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COURSE MANUAL NORWEGIAN TRAINING CENTER - MANILA

(COMPENDIUM) NTC-M
of the
NMFPI
Bilge Water & Waste
Oil Operation Mgt. NORWEGIAN MARITIME FOUNDATION OF THE PHILIPPINES, INC

Section/Title Table of Contents


Revision No. 03 Effectivity Date 16 July 2007 Page No. 1 of 1

Table of Contents
TOPIC 1 Regulatory Framework
TOPIC 2 Introduction to OWS and Bilge Water System
TOPIC 3 Bilge Water Treatment Techniques
TOPIC 4 Bilge Water/Oily Waste Laboratory Facility Familiarization and Operation
TOPIC 5 Correct Entries in the Oil Record Book – Part I
TOPIC 6 Port State Control Inspections
TOPIC 7 Seafarers Role and Attitudes in Pollution Prevention

Appendices:

ORB Part 1 Oil Record Book – Part I Machinery Space Operations (All Ships) Sample IOPP Certificate
MSA Maritime Safety Advisory (MARPOL Annex 1 Requirements – Check List)
COURSE MANUAL NORWEGIAN TRAINING CENTER - MANILA
(COMPENDIUM) NTC-M
of the
NMFPI
Bilge Water & Waste
Oil Operation Mgt. NORWEGIAN MARITIME FOUNDATION OF THE PHILIPPINES, INC

Section/Title Table of Contents


Revision No. 03 Effectivity Date 16 July 2007 Page No. 1 of 2

INTRODUCTION

This course program is designed for marine engine and deck officers involved in the
management and operation of bilge water treatment system on board ships. The overall goal
of the program is to update trainees’ knowledge on existing regulations and treatment
techniques for bilge water. Practical exercises on the proper management and operation of
bilge water are emphasized to demonstrate expertise and full understanding on the treatment
and disposal processes of bilge water.

The course covers the following topics: regulatory framework on OWS, oily waste treatment
techniques, bilge water on-line monitoring system, correct entries to Oil Record Book – Part
1, port state control inspection, site assessment / faults and remedies, and seafarers’ role and
attitudes in pollution prevention.

This course is conducted for one (1) week. It consists of 21-hour lecture and 9-hour
laboratory. In general, this course aims to meet the mandatory minimum requirements for
knowledge, understanding and proficiency in relation to the competence standard of the 1995
STCW Code, Table III/1 and Table III/2 for marine engineering in the operation and
management level. This module provides the background knowledge to support monitoring
and controlling compliance with legislation to ensure protection of the marine environment.

This module provides knowledge-based and skill-based assessment of trainees’ performance.


Knowledge-based criteria shall be satisfied through written evaluation while skill-based
criteria shall be met through appropriate practical laboratory exercises and instructions.

COURSE OBJECTIVE

The objective of this course is to upgrade the knowledge and skills of trainees involved in
managing and operating bilge water treatment system on board. This functional element
provides the detailed knowledge and skills to support the tasks, duties and responsibilities in
monitoring and controlling compliance with the legislation to ensure protection of the
environment. Trainees successfully completed this course should be able to:
• explain the principles underlying MARPOL 73/78, Annex I Regulations concerning
Oil Water Separator
• describe the physical and chemical treatment methods for bilge water on board
• explain all possible modifications and improvement in handling bilge water and oily
waste on board within the context of the regulations
• write correct entries to Oil Record Book
• explain how port state control inspections are conducted
• explain seafarers’ role and attitudes in pollution prevention
COURSE MANUAL NORWEGIAN TRAINING CENTER - MANILA
(COMPENDIUM) NTC-M
of the
NMFPI
Bilge Water & Waste
Oil Operation Mgt. NORWEGIAN MARITIME FOUNDATION OF THE PHILIPPINES, INC

Section/Title Table of Contents


Revision No. 03 Effectivity Date 16 July 2007 Page No. 2 of 2

Table of Contents Topic 7: Seafarers Role & Attitude in Pollution Prevention

Topic 1 Regulatory Framework

Topic 2 Introduction to OWS and Bilge Water System

Topic 3 Bilge Water Treatment Techniques (11 Pages)

Topic 4 Bilge Water/Oily Waste Laboratory Facility


Familiarization and Operation

Diagrams:
NTC-M Bilge Water / Waste Oil Operational Management
Laboratory Facility

Topic 5 Correct Entries in the Oil Record Book – Part I

Topic 6 Port State Control Inspections

Topic 7 Seafarers Role and Attitudes in Pollution Prevention


COURSE MANUAL NORWEGIAN TRAINING CENTER - MANILA
(COMPENDIUM) NTC-M
™ of the
NMFPI
Bilge Water / Waste
Oil Operation Mgt. NORWEGIAN MARITIME FOUNDATION OF THE PHILIPPINES, INC

