readiness items in §156.120 read as a walk-down of the rig, and that is how to hold them:

Moorings strong enough to hold through all expected conditions of surge, current and weather, and long enough to allow adjustment for changes in draft, drift and tide.
Hoses and loading arms long enough to let the vessel move to the limits of her moorings without strain on the hose, loading arm or transfer piping; each hose supported to prevent kinking or other damage and strain on its coupling.
The transfer system aligned to allow the flow, with every part not needed for the transfer securely blanked or shut off, and the unconnected end of each hose and loading arm blanked off.
The system attached to a fixed connection on the vessel and the facility — with one exception, that a vessel receiving fuel may use an automatic back pressure shutoff nozzle.
Each overboard discharge or sea suction valve connected to the transfer or cargo tank system sealed or lashed closed, except when receiving or discharging ballast in compliance with 33 CFR Part 157.
Each transfer hose free of unrepaired loose covers, kinks, bulges, soft spots or any other defect that would permit discharge through the hose material, and free of gouges, cuts or slashes penetrating the first layer of reinforcement — reinforcement meaning the strength members: fabric, cord and/or metal.
All connections leak free, with one allowance: a component such as a pump's packing glands may leak at a rate not exceeding the capacity of the discharge containment provided during the transfer.

Separately from that walk-down, equipment used for transfer operations must have been tested and inspected by the vessel or facility operator 33 CFR §156.170. The values that decide questions: a nonmetallic transfer hose must not burst, bulge, leak or abnormally distort under static liquid pressure of at least 1½ times the maximum allowable working pressure; the entire external surface of the hose must be accessible during the test; each pressure gauge must show pressure within 10 percent of actual; each relief valve must open at or below its set pressure; each loading arm and transfer pipe system, metallic hose included, must not leak at 1½ times MAWP; and each item of remote operating or indicating equipment — remote valve, tank level alarm, emergency shutdown device — must perform its intended function. Frequency for vessels is annually, or as part of the biennial and mid-period inspections.

Containment, and what is under the connection

Three items, and candidates lose all three by treating them as one:

The discharge containment equipment required by §154.545 is readily accessible or deployed, as applicable .
The discharge containment required by §§154.530, 155.310 and 155.320, as applicable, is in place and periodically drained to provide the required capacity.
Each drain and scupper is closed by the mechanical means required by §155.310.

A fixed containment that has taken rain or drip water is no longer containment. Draining it during the transfer to hold its rated capacity is a requirement, not housekeeping.

Communication, shutdown, and reporting oil in the water

The communications required by §§154.560 and 155.785 must be operable for the transfer, and the emergency means of shutdown required by §§154.550 and 155.780 must be in position and operable. Where the PICs use radios, they agree a predetermined frequency for the transfer beforehand, and at least one person at the site of the transfer must fluently speak the language or languages spoken by both PICs.

Those come out of the pre-transfer conference, which the two PICs hold to ensure each of them understands the product identity, the sequence of operations, the transfer rate, the name or title and location of each person participating, the details of both systems including procedures to keep transfer pressure below the MAWP of each hose assembly, loading arm and transfer pipe system, the critical stages, applicable Federal, state and local rules, emergency procedures, discharge containment procedures, discharge reporting procedures, the watch or shift arrangement, and transfer shutdown procedures. Then both must agree to begin.

Instructors commonly teach that conference as five questions — what product, how fast, in what order, who is doing what, and what if it goes wrong. Use it to recall the list, but the fifth question carries four separate items in the rule (emergency, containment, reporting, shutdown), and the agreement to begin is a distinct requirement of its own.

Where do the reporting specifics live? In the vessel's transfer procedures, which must contain procedures for reporting discharges of oil or hazardous material into the water 33 CFR §155.750. Those same procedures carry the number of persons required on duty during transfer, the duties by title of each officer, PIC, tankerman and deckhand, duty assignments for tending the moorings during the transfer, procedures for operating the emergency shutdown and communications means, procedures for topping off tanks, and procedures for ensuring all valves used are closed on completion. That document is required to be readily available to you in the marine transfer area — which is where an open-book candidate should expect the answer to a reporting question to be, and where a real PIC finds it at 0200.

