U.S. regulations require a meeting before starting any oil transfer operation. Who must be in attendance at this meeting?
• 33 CFR Part 155 – especially requirements before starting oil transfer operations • The regulatory definition of "person in charge" for vessel and facility oil transfers • Who actually controls and monitors the transfer operation vs. who has overall command of the ship or terminal
• Ask yourself: during an oil transfer, which specific individuals are legally designated to oversee and directly control the transfer on each side (vessel and facility)? • Consider whether the regulation focuses on titles like master/chief engineer/superintendent, or on a particular function/role related to oil transfer operations. • Think about who must be able to agree on procedures, communications, and emergency actions right at the transfer connection.
• Verify in 33 CFR 155 who is identified as the "person in charge" of oil transfer operations on a vessel. • Verify in 33 CFR 155 who is identified as the "person in charge" of oil transfer operations at an onshore facility or terminal. • Check whether the Coast Guard is required to be physically present at every routine oil transfer, or if their role is more oversight and inspection, not mandatory attendance at each pre-transfer conference.
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