What Regulation 17 requires and who it binds
MARPOL Annex II Regulation 17 is short. It requires every ship of 150 gross tonnage and above certified to carry noxious liquid substances in bulk to carry on board a shipboard marine pollution emergency plan for noxious liquid substances approved by the Administration. That single sentence carries three load-bearing facts: the 150 GT threshold, the link to the NLS certificate (the ship must be certified for NLS carriage, not merely capable of it), and the approval requirement that puts the flag State, not the company, in control of the plan’s content.
The threshold is a flat 150 GT. There’s no second, higher figure of the kind that appears in Annex I Regulation 37, where oil tankers above 150 GT and all other ships above 400 GT both fall in. The reason is structural: Annex II governs NLS carried in bulk, and a ship carrying NLS in bulk is a chemical tanker or a combination carrier built and certificated for that trade. There’s no class of incidental NLS carriage below the chemical-tanker fleet the way bunker oil makes every ship a potential oil polluter. So Annex II draws one line at 150 GT and applies it to the whole NLS fleet.
The plan must be approved by the Administration. The flag State, or a Recognized Organization acting on its behalf, reviews the plan against the IMO content guidelines and stamps it before it counts as compliant. A plan that follows the guidelines but has never been submitted is not an approved plan, and a PSC officer who finds an unapproved or expired plan can record a deficiency. Approval is not a one-time event either: when the cargo list on the Certificate of Fitness changes, or when the national contacts appendix is reissued, the plan changes with it, and substantive revisions go back to the Administration.
Regulation 17 is the consolidated number. In the revised Annex II adopted by Resolution MEPC.118(52) and in force from 1 January 2007, the SMPEP requirement sits at Regulation 17 of Chapter 6 (measures for control of pollution). Before that recast it lived at the old Regulation 16. Citing the SMPEP as Regulation 16 or, worse, Regulation 14 is a pre-2007 number carried forward by mistake; the current text is Regulation 17, and any compliance document, audit checklist, or wiki entry that says otherwise is out of date. The renumbering matters because the whole annex was reordered in the 2007 revision, so a stale regulation reference signals the writer was working from a superseded edition.
How the SMPEP grew out of the SOPEP
The shipboard pollution emergency plan started on the oil side. The 1991 amendments to MARPOL Annex I inserted what was then Regulation 26, requiring oil tankers and large ships to carry a Shipboard Oil Pollution Emergency Plan, the SOPEP. That amendment was the IMO’s answer to the Exxon Valdez grounding of 24 March 1989 and the US Oil Pollution Act of 1990, both of which exposed how little a stricken ship’s crew had to work with in the first hour of a spill. The 2004 consolidation of Annex I renumbered that regulation 26 to the present Regulation 37 without changing its substance.
Chemical tankers were the obvious next case. A ship carrying a Category X or Y noxious liquid substance can do as much environmental harm as an oil tanker, and often more to human health, yet under the original Annex II it had no equivalent planning requirement. The IMO closed that gap in two steps. First it built the content standard: at the 44th session of the Marine Environment Protection Committee in 2000, Resolution MEPC.85(44) (adopted 13 March 2000) set out the Guidelines for the Development of Shipboard Marine Pollution Emergency Plans for Oil and/or Noxious Liquid Substances. The title is deliberate. Rather than write a separate NLS guideline, the MEPC wrote one combined guideline covering oil, NLS, or both, so that a ship carrying both could work from a single document. Then it inserted the carriage requirement into Annex II itself.
Resolution MEPC.137(53), adopted 22 July 2005, amended MEPC.85(44). The amendment tightened the contacts appendix and aligned the SMPEP guideline with the parallel SOPEP guideline in Resolution MEPC.54(32) as amended by MEPC.86(44). The IMO later consolidated both guidelines into the 2010 Edition of the Guidelines for the Development of Shipboard Marine Pollution Emergency Plans, which is the single volume a designated person or a surveyor reaches for today. The preamble to MEPC.137(53) recalled that, at the time, Regulation 26 of Annex I and Regulation 16 of Annex II required the plans; the Annex II number moved to 17 only with the MEPC.118(52) recast that took effect on 1 January 2007.
So the lineage runs: oil first (Annex I, 1991), then the combined content guideline (MEPC.85(44), 2000), then its amendment (MEPC.137(53), 2005), then the renumbered carriage requirement (Annex II Regulation 17, in force 2007). The SMPEP did not replace the SOPEP. It extended the same planning logic to a harder class of cargo and gave operators the option to fold both obligations into one binder.