Two prohibitions to carry as written: smoking is not permitted in a facility's marine transfer area except in designated smoking areas, and welding, hot work and smoking are prohibited on vessels during the transfer of flammable or combustible materials, except that smoking may be permitted in accommodation areas designated by the master .

Telling it apart

Three paper items govern one transfer, and the criterion that separates them is when each one comes into existence.

Declaration of inspection — created for this transfer, at the meeting that begins it; signed by each PIC only after inspection against §156.120; a signed copy in each PIC's hands for the COTP during the transfer; retained 1 month from signature 33 CFR §156.150. Most often misfiled: candidates treat it as the record of the annual hose test.
Transfer procedures — a standing document for the vessel, contents fixed by §155.750, in force before you ever reach the fuel dock and readily available in the marine transfer area. Most often misfiled: reporting and topping-off procedures are looked for on the DOI when they live here.
Written records under §155.820 — the operator's file, open to the COTP or OCMI: the name of each person currently designated as PIC of transfer operations, the date and result of the most recent §156.170 test and inspection of each item, the hose information required by §154.500(e) and (g) unless marked on the hose, and the DOI required by §156.150(f) 33 CFR §155.820. Most often misfiled: candidates think designating a PIC is done on the DOI rather than recorded by the operator.

Hose condition at the transfer against the hose test

§156.120(i) — a condition for this transfer: no unrepaired loose covers, kinks, bulges, soft spots or other defect permitting discharge, no gouges, cuts or slashes into the first reinforcement layer. Visual, every time, by the PIC signing the DOI.
§156.170 — a periodic test by the operator: static liquid pressure at 1½ times MAWP with the entire external surface accessible, plus internal deterioration to the extent visible with both ends open; annually for vessels, or as part of the biennial and mid-period inspections.

Working a question

You are master of a 92 GT inspected small passenger vessel taking 1,200 gallons of diesel from a shoreside facility. The question gives you a sequence of actions and asks which is required, or which comes first. Work it in this order.

Meet the facility PIC. This is the start of the transfer under §156.120, so the moorings, hose and containment requirements are already in force while you are still holding a clipboard.
Walk down §156.120 and initial as you go. Moorings adequate for expected surge, current and weather with slack for tidal change; hose long enough to reach the limits of the moorings without strain and supported against kinking; unused parts of the system blanked or shut off; sea suction and overboard discharge valves sealed or lashed closed; hose free of the listed defects; containment in place under the connection; scuppers and drains closed by their mechanical means; communications operable; emergency shutdown in position and operable.
Hold the conference. Product, rate, sequence, who is where, both systems and the pressure limit, critical stages, applicable rules, emergency and containment and reporting and shutdown procedures, watch arrangement — and if you are on radios, the agreed frequency.
Sign, both of you. You may not sign until you have determined by inspection that the requirements are met, and the form records date, time of signing, signature and title for each PIC. Enter the time the transfer is started 33 CFR §156.150.
Agree to begin, then let flow start on instruction. The deckhand does not open up because the hose looks ready; flow starts only when instructed by either PIC 33 CFR §156.160.
Stay at the site. Immediate vicinity, immediately available. Supervise topping off yourself — it is named in §156.160(a) alongside connecting and disconnecting as a procedure requiring the PIC's supervision.
Drain the containment as it collects. Required capacity has to be there for the whole transfer 33 CFR §156.120.
On completion: close every valve used, per the vessel's transfer procedures; disconnect under your supervision; enter the date and time the transfer was completed on the DOI; keep the signed copy for a month.

If instead the question puts a sheen on the water beside you, the sequence is shutdown and the reporting procedure your transfer procedures carry — the document §156.120(t)(2) requires you to have in hand in the marine transfer area.

Halfway through the bunkering, the facility PIC leaves the dock to answer a phone in the office ashore. Is the transfer still lawful?

