Overview

Ship to ship operations, more commonly known as “STS operations" involve the transfer of oil/gas cargo
from one vessel to another.

Over the years the transport of oil and gas has increased significantly with the size of ships growing
accordingly. However, at some ports the infrastructure may not have evolved to keep pace with the
increased size of vessel, or they may simply not have the capabilities to handle larger size vessels.
Limitations may arise from factors such as available water depth or restrictions imposed by international or
national regulatory requirements.

In addition, The STS Guidance 2nd edition introduced updated terminology, replacing the term “Mother ship”
and “Daughter ship” with “Constant Heading Ship” (CHS) and “Manoeuvring” Ship (MS).

Regulatory Requirements

STS operations are required to be conducted in full compliance with MARPOL Annex I, as adopted by IMO
Resolution MEPC.186(59) and subsequent amendments. All oil tankers of 150 GT and above engaged in
STS operations are required to carry an Administration‑approved STS Operations Plan.

The STS Operations Plan should be developed taking into account the IMO Manual on Oil Pollution and the
latest industry guidance issued by OCIMF, ICS, CDI and SIGTTO. Coastal State notification should be
made not less than 48 hours before the STS operation, or at the earliest opportunity, in accordance with
MARPOL requirements, together with the prerequisite notification information required by the relevant
authorities. If the estimated time of arrival of vessel changes by more than six hours, the master, owner or
agent of that vessel should provide a revised estimated time of arrival to local authorities.

Person in Overall Advisory Control (POAC)

STS operations are conducted under the advisory control of a suitably qualified Person in Overall Advisory
Control (POAC). The POAC may be an independent STS superintendent or one of the Masters involved in
the operation, however, this does not relieve the Masters of their duties, requirements or responsibilities
under the ISM Code.

The POAC is expected to be suitably qualified and experienced to perform all aspects of STS operations.
The POAC should hold appropriate management level deck certification in accordance with STCW,
including relevant dangerous cargo endorsements, together with recognised ship handling training and
proven experience in STS operations, a thorough understanding of cargo handling and its associated
equipment, mooring and unmooring operations and familiarity with the transfer area, spill response
arrangements and the approved STS Operations Plan.
The POAC’s role includes reviewing the location specific risk assessment, the Joint Plan of Operations
(JPO) and associated risk assessments, verifying that agreed STS operating procedures are followed and
that the STS operation is conducted in compliance with applicable regulatory requirements. This includes
confirming that all required notifications have been made to the appropriate authorities and relevant
checklists have been completed. The POAC should oversee the placement of primary and secondary
fenders and sighting and checking mooring equipment.
The POAC should conduct a pre-operations discussion with the responsible persons of all ships involved,
including Lightering Support Vessels (LSVs) and tugs and confirm that personnel involved in the STS
operation are properly briefed and understand their responsibilities. Current and forecast environmental
conditions should be discussed together with the need for their continuous monitoring throughout the
operation(s). For at sea transfers, discuss passage planning and agree courses and speeds for
manoeuvring and mooring operations.

The POAC should confirm joint agreement of the mooring and unmooring plans and review and verify that
any site specific risk mitigations are in place. During the operation, the POAC should supervise ship
approach and manoeuvring alongside, confirm the safe connection of transfer hoses/arms and any
associated Emergency Release Systems (ERS) and verify that any Emergency Shutdown (ESD) systems
are operational as required. The integrity of the mooring arrangement should be continuously monitored
throughout the operation.

In the event of an emergency, the POAC should ensure that agreed contingency plans are implemented.
The POAC should also verify that cargo transfer lines are drained and purged where required, confirm the
safe disconnection of hoses/arms and supervise the unmooring and separation of ships. If required, this
may include supervising the return of primary and secondary fenders and transfer equipment.