The combined SOPEP/SMPEP plan
A chemical tanker rarely carries only NLS. Product carriers swing between clean petroleum products under Annex I and chemical parcels under Annex II on consecutive voyages, and many parcel tankers load oil and chemicals in the same lift. Carrying two separate emergency plans for one ship would be wasteful and confusing: the reporting procedure, the master’s decision tree, and the shore contacts list are the same regardless of whether the substance overside is gasoil or a Category Y solvent.
The IMO guidelines resolve this by allowing one combined plan. Most of the content is common, so a single combined plan on board is more practical than two separate ones. When the plan covers both oil and NLS, it should be called a Shipboard Marine Pollution Emergency Plan, the SMPEP, to make clear it is the combined document. A combined SMPEP satisfies both the Annex I Regulation 37 SOPEP requirement and the Annex II Regulation 17 SMPEP requirement at once. The flag State approves the one document against both regulations, and the ship carries one binder rather than two.
The structure of the combined plan follows the same four-part shape as a standalone SOPEP. Section 1 is the introduction: ship particulars, the purpose of the plan, the relationship to the company safety management system, and the revision-control table. Section 2 is the reporting procedure: when the master must report, what to report, and to whom. Section 3 is the action to control the discharge: the steps the crew takes on deck and at the cargo control room to stop or reduce the release. Section 4 is the contacts list: coastal-State authorities, the flag State, the company and its designated person, the P&I club, salvage and response contractors, and the cargo’s shore interests. The difference between an oil-only SOPEP and a combined SMPEP shows up inside Sections 3 and 4, where the NLS cargo brings its own hazards and its own data references.
A practical detail trips up new chemical-tanker officers: the combined plan does not duplicate the cargo properties for every substance the ship may carry. The IBC Code Cargo List runs to several thousand entries, and reproducing each one’s reactivity and toxicity in the SMPEP would make the binder unusable. Instead the plan tells the response team where to look: the P&A Manual for the ship-specific handling and residue procedures, the IBC Code chapter 17 entry and chapter 16 operational requirements for the cargo’s carriage conditions, the Medical First Aid Guide for casualty management, and the EmS Guide for fire and spill response. That referencing approach is what separates an SMPEP from an oil-only SOPEP, where one substance, oil, behaves predictably enough that the plan can carry its response steps in full.
Section 2: the reporting procedure
The reporting section is the part of the SMPEP a PSC officer reads first, because it is the part that has to work in the first ten minutes of an incident. It implements MARPOL Article 8 and Protocol I, which require the master of a ship involved in an incident to report without delay to the nearest coastal State. The plan turns that legal duty into a one-page flow the master can follow under pressure.
The trigger conditions come straight from Protocol I of MARPOL. A report is required for an actual discharge of NLS, for a probable discharge (a casualty such as a grounding, collision, fire, structural failure, or flooding that makes a release likely even if none has happened yet), and for the loss or probable loss overboard of packaged harmful substances. The probable-discharge trigger matters: the master must report a collision that has not yet breached a cargo tank, because the coastal State needs the warning before the spill, not after. Officers trained only on oil tankers sometimes under-report here, waiting for visible cargo overside; the SMPEP corrects that by listing the casualty triggers explicitly.
The report content follows the standard IMO ship-reporting format set out in Resolution A.851(20): ship identity, position, the substance involved, the quantity, the nature of the incident, weather and sea state, and the assistance required. For an NLS incident the substance line carries more weight than it does for oil, because the coastal State’s response, the exclusion zone, the protective equipment its responders wear, depends on whether the cargo is a chlorinated solvent, a strong acid, or a vegetable oil. The plan reminds the master to state the proper shipping name and the UN number where one applies, not a trade name.
The “to whom” is the contacts list in Section 4, anchored by the list of national operational contact points the IMO maintains. That list is issued as the MSC-MEPC.6/Circ. series and reissued on a quarterly cycle: the consolidated annual circular comes out on 31 January, with updates on 30 April, 31 July, and 31 October. Carrying the current list is mandatory, and a ship working from a year-old appendix is carrying wrong phone numbers and telex addresses for half the coastal States it will pass. This is the most-cited SMPEP deficiency at Port State Control, and it is entirely avoidable: the company’s superintendent inserts the new circular each quarter, and the master checks the revision date before the plan is needed.