No. No person may transfer oil to or from a vessel unless each PIC is in the immediate vicinity and immediately available to transfer personnel , and §156.120(t)(1) requires each PIC to be at the site of the transfer operation. Shut down.

Where candidates lose the point

"The transfer begins when product starts moving." The rule fixes the start at the first meeting of the two PICs to begin completing the DOI. Any option keyed to the pump, the coupling or the valve is wrong, and the practical consequence is that a defect found after that meeting is a defect during a transfer.

Signing the form to save time, intending to walk the deck after. §156.150(b) bars a PIC from signing until he or she has determined by inspection that §156.120 is met and has initialled each item to say so. An option that has you sign first and inspect during the transfer fails.

Reading "person in charge" as "designated on the crew list." The requirement is physical: at the site, immediate vicinity, immediately available, with the transfer procedures to hand. A PIC monitoring from the wheelhouse or by phone does not satisfy it.

Draining or discharging the containment overboard to restore capacity. The requirement is that containment be in place and periodically drained to provide the required capacity, with drains and scuppers closed by mechanical means. Options that clear the deck to the water are wrong on their face.

Confusing the two pressure figures. The static liquid pressure test is at 1½ times the maximum allowable working pressure; the 10 percent figure belongs to pressure gauge accuracy. A distractor swapping them looks reasonable to anyone who half-remembers the section.

Answering 12 months for DOI retention. One month from the date of signature. The annual figure belongs to §156.170 test and inspection frequency, and that adjacency is exactly why the distractor works.

Assuming a hose can be tested as rigged. The entire external surface must be accessible during the test, so a hose still made up on a reel or run through a chock has not been inspected to the rule.

Check yourself

You and the facility PIC meet at 1345 to start the DOI. At 1358, while you are still initialling items, a deckhand notices the hose has a soft spot. Is this a defect found before the transfer or during it?

During it. The transfer began at 1345, when the two PICs first met to begin completing the declaration of inspection 33 CFR §156.120. The hose has a defect under §156.120(i) and may not be used; it is not made acceptable by the fact that no product has moved.

The facility PIC has signed the DOI and tells your deckhand to open up while you are still checking the sea suction valves. What action is required?

Do not let flow start. Both PICs must have signed, both must agree to begin, and no person may start the flow unless instructed by either PIC 33 CFR §156.160. Your own signature is also unlawful until you have inspected and initialled each §156.120 item.

A COTP boarding officer arrives 20 minutes into the transfer and asks for the declaration of inspection. Where is it?

In your hands. The vessel and facility PICs must each have a signed copy available for inspection by the COTP during the transfer operation 33 CFR §156.150. Filed in the office ashore does not meet it.

Rain has half-filled the containment under the hose connection. The transfer has an hour to run. What is required?

Drain it so the required capacity remains available. The containment must be in place and periodically drained to provide the required capacity through the transfer, and drains and scuppers stay closed by their mechanical means .

Your transfer pump's packing gland is weeping diesel at a slow drip into the containment tray. All connections must be leak free. Must you stop?

Not on that ground alone. §156.120(p) allows a component of the transfer system, such as the packing glands of a pump, to leak at a rate not exceeding the capacity of the discharge containment provided during the transfer. If the rate exceeds that capacity, the transfer stops.

A boarding officer asks for the date and result of the most recent test of the vessel's emergency shutdown device. Which document holds it?

The operator's written record under 33 CFR §155.820, which must include the date and result of the most recent test and inspection of each item required by §156.170 — an emergency shutdown device being remote operating equipment that must perform its intended function. It is not an entry on the DOI.

You are PIC for bunkering an uninspected six-pack. What must be readily available to you in the marine transfer area, and what does it tell you if fuel reaches the water?

The most recently examined vessel transfer procedures . Among their required contents are the procedures for reporting discharges of oil or hazardous material into the water, the emergency shutdown and communications procedures, and the duties by title of each person in the operation 33 CFR §155.750.