Ireland’s increasing exposure to “shadow fleet” shipping is among the risks prompting a review of the State’s preparedness for a major marine pollution incident.
The Irish Coast Guard has opened a five-week public consultation on a review of Ireland’s National Maritime Oil and Hazardous and Noxious Substances (HNS) Spill Contingency Plan.
The plan, first published in 2020, provides the national framework for preparedness, response, recovery and interagency coordination following major maritime casualties and pollution incidents.
However, the Department of Transport says the maritime risk environment has changed significantly in the intervening six years.
Its Issues Paper says the likelihood of a major oil pollution incident is increasing, due partly to greater shipping activity and the “emerging use of so-called ‘shadow fleets’ in Irish waters”.
The Department says these fleets operate outside normal regulatory oversight and sanctions regimes and can involve ageing and poorly maintained vessels without adequate inspections, certification or insurance.
Afloat reported earlier this month on a sharp increase in Russian shadow fleet transits off Ireland’s west coast, with Naval Service figures recording a 189 per cent increase in passages.
Major Marine Pollution Response
The National Contingency Plan covers oil and hazardous and noxious substance pollution from sources including ships, harbours, offshore installations, cargo-handling facilities and land-based sources.
Ireland operates a three-tier response system. Smaller Tier 1 incidents are generally dealt with by the operator responsible, while Tier 2 incidents require additional regional resources and Irish Coast Guard coordination.
The national plan is designed for Tier 3 events — major incidents requiring a full national response and potentially international assistance.
The Coast Guard maintains strategically located stocks of equipment including oil-containment booms, skimmers and absorbents and has arrangements for supplementary equipment, dispersants and specialist pollution expertise.
Afloat reported on the publication of the original National Maritime Oil/HNS Spill Contingency Plan in 2020, when its introduction was described as a significant milestone in Ireland’s preparations for major marine pollution incidents.
Offshore Wind and Marine Protected Areas
The new review will examine whether Ireland has sufficient operational capability, including the balance between national resources, contracted specialist services and international assistance.
It will also consider Ireland’s resilience during the critical early stages of a significant incident, including shoreline response, environmental assessment, casualty management, salvage support, emergency towing and places of refuge.
Ireland’s expanding offshore renewable energy sector is another focus, with the review examining whether additional guidance is required for emergency preparedness, casualty response and pollution management around offshore developments.
The planned expansion of Marine Protected Areas will also have to be incorporated into future pollution-response planning. The Government’s proposed legislation aims to provide a framework for protecting 30 per cent of Ireland’s maritime area by 2030.
New Pollution Surveillance Technology
There have also been significant technological developments since the existing plan was prepared.
The European Maritime Safety Agency’s CleanSeaNet system now provides near real-time satellite oil-spill detection, vessel tracking and emergency monitoring.
EMSA has also expanded its use of remotely piloted aircraft systems for pollution detection, shoreline assessment and response operations.
Minister for Transport Darragh O’Brien said protecting the maritime environment from casualty and pollution was “critical to the lives and livelihoods that depend on it”.
Minister of State with responsibility for the Irish Coast Guard Seán Canney encouraged those involved in maritime industries and coastal businesses, as well as those with an interest in wildlife and the marine environment, to participate.
The public consultation will remain open for five weeks, closing at 5pm on Wednesday, 4 November 2026.

















