Section 3: action to control the discharge
Section 3 tells the crew what to do on board to stop or reduce the release, and this is where the NLS plan diverges most from its oil counterpart. An oil spill is a buoyancy-and-containment problem: stop the source, transfer cargo away from a breached tank, deploy what containment the ship has. An NLS release can be all of that plus a toxicity, reactivity, or fire problem, and the order of operations changes with the cargo.
The plan distinguishes operational spills from casualty spills. An operational spill, a hose burst at the manifold, a tank overflow during loading, an ODME-related miscalculation on discharge, is something the crew can usually contain: stop the pump, close the valve, contain the cargo on deck with the manifold drip trays and scuppers, and pump it back inboard. A casualty spill from grounding, collision, or fire is a damage-control problem the crew manages while shore assistance mobilizes: assess the breached tanks, consider internal transfer to undamaged tanks where the cargo’s compatibility allows it, and stabilize the ship.
NLS-specific hazards drive the response sequence. The plan, read with the cargo’s data, tells the crew whether the substance is toxic by inhalation or skin contact (so the response is upwind, with breathing apparatus and chemical suits), whether it reacts violently with water (so seawater firefighting or deck washdown is the wrong move), whether it is flammable (so the inert gas and fixed firefighting systems govern), and whether it polymerizes or self-reacts (so cargo temperature and inhibitor status matter). These are not generic warnings. They come from the cargo’s individual carriage requirements in the IBC Code and from the safety data sheet the shipper provides at loading, and the SMPEP’s job is to send the response team to those sources fast, not to memorize them.
Cargo compatibility constrains the internal-transfer option in a way oil never does. Transferring oil from a breached tank to a slack tank is a straightforward decision. Transferring an NLS into another tank means checking that the receiving tank’s previous cargo, its coating, and its heating arrangement are compatible, because mixing incompatible chemicals can generate heat, gas, or a reaction worse than the spill. The P&A Manual and the cargo segregation plan carry that compatibility data, and the SMPEP points to them rather than reproducing them.
NLS hazards, the MFAG, and the EmS Guide
The two reference works that make an NLS emergency plan workable are the Medical First Aid Guide and the EmS Guide. Neither is part of the SMPEP itself; the plan references both, and both must be on board the chemical tanker.
The IMO/WHO/ILO Medical First Aid Guide for Use in Accidents Involving Dangerous Goods, the MFAG, is the chemical-casualty reference. It is the chemicals supplement to the WHO International Medical Guide for Ships, and it covers the substances regulated under the IMDG Code and the bulk materials in appendix B of the IMSBC Code, which between them reach the chemicals a tanker handles. The revised text was adopted by the Maritime Safety Committee in May 1998 for use with the IMDG Code, and it is reproduced in the IMDG Code Supplement. The MFAG works in three steps the SMPEP can direct the medical responder to: Step 1 covers emergency action and diagnosis, Step 2 gives the treatment tables for special circumstances, and Step 3 holds the appendices with the medicines list and the list of chemicals keyed to the tables. For a casualty exposed to a cargo vapor, the officer treating them works the MFAG from the substance back to the table, not from memory.
The EmS Guide, formally the Emergency Response Procedures for Ships Carrying Dangerous Goods, holds the Emergency Schedules. Each schedule is a fire or spillage response procedure keyed to a class of dangerous goods, and the EmS Guide was amended at the 87th session of the Maritime Safety Committee in May 2010, recorded in MSC.1/Circ.1360. The MFAG and EmS Guide are designed to be used together: in a cargo fire the responder identifies the applicable EmS fire schedule, follows it with appropriate breathing apparatus and protective clothing, and stands ready to apply the MFAG if a crew member is exposed. The EmS Guide is the packaged-goods and IMDG counterpart; for bulk NLS the IBC Code’s individual carriage requirements and the cargo data sheet are the primary references, with the EmS Guide and MFAG covering the human-health and fire dimensions that the discharge-control rules of Annex II do not address.
The reason the SMPEP relies on these external references rather than carrying the data itself is volume and currency. The IBC Code Cargo List runs to several thousand products, the chemistry behind a given cargo’s hazards can fill pages, and the references are revised on their own cycles. A plan that tried to internalize all of it would be both unmanageably large and perpetually out of date. The discipline the guideline imposes is that the plan be a router: it directs the response team to the right reference for the cargo in the tank, and it keeps those references on board and current.