Human Factors and Continuous Improvement

In line with the latest STS Transfer Guide and ISGOTT 6, consideration should be given to human factors,
including fatigue management, workload, situational awareness and communication. Lessons learned from
each STS operation should be reviewed and, where appropriate, be incorporated into the existing STS
Operations Plan and company procedures. Training needs may vary between ships and operations,
depending on the experience and familiarity of the crew on board. It should be noted that factors such as
location, service provider and equipment used may result in additional training being required, even for
experienced personnel. For example:

• Provide specific training on the risk of snap-back during the cargo transfer, mooring and unmooring
operations;
• Operation of cranes during cargo hose handling and hose draining operations, including emergency
operations where applicable;
• Conduct personnel transfer operations using the Personnel Transfer Basket (PTB);
• Working safely alongside support craft, ensuring effective communication and compliance with all
required safety precautions;
• Handling transfer equipment in accordance with approved operational procedures.

Risk Assessment

A documented risk assessment should be carried out for each STS operation, covering all phases from pre-
fixture compatibility assessment, pre-arrival planning, approach and mooring, cargo transfer, completion
and unmooring. The risk assessment should consider vessel compatibility, manoeuvring characteristics,
environmental limits, mooring arrangements, fendering, hose configuration, communications, human
factors and emergency preparedness, supported by a comprehensive evaluation of both vessels’
characteristics and operational parameters to ensure safety and efficiency.

Page 2 of 6 Risk Alert 134: Safe Ship to Ship Operations

Where there is a significant size disparity between vessels, this may result in improper fender compression
and increased hull stress during mooring therefore it is advisable to verify the suitability, number and
arrangement of fenders, including calculations provided by the STS service provider.

Cargo transfer considerations should include pump capacity, pipeline diameter, allowable working
pressure, and cargo properties such as density, viscosity, and temperature, as mismatches in transfer rate
or pressure surges can introduce additional risk. Environmental and location factors, including the
availability of tug assistance, should also be evaluated to mitigate risks associated with congested waters
or limited sea room, supported by vigilant navigation watch and continuous AIS and radar monitoring.

Effective communication arrangements and systems are vital and should include compatible primary and
backup systems together with adequate language proficiency, as miscommunication or system failure can
compromise safety. Emergency preparedness should address shutdown procedures, oil spill response,
firefighting readiness, hose disconnection protocols and alignment of contingency plans between vessels to
avoid delayed responses, supported by joint safety meetings and clearly agreed emergency signals.

Readiness of Equipment for STS Operations

It is vital that during pre-contract compatibility study, Members give due consideration to every aspect of
STS operations, and the Masters of both vessels should be consulted regarding their on-board equipment.
Prior to commencement of any STS operations, POAC and Masters of both vessels should exchange
information regarding the availability, readiness and compatibility of the equipment to be used in the STS
operation. This should include confirmation of the condition, certification and maintenance history of
fenders, hoses, mooring and communications equipment, together with the readiness and reliability of the
main engine, steering gear and other essential systems. Before commencement of the STS operation, all
equipment should be confirmed as suitable, compatible and fit for purpose. Particular attention should be
given to the following:

Fenders

Members are advised to ensure that marine industry

recommended fenders, in accordance with ISO 17357-2:2014
Part 2 (or latest equivalent) are provided for the STS operations.
This should include primary and secondary of appropriate types,
quantity and size to protect the vessels from the possibility of
damage.

The POAC should advise in advance the positioning and method

of securing fenders to the vessels. Frequent areas of damage
are on the shoulder and around the accommodation areas
where secondary fenders have not been correctly positioned or
adjusted to take account of changes in draught and freeboard
and where vessels may roll together due to swell and waves.

Cargo Hoses

Hoses used for STS transfers should be suitable for the product and service intended and comply with
recognised industry standards, such as EN 1765 (or the latest equivalent). The handling, inspection and
testing of hoses should follow BS 1435 (or the latest equivalent) and relevant OCIMF guidance.

Hoses should be clearly marked with standard industry identification, including the applicable
manufacturing standard, factory test pressure (note: equal to rated working pressure, maximum working
pressure, maximum allowable working pressure), month and year of manufacture, manufacturer’s serial
number, continuity status (electrically continuous, semi‑continuous or anti‑static) and the intended service
e.g. oil or chemical. Relevant test data for each hose should be available and reviewed prior to use to
confirm that hoses are fit for purpose and leak‑free before transfer operations commence.

