Reference is made to our circular 2454/2007 (web only) dated January 8th 2007.

The Clubs in the International Group are the principal providers of the Blue Cards which provide the basis for States to issue the State certificates in accordance with the International Convention on Civil Liability for Oil Pollution Damage, 1992 (CLC).

The Convention requires the owner of a ship registered in a CLC Contracting State and carrying more than 2,000 tons of oil in bulk as cargo to maintain insurance cover in accordance with the requirements of the Convention, which is evidenced by the Blue Card issued by the Club. CLC tankers must carry a State certificate on board attesting the insurance coverage.

It has been reported that some Gas Carrier Members entered in International Group Clubs have requested the issuance of Blue Cards on the basis that they are required by certain port authorities in order to meet the certification requirements of the 1992 CLC. It is understood that some Clubs may have complied with these requests.

Technically, no Blue Cards should be needed by, or issued to, Gas Carriers (whether LNG or LPG) to meet the requirements of the Convention because:

(i)   LNG vessels are not able to carry persistent oil as cargo;

(ii)   no new LPG vessels can carry oil as cargo, and

(iii)   while some old LPG vessels can carry oil as cargo they are only certified to carry clean oil products as cargo.

However, it is the case that some older LPG vessels could carry persistent oil in bulk as cargo on account of having been constructed or adapted to do so. In such cases, Blue Cards may be required since the Convention covers any sea going vessel constructed or adapted for the carriage of persistent oil as cargo when it is carrying such cargo or during any voyage following such carriage (unless it proves that it has no residues of such carriage of oil aboard). The owner of such a vessel would therefore be entitled to ask for the issuance of a Blue Card.

In all other circumstances in respect of Gas Carriers, it has now been agreed that the practice of issuing Blue Cards for Gas Carriers should be discontinued with immediate effect since this does not reflect the clear provisions of the Convention.

Those authorities that have previously requested Blue Cards for Gas Carriers have been contacted in order to educate them on the certification requirements under the Convention.

Yours sincerely,
The Swedish Club
Lars Rhodin