Relationship to the IBC Code, the P&A Manual, and the cargo’s emergency data
The SMPEP does not stand alone. It is the emergency layer on top of a stack of chemical-tanker documents that together govern how the ship carries NLS, and an officer who treats the plan as self-contained has misunderstood it.
The IBC Code, the International Code for the Construction and Equipment of Ships Carrying Dangerous Chemicals in Bulk, is the foundation. It sets the ship type (1, 2, or 3) for each cargo, the tank arrangement and protective siting under Annex II Regulation 16, and, in chapter 17, the individual carriage requirements for each listed product: the tank environmental control, the temperature limits, the materials of construction, the personal protection, and any special requirements such as inhibition or inert-gas blanketing. When the SMPEP’s response section says to consult the cargo’s hazards, that chapter 17 entry is where the answer is. The IBC Code also carries, in chapter 16, the operational requirements, and in chapter 14, the personal protection equipment the ship must hold for the cargoes on its Certificate of Fitness.
The Procedures and Arrangements Manual, the P&A Manual required under Annex II, is the ship-specific operational document. Where the IBC Code is generic to the cargo, the P&A Manual is generic to neither: it sets out how this particular ship handles loading, discharge, tank cleaning, prewash, ventilation, and residue disposal for the cargoes it is certified to carry, with the actual pump rates, line arrangements, and stripping procedures. In an emergency the P&A Manual tells the crew which valve isolates which tank, how the stripping and prewash systems behave, and what the ship can and cannot do to contain a release. The SMPEP’s Section 3 leans on it heavily for the control actions that depend on the ship’s own piping.
The cargo’s emergency data sheet, supplied by the shipper at loading, is the third leg. It carries the product’s safety data: the hazards, the recommended firefighting media, the spill cleanup method, the first-aid measures, and the emergency contacts for the cargo’s manufacturer. For a cargo the crew has not carried before, or a cargo with unusual reactivity, that sheet is the most current source on board, and the SMPEP directs the response team to read it alongside the IBC Code entry. The plan, the IBC Code, the P&A Manual, the MFAG, the EmS Guide, and the cargo data sheet form one referenced set; the SMPEP is the index that ties them together at the moment of an incident.
How the NLS pollution categories shape the plan
Annex II sorts noxious liquid substances into four categories by environmental hazard, and the category of the cargo in the tank changes both the urgency of the report and the tenor of the response. The categories are X, Y, Z, and Other Substances (OS), and they replaced the older A, B, C, D scheme in the MEPC.118(52) revision that took effect on 1 January 2007.
A Category X cargo is presumed to present a major hazard if discharged, and its residues must go to shore reception facilities under a discharge prohibition. For the SMPEP that means a Category X spill is the worst case the plan has to handle: the substance the annex treats as too harmful to allow into the sea at any operational concentration is the one overside. The reporting and response have no operational-discharge fallback; everything in Section 3 is about stopping and containing. A Category Y cargo presents a hazard justifying substantial restrictions including prewash and controlled discharge below a defined concentration; a Category Z cargo presents a minor hazard with lighter restrictions. The SMPEP does not change category by category in the way the discharge rules do, but the response team’s sense of how hard to push the containment and how wide to set the exclusion zone tracks the category and, more precisely, the cargo’s individual hazards.
The distinction the plan must keep clear is between the pollution category and the safety hazard. A cargo’s Annex II category measures its environmental harm; its IBC Code carriage requirements measure its safety hazards to the ship and crew, toxicity, flammability, reactivity, corrosivity. The two do not always move together: a cargo can be a low pollution category yet acutely toxic by inhalation, or a high pollution category yet relatively benign to handle. The SMPEP’s response section is driven by the safety hazards, the MFAG and IBC Code data, while the reporting section is driven by the pollution incident, the Annex II and Protocol I triggers. An officer who reads only the pollution category and skips the cargo’s safety data has read half the picture.
The four-section anatomy in detail
The IMO guidelines give the plan a recommended structure, and the discipline of that structure is what makes the plan usable under stress. The four mandatory sections are deliberately ordered so that the master works top to bottom in an incident: introduction, reporting, action, contacts.
Section 1, the introduction, carries the ship particulars, a statement of the plan’s purpose and the regulations it satisfies, the relationship to the company safety management system, and the revision-control table. It is the section a surveyor reads to confirm the plan is the right plan for this ship and has been kept current. The revision table is small but load-bearing: it is the audit trail that shows when the contacts appendix was last updated and when the plan was last reviewed against a Certificate of Fitness change.