Section/Title Topic 1: Regulatory Framework


Revision No. 03 Effectivity Date 16 July 2007 Page No. 1 of 19

TOPIC 1

Regulatory Framework

Content: Page

1.1 International Environmental Regulations for Shipping ......................................02


1.2 Summary of MARPOL 73/78.............................................................................03
1.3 Regulations for the discharge of oil and oily mixtures .......................................05
1.4 MARPOL Annex I, Chapter I Regulations.........................................................06
1.5 Basic Elements of Marine Oil Pollution Law .....................................................10
1.6 Limits of Owner/Operator Liability....................................................................10
1.7 The US Spill Prevention Act and other related regulations................................10
1.8 Criminal Environmental Prosecutions in the Maritime Industry........................13
1.9 Bilge Water Monitoring Systems Onboard Ships...............................................15
1.10 Type approval requirements for OWS adopted by IMO ....................................17
COURSE MANUAL NORWEGIAN TRAINING CENTER - MANILA
(COMPENDIUM) NTC-M
™ of the
NMFPI
Bilge Water / Waste
Oil Operation Mgt. NORWEGIAN MARITIME FOUNDATION OF THE PHILIPPINES, INC

Section/Title Topic 1: Regulatory Framework


Revision No. 03 Effectivity Date 16 July 2007 Page No. 2 of 19

TOPIC 1
Regulatory Framework
1.1 International Environmental Regulations for Shipping

International Maritime Organization


It is in this organization that nations form the common body of law that serves to
guide international maritime transport. Through its international Conventions, the
IMO sets the regulatory framework for reducing the incidence of pollution from
ships. This framework has evolved over time, as has awareness of the maritime
sector’s environmental impact.

Currently the bulk of international regulations pertaining to pollution prevention


for ships are contained in the International Convention for the Prevention of
Pollution from Ships of 1973 as amended in 1978 and thereafter (MARPOL
73/78). This Convention seeks to reduce pollution from ships by specifying both
structural requirements and performance standards for various ship subsystems
that represent a potential source of pollution.

Flag States and Class Societies


The Flag States has the principal responsibility for complying with the IMO's
regulatory framework. These states traditionally exercise direct control over
national fleets and their crews that tended to be nationals of those states. Flag
States normally carry out their regulatory responsibilities through Class Societies.

Class Societies play an important role in ensuring the safety, seaworthiness and
quality of these national registries. Especially with an increasing number of
responsibilities being delegated to them by flag states, who have neither the
expertise nor the financial standing to ensure that vessels flying their flags are in
compliance with international conventions. The continued existence of
classification societies is very essential for the promotion of safety of life and
property at sea, as well as to conserve our sensitive environment and marine
resources.
COURSE MANUAL NORWEGIAN TRAINING CENTER - MANILA
(COMPENDIUM) NTC-M
™ of the
NMFPI
Bilge Water / Waste
Oil Operation Mgt. NORWEGIAN MARITIME FOUNDATION OF THE PHILIPPINES, INC

Section/Title Topic 1: Regulatory Framework


Revision No. 03 Effectivity Date 16 July 2007 Page No. 3 of 19

Port States
Given the complexities inherent in an international framework for registry and
class certification, Port States have increasingly exercised their right to inspect
incoming vessels. Port state inspections have become the principal rampart
against substandard shipping, at least to the extent that countries are able to, and
choose to, exercise this prerogative. Many countries have organized their Port
State Control Agencies into international groupings (“Memoranda of
Understanding” – MOU) that exchange information among participants. The
principal MOU's covers Europe, the Asia-pacific region and North America. Not
all ships are inspected, but, with the development of targeted boarding matrices,
Port State Control inspections have a fairly reasonable chance of catching the
most offensive/flagrant substandard ships.

1.2 Summary of MARPOL 73/78

The MARPOL Convention is the main international convention covering


prevention of pollution of the marine environment by ships from operational or
accidental causes. It is a combination of two treaties adopted in 1973 and 1978
respectively and updated by amendments through the years.

The International Convention for the Prevention of Pollution from Ships


(MARPOL) was adopted on 2 November 1973 at IMO and covered pollution by
oil, chemicals, harmful substances in packaged form, sewage and garbage. The
Protocol of 1978 relating to the 1973 International Convention for the Prevention
of Pollution from Ships (1978 MARPOL Protocol) was adopted at a Conference
on Tanker Safety and Pollution Prevention in February 1978 held in response to a
spate of tanker accidents in 1976-1977 (Measures relating to tanker design and
operation were also incorporated into a Protocol of 1978 relating to the 1974
Convention on the Safety of Life at Sea, 1974).