Page 3 of 6 Risk Alert 134: Safe Ship to Ship Operations

Hoses should be withdrawn from service when any kind of defect is identified during inspection, where
manufacturer recommended service life has been exceeded, or where temporary elongation exceeds
allowable limits. During operations, hoses should be adequately supported to avoid twisting, chafing,
excessive loading or tight bending and care should be taken to ensure that bend radius and elongation
limits are not exceeded.

Members are reminded that there is currently no single international standard that specifically addresses
hoses used for STS operations. In practice, the suitability of hoses is therefore assessed by reference to
recognised dock hose standards and offshore hose guidance applicable to the intended service.

Commonly referenced standards include BS EN 1765 and GMPHOM for oil service; BS EN 13765 for oils,
solvents and chemicals; ISO 10380, ISO 2928 and EN 13766 for LPG; BS EN 14743 for LNG; and BS EN
ISO 8031 for rubber and plastic hoses and hose assemblies. The recommended electrical properties of
hoses used in STS operations are detailed in the Guidelines for the Handling, Storage, Use, Maintenance
and Testing of STS Hoses.

Guidance for Vapour Hoses

Vapour balancing or vapour recovery operations involving Annex I and Annex II cargoes are becoming
increasingly common, although their application remains dependent on local regulations and/or client
requirements.

Members are advised to note that vapour hoses are not covered by any international standard. The
materials used in manufacture should therefore be compatible with the cargo being transferred. To avoid
vapour flow restriction or total blockage, the hose should be constructed to keep a uniform non-collapsible
profile, which is usually achieved by incorporating helical type strengthening. As the required working
pressure rating of a vapour hose need only exceed the maximum pressure and vacuum limits of the
vessel’s vapour system limits and associated safeguards, a manufacturer’s construction method may differ
from that of a liquid cargo hose.

Vapour hoses used during STS operations should be clearly distinguishable through appropriate markings
to avoid confusion with liquid transfer hoses.

Mooring Equipment

Members are advised to ensure that both vessels involved in STS operation are fitted with good quality
mooring lines, efficient winches and sufficiently strong closed fairleads, bitts and other associated mooring
equipment. Particular attention should be given to ensuring that mooring arrangements are appropriate for
STS operations and that unsafe mixed moorings are avoided, with relevant guidance such as the OCIMF
Mooring Equipment Guidelines (MEG4) taken into account.

All fairleads used should be of the enclosed type. A main consideration during mooring is the provision and
positioning of fairleads and bitts for all lines, to minimise the risk of mooring lines chafing against one
another, against the vessel’s structure or against fenders.

It is important that fairleads, bitts and mooring fixtures and fittings should be free of burrs and potential
snagging obstructions that could cause damage to the mooring lines and any potential sources of chafing
should be identified and appropriately addressed.

Where wire or high‑modulus synthetic fibre lines are used, the use of suitable synthetic fibre tails is
recommended to provide additional elasticity for STS mooring arrangements, together with adequate
buoyant messengers. Members are also advised to ensure that winch brake settings are appropriate for the
mooring configuration and line characteristics.

Page 4 of 6 Risk Alert 134: Safe Ship to Ship Operations

Communications

Good, reliable communications in the common language between all concern parties is the key for safe and
successful STS operations. From commencement through to completion of the operation, all essential
personnel should be provided with a reliable means of communication such as an explosion-proof type or
intrinsically safe handheld radio. In the event of breakdown of communications on either vessel, the vessel
should sound an agreed emergency signal. At this signal, the STS operation should be suspended and only
resumed after the regular means of communication have been restored.

Contingency Planning and Emergency Procedures

Members are reminded that, prior to committing to an STS transfer operation a thorough risk assessment
should be carried out covering all aspects of the operation, identifying potential risks and how these risks
are to be managed.

The output of the risk assessment should be used to develop risk mitigation measures and contingency
plans for credible scenarios and emergencies, including the notification of relevant authorities. Any leak or
spillage during STS operations should be reported immediately to the officers on cargo watch who should
immediately stop the cargo transfer and notify the POAC. The transfer should remain suspended until the
root cause of any leak or spillage has been identified and addressed, and it is determined to be safe to
resume the operation.