Section 2, the reporting requirements, is the procedural heart already described: the triggers from Protocol I, the report content in the A.851(20) format, and the addressees. The guidelines push operators to make this section a flow the master can follow without reading prose, because the value of the section is measured in the minutes it saves at the start of an incident.
Section 3, the steps to control the discharge, splits in practice into operational-spill actions and casualty actions, with the NLS hazards governing the order of work. The guidelines expect this section to be ship-specific rather than generic: it should reference the ship’s own piping, its stripping and prewash arrangements, its deck containment, and its cargo-compatibility constraints, all of which come from the P&A Manual and the cargo segregation plan.
Section 4, the list of contacts, is the most maintenance-hungry. It carries the coastal-State contacts from the MSC-MEPC.6/Circ. list, the flag State, the company and its designated person, the P&I club, salvage and response contractors, and the cargo’s shore interests. The guidelines treat the national contact points list as a mandatory appendix in its own right, kept current to the quarterly IMO reissue. Beyond the four mandatory sections, the plan carries appendices: the contacts list, ship plans and drawings useful in a response, and references to the on-board MFAG, EmS Guide, IBC Code, and P&A Manual.
The SMPEP inside the safety management system
The SMPEP does not float free of the ship’s other documents. The ISM Code requires every company to operate a safety management system, and Element 8 of the Code requires procedures to identify and respond to emergency situations. The SMPEP is the pollution-emergency procedure inside that system, and treating it as a standalone MARPOL document rather than an integrated SMS element is a common organizational mistake.
The integration runs two ways. The SMS provides the SMPEP its activation chain: the master mobilizes the crew, the master contacts the designated person ashore, and the designated person mobilizes the company’s response organization, salvage, technical support, the P&I correspondent, and the media response. The SMPEP provides the SMS its pollution-specific content: the reporting triggers, the discharge-control steps, and the contacts that a generic emergency procedure would not carry. A drill that exercises the SMPEP is, at the same time, an Element 8 emergency-preparedness exercise, and the records satisfy both the ISM and the SMPEP maintenance expectation.
This integration is why the designated person ashore appears at two points in the SMPEP and why the company’s side of the plan has to be as current as the ship’s. A plan whose ship side is immaculate but whose company response organization has not been tested out of hours has a single point of failure at the activation chain. PSC officers and ISM auditors both probe this seam, the auditor through the SMS, the PSC officer through the SMPEP, and a finding on one side usually implies a weakness on the other.
The OPRC-HNS Protocol and the regional response regime
The SMPEP is the ship’s plan; the OPRC-HNS Protocol is the shore’s. The two are designed to interlock, and understanding the Protocol explains why the SMPEP’s reporting procedure matters as much as its response procedure.
The 1990 International Convention on Oil Pollution Preparedness, Response and Co-operation (OPRC), in force 13 May 1995, built the international framework for oil-spill preparedness: national contingency plans, stockpiles of response equipment, and mutual assistance between States. The OPRC-HNS Protocol 2000 extended that framework to hazardous and noxious substances. It was adopted in 2000 and entered into force on 14 June 2007, and from that date ships flying the flag of a Party must carry a pollution emergency plan dealing specifically with HNS incidents. That carriage obligation under the Protocol is satisfied by the same SMPEP the ship already holds under Annex II Regulation 17; the Protocol does not require a second plan.
The HNS definition in the Protocol is broad and deliberately operational: a hazardous and noxious substance is any substance other than oil which, if introduced into the marine environment, is likely to create hazards to human health, to harm living resources and marine life, to damage amenities, or to interfere with other legitimate uses of the sea. That definition is wider than the noxious-liquid-substance categories of Annex II and wider still than the HNS named in the liability-and-compensation HNS Convention; the same acronym carries different scopes in the preparedness Protocol and the compensation Convention, and conflating them is a common error. Only Parties to the OPRC Convention 1990 can accede to the OPRC-HNS Protocol, so the two instruments move together.
The practical link to the SMPEP runs through Section 2. When the master reports an NLS incident to the nearest coastal State, the State that receives the report is, if it is a Party, operating an HNS national contingency plan built under the Protocol: trained responders, identified equipment, and a command structure. The ship’s plan and the State’s plan meet at the report. A timely, correctly addressed report under the SMPEP feeds the shore response that the Protocol stood up; a late or misaddressed report leaves that response blind. This is why the currency of the MSC-MEPC.6/Circ. contacts list is not a paperwork formality: it is the wiring between the ship’s plan and the coastal State’s plan.
