Marine Fueling Safety
Gas stations are busy places. Cars and trucks fuel regularly, and most drivers fill their vehicles without giving it a second thought. How often have we all stood at the gas station and watched as another motorist filled their tank while talking on a cell phone, or was scrolling through social media, or doing some other mundane tasks while waiting for their tank to be full? When the nozzle clicked, and the process was complete, the driver would simply go on their way. For most, refueling is almost as routine as walking or chewing gum.
Boats need fuel too but their refueling process can be very involved. There are several regulations surrounding marine fueling, and many things to take into consideration. Spilling fuel on the ground is a big deal, and cleaning up a spill is a very complex process. Spilling fuel in the water and cleaning up after a marine fueling spill takes that to an entirely different level. For that reason, there are many additional considerations, regulations, and precautions.
If a vessel has a total capacity, from a combination of all bulk products, of 250 barrels or more, the refueling process is considered a Coast Guard regulated delivery. One barrel of oil is 42 gallons, so if the vessel has a total capacity for all bulk tanks, greater than 10,500 gallons, there are a lot of hoops to jump through, for both the vessel and the delivery vehicle.
Both the vessel and the delivery vehicle or “mobile facility” (as the Coast Guard calls it) are required to have a designated “Person in Charge” or “PIC”. PICs are required to receive annual training and must have specific experience making fuel deliveries.
Before a fueling operation is allowed to commence, the Coast Guard’s Captain of the Port (COTP) must be given advanced written notice in the form of an “Advanced Notice of Transfer”. This is required to be sent at least 4 hours before the delivery begins and must outline the time and place of the delivery, and prior history of any spills that may have taken place in the past.
PICs have specific duties and responsibilities during the transfer of fuel. They must communicate with one another prior to the transfer to ensure they’re on the same page and are each required to complete a thorough checklist to ensure the vessel and the mobile facility are in safe working order, and adequately prepared for the transfer to begin. Once both PICs have signed off, only then can the delivery process begin.
While vessels with an overall capacity of less than 10,500 gallons are not regulated by the US Coast Guard, they still require a great deal of vigilance and preparation. Permits are required to fuel commercially, and there are several regulations and training requirements. In all cases, regardless of whether a fuel transfer is Coast Guard regulated or not, there cannot be any hose connections over the water. If multiple hoses are required, the connections must be either on land, or on the vessel. It’s imperative that any hot work, sparks, flames, or other heat sources be removed from the area or stopped during the transfer. This sounds like common sense, and like something that would be easy to accomplish, but for working vessels, often the only time they must make repairs is when they are at the dock refueling, so vessel staff often try to multi-task or “kill two birds with one stone”. Delivery drivers must always remain vigilant to ensure the safety of all involved.