In the event of an accident, dispute or a claim and dependent on the circumstances, the Club would require
Members to provide relevant documentation and supporting evidence. This may include, but is not limited
to:

• Investigation reports, Statements from Masters of both vessels;

• The POAC and other pertinent personnel and details of POAC;
• Letters of Protests (LOPs), VDR data, logbooks’ entries, weather reports, photographs of damage
and / or other pertinent areas or equipment;
• General photographs illustrating the transfer operation including vessels alongside, mooring
arrangements and associated equipment, copies of STS Operations Plans for both vessels;
• Vessel compatibility studies, STS Operation checklists, cargo transfer checklists, copies of
Charterparties, certificates for relevant equipment such as fenders, hoses, mooring lines and
relevant maintenance records.

Suspension of STS Operations

STS operations should be capable of being suspended at any stage, with both vessels prepared, where
necessary, to unmoor and depart. The operation should be suspended when the environmental conditions
such as wind and/or sea conditions approach pre-agreed limits, or where vessel movements increase the
risk of vessel to vessel contact or the possibility of breaching the maximum permissible separation and
putting excessive strain on hoses.

Operations should also be suspended where observed or forecast weather exceeds agreed thresholds or
deteriorates rapidly, excessive relative motion develops beyond fender design assumptions, or where
mooring arrangements show signs of unsafe behaviour, including chafing, unexpected line loading or winch
brake slippage. Loss of propulsion, steering, power generation, thrusters or failure of essential tug support,
where provided, should likewise be treated as grounds for suspension.

STS operations should only be resumed once the cause of suspension has been identified, appropriate
corrective measures have been implemented, and conditions are assessed to be safe for operations to
continue.

Page 5 of 6 Risk Alert 134: Safe Ship to Ship Operations

Completion of STS Operations

On completion of the STS operation, the vessel with the greatest freeboard should close its manifold valve
and drain cargo hose contents into the tank of the other vessel. Hoses should only be disconnected once
fully drained and should then be securely blanked, as should the cargo manifolds.

Following completion of any relevant checklists, the Masters should coordinate the unmooring plan in
preparation for the unmooring operation, considering prevailing sea and weather conditions in the area.
Once cargo transfer operations are completed, the responsible person on each vessel should ensure that
all valves in their system are closed and cargo tank openings are closed and secured for sea.

For STS operations involving LNG and Refrigerated LPG cargoes,

particular consideration should be given to protecting the ships’ steel
structures against brittle fracture in areas likely to be affected by
cargo spillage. Members are also reminded that the rapid evaporation
of spilled cargo may generate a flammable vapour cloud which can
disperse downwind and pose a hazard to nearby vessels.

Conclusion

Safe STS operations rely upon careful planning, effective communication and disciplined execution
throughout every stage of the operation. Although STS transfers are often operationally necessary, they
introduce additional risks which can only be managed through proper preparation, suitable equipment and
experienced oversight.

Members are encouraged to review their existing STS arrangements against current industry guidance and
to ensure that all personnel involved are adequately trained and familiar with the requirements of the
operation before commencement.

Resources
MARPOL Annex I – Prevention of Pollution by Oil
IMO Manual on Oil Pollution
Ship to Ship Transfer Guide for Petroleum, Chemicals and Liquefied Gases, 2nd Edition (2025)
ISGOTT, 6th Edition
OCIMF Mooring Equipment Guidelines (MEG4)

Supportive Information
For further information on this or other Loss Prevention topics please contact the Loss Prevention
Department, Steamship Insurance Management Services Ltd.
Tel: +44 20 7247 5490
Email: [Link]@[Link]

The information contained in this publication is provided for general informational and guidance purposes only and does not constitute legal or
professional advice. While every effort has been made to ensure the accuracy and reliability of the content at the time of publication, no guarantee
is given that the information is complete, current or applicable to all circumstances.

Page 6 of 6 Risk Alert 134: Safe Ship to Ship Operations