Drills, maintenance, and plan currency in practice
A plan that sits unopened in the bridge file is worth little, and the chemical-tanker fleet treats SMPEP drills and maintenance as a managed routine rather than an annual box-tick.
Drills exercise the plan against realistic scenarios. The SOPEP and SMPEP drill regime aligns with the ISM Code requirement for emergency-preparedness exercises, run at least quarterly, which gives a minimum of four drills a year, though well-run chemical tankers rotate through more. The scenarios that matter for an SMPEP are the ones that stress the NLS-specific parts of the plan: a manifold spill of a toxic cargo that forces the response team into breathing apparatus and chemical suits, a tank overflow during loading that tests the deck-containment and stripping response, a collision that triggers the probable-discharge report before any cargo is overside, and a cargo fire that exercises the EmS schedule and the fixed firefighting interface. Drilling the toxic-cargo scenarios is what distinguishes SMPEP practice from oil-only SOPEP practice, because the personal-protection and exclusion-zone discipline does not transfer from an oil drill.
Plan maintenance is mostly about the contacts appendix and the cargo list. The contacts list is the part that goes stale fastest, because the IMO reissues the national contact points quarterly; a managed ship has a standing procedure for the superintendent to send the new MSC-MEPC.6/Circ. each quarter and for the master to insert it and log the revision. The cargo references update on a slower cycle: when the ship’s Certificate of Fitness changes, the IBC Code is amended, or the MFAG and EmS Guide are revised, the relevant references on board change with them. The revision-control table in Section 1 of the plan is the audit trail a surveyor checks to confirm the plan has been kept current rather than printed once and forgotten.
The designated person ashore sits at the center of the maintenance loop. Under the ISM Code the designated person links ship and company and has the responsibility and authority to mobilize the company’s emergency response. In an SMPEP context that means the designated person is both a name in the Section 4 contacts list, the first company contact the master calls, and the person responsible for keeping the company’s side of the plan, the response contractors, the salvage arrangements, the technical support, ready to activate. A plan with a designated person who cannot be reached out of hours, or a contact chain that has not been tested, fails at the point it is needed.
Port State Control inspection of the SMPEP
Port State Control treats the SMPEP as a documentary and a substantive check, and the chemical-tanker trades see it inspected often because the Paris MoU and Tokyo MoU target chemical tankers under their risk-profiling.
The documentary check is quick and unforgiving. The PSC officer confirms the plan exists, is approved by the flag State or its Recognized Organization, is written in a language the crew works in, and carries the current MSC-MEPC.6/Circ. national contact points list. The contacts-list check is the one that catches ships: because the list is reissued four times a year, an officer who finds a year-old appendix has found a clear deficiency, and “SOPEP/SMPEP not as required” is among the most frequently recorded items in the deficiency statistics precisely because operators fail to insert the quarterly update. The fix is procedural, not technical, which is why detention-grade findings on this point read as management failures.
The substantive check probes whether the crew can use the plan. A PSC officer may ask the duty officer to walk through the reporting procedure for a given scenario, to point to the contacts for the coastal State the ship is in, or to locate the MFAG and EmS Guide and explain how they would be used for a named cargo. A crew that cannot find its own references, or an officer who reports only on visible cargo overside and misses the probable-discharge trigger, exposes a training gap that the drill record should have closed. The plan and the drill log are read together: a clean plan with no evidence of realistic drills invites a closer look.
Findings escalate by severity. A stale contacts list or a minor documentary gap is a recordable deficiency to be rectified. A missing or unapproved plan, or a crew demonstrably unable to operate it, can support detention because the ship cannot meet its Annex II Regulation 17 and OPRC-HNS obligations. For a chemical tanker the SMPEP sits alongside the NLS Certificate, the P&A Manual, and the Cargo Record Book as the document set a PSC officer expects to find complete, current, and used, and the NLS discharge calculator and related Annex II tooling sit in the same compliance orbit for the operational discharge side that the SMPEP backs up in an emergency.
A manifold-spill walkthrough
The clearest way to see how the four sections work together is to follow a manifold spill from the first second, the scenario most often drilled because it is the most likely operational release on a chemical tanker.
A cargo hose at the manifold ruptures during discharge of a Category Y solvent. The first action belongs to no section of the plan: the duty officer or the pumpman hits the emergency stop and the cargo pumps wind down, then the manifold valve closes and the line is isolated. The plan’s Section 3 begins the moment the source is stopped: the deck team contains the cargo already on deck in the manifold drip trays, confirms the scuppers are plugged so nothing reaches the sea, and assesses the quantity overside if any reached the water. Because the cargo is a solvent, the response is upwind and the team is in breathing apparatus and chemical suits before they approach the spill, a step the SMPEP’s response section and the cargo’s IBC Code entry both drive.
If any cargo reached the water, the probable-or-actual-discharge trigger in Section 2 fires and the master reports. The master pulls the contacts for the coastal State from the Section 4 appendix, confirms the list’s revision date is current, and sends the report in the A.851(20) format with the cargo’s proper shipping name and quantity. The designated person ashore is the next call, and from there the company’s response organization activates under the ISM Element 8 chain. While that runs, the crew works the cargo data sheet and the IBC Code chapter 17 entry for the solvent: its flammability sets whether the fixed firefighting and inert-gas systems are armed, its toxicity sets the exclusion zone on deck, and its water-reactivity (or absence of it) sets whether a deck washdown is safe.
The recovery phase pumps the contained cargo back inboard where a compatible tank exists, with the compatibility checked against the P&A Manual and the segregation plan rather than assumed. The incident closes with the entries the plan and the annex require: the Cargo Record Book operation, the SMS non-conformity and corrective-action record, and the report follow-ups to the coastal State and the flag State. The walkthrough shows why the plan is a router and not a manual: at four points, the hazard, the report addressee, the firefighting decision, and the transfer compatibility, the crew leaves the SMPEP and reads a referenced document, and the plan’s value is that it sent them to the right one fast.
Limitations
This article states the requirement and structure of the SMPEP as set by Annex II Regulation 17 and the IMO guidelines, and it does not substitute for the approved plan on a specific ship. The plan that governs a vessel is the one approved by its flag-State Administration for its Certificate of Fitness cargo list; where this article and a ship’s approved plan differ, the approved plan controls.
The 150 GT threshold and the approval requirement are stated as the consolidated Annex II text. Flag States and regional regimes can impose stricter or additional requirements: the US 33 CFR vessel-response-plan regime, for example, runs in parallel with and beyond the IMO SMPEP for ships trading to US waters, and a ship’s actual obligations are the union of the IMO requirement and every applicable national rule. This article covers the IMO baseline, not the full set of national overlays.
The hazard handling here is described at the level of how the plan routes the response, not at the level of any specific cargo’s chemistry. The reactivity, toxicity, firefighting media, and first-aid measures for a given NLS come from that cargo’s IBC Code entry, its safety data sheet, the MFAG, and the EmS Guide, all of which are revised on their own cycles. Nothing in this article should be read as cargo-specific response advice; the on-board references for the cargo in the tank are the authority.
Resolution and regulation numbers are cited as adopted: MEPC.85(44) of 13 March 2000, MEPC.137(53) of 22 July 2005, the MEPC.118(52) revised Annex II in force 1 January 2007, and the OPRC-HNS Protocol in force 14 June 2007. The IMO amends the underlying guidelines and the national contact points list on continuing cycles, and the MSC-MEPC.6/Circ. contacts appendix in particular is reissued quarterly; the dates given here are the adoption and entry-into-force anchors, not a guarantee that a later amendment has not since refined the detail. Verify the current edition of the 2010 Guidelines and the latest MSC-MEPC.6/Circ. before relying on any specific provision operationally.
See also
- MARPOL Annex II: the noxious liquid substances annex, its four pollution categories, and the full regulation set
- MARPOL Annex II Regulation 13: cargo tank washing: prewash, P&A Manual, and the Cargo Record Book
- MARPOL Annex II Reg 16: cargo tank arrangement: ship Type 1/2/3 and the Certificate of Fitness
- MARPOL Annex I Regulation 37: SOPEP: the oil-side plan and the combined SMPEP/SOPEP
- MARPOL Convention: the parent convention and its annex structure
- IBC Code: the construction and equipment code for chemical tankers
- Chemical tanker: the ship type Annex II governs
- OPRC-HNS Protocol 2000: the regional preparedness regime for hazardous and noxious substances
- Port State Control: how the SMPEP is inspected at the boarding
- NLS discharge calculator: the operational discharge-criterion tool for Annex II cargoes