As the 1973 MARPOL Convention had not yet entered into force, the 1978
MARPOL Protocol absorbed the parent Convention. The combined instrument is
referred to as the International Convention for the Prevention of Marine Pollution
from Ships, 1973, as modified by the Protocol of 1978 relating thereto (MARPOL
73/78), and it entered into force on 2 October 1983 (Annexes I and II).
COURSE MANUAL NORWEGIAN TRAINING CENTER - MANILA
(COMPENDIUM) NTC-M
™ of the
NMFPI
Bilge Water / Waste
Oil Operation Mgt. NORWEGIAN MARITIME FOUNDATION OF THE PHILIPPINES, INC

Section/Title Topic 1: Regulatory Framework


Revision No. 03 Effectivity Date 16 July 2007 Page No. 4 of 19

MARPOL 73/78 Annexes


The Convention includes regulations aimed at preventing and minimizing
pollution from ships - both accidental pollution and that from routine operations -
and currently includes six technical Annexes:

Annex I : Regulations for the Prevention of Pollution by Oil


Annex II : Regulations for the Control of Pollution by Noxious Liquid
Substances in Bulk
Annex III : Prevention of Pollution by Harmful Substances Carried by Sea in
Packaged Form
Annex IV : Prevention of Pollution by Sewage from Ships
Annex V : Prevention of Pollution by Garbage from Ships
Annex VI : Prevention of Air Pollution from Ships

States Parties must accept Annexes I and II, but the other Annexes are voluntary.

Status of MARPOL 73/78 Annexes


From IMO: SUMMARY OF CONVENTIONS as at 30 November 2006

No. of
Entry into % world
Instrument Contracting
force date tonnage*
States
MARPOL 73/78 (Annex I/II) 02-Oct-83 138 97.84
MARPOL 73/78 (Annex III) 01-Jul-92 123 94.05
MARPOL 73/78 (Annex IV) 27-Sep-03 113 75.27
MARPOL 73/78 (Annex V) 31-Dec-88 128 96.13
MARPOL Protocol 1997 (Annex VI) 19-May-05 37 72.26

* Source: Lloyd's Register of Shipping/World Fleet Statistics as at 31 December 2005

States Parties must accept Annexes I and II, but the other Annexes are voluntary.
COURSE MANUAL NORWEGIAN TRAINING CENTER - MANILA
(COMPENDIUM) NTC-M
™ of the
NMFPI
Bilge Water / Waste
Oil Operation Mgt. NORWEGIAN MARITIME FOUNDATION OF THE PHILIPPINES, INC

Section/Title Topic 1: Regulatory Framework


Revision No. 03 Effectivity Date 16 July 2007 Page No. 5 of 19

MARPOL Annex 1
The regulations of Annex I - 2006 edition - are divided into seven (7) chapters:

Chapter 1 : General
Chapter 2 : Surveys and Certification
Chapter 3 : Requirements for Machinery spaces of all Ships
Chapter 4 : Requirements for the Cargo Areas of Oil Tankers
Chapter 5 : Prevention of Oil Pollution Arising from an Oil Pollution
Chapter 6 : Reception Facilities
Chapter 7 : Special Requirements for Fixed or Floating Platforms

This course chapter will concentrate on the regulations in chapter 2 and 3 as they
are relevant to bilge water operations.

1.3 Regulations for the Discharge of Oil and Oily Mixtures

Whether or not a discharge


is permissible depends on
the oil content, usually
expressed in ppm (parts per
million) and the location of
the ship at the time of the
discharge. The differences
in the regulations are
determined mainly by the
ecological conditions in the
areas concerned. In the Special Areas, comprising the Baltic Sea area, the
Mediterranean Sea area, the Black Sea area, (and the Red Sea area, and the Gulfs
area when they are so declared by IMO), every form of discharge is prohibited
except for those containing processed bilge water from the machinery spaces
which contain not more than 15 ppm of oil, clean ballast and segregated ballast. In
other areas a higher content of oil is allowed in the effluent from machinery
spaces and discharge of dirty ballast is also allowed provided the total quantity of
oil discharged does not exceed a fixed quantity. In those areas limits of distance
from land are imposed for the discharge of dirty ballast and other effluent having
an oil content in excess of 15 ppm. Anything that may not be discharged
according to the regulations must either be disposed on board (incinerated for
example) or retained until it can be discharged to a reception facility.
COURSE MANUAL NORWEGIAN TRAINING CENTER - MANILA
(COMPENDIUM) NTC-M
™ of the
NMFPI
Bilge Water / Waste
Oil Operation Mgt. NORWEGIAN MARITIME FOUNDATION OF THE PHILIPPINES, INC

Section/Title Topic 1: Regulatory Framework


Revision No. 03 Effectivity Date 16 July 2007 Page No. 6 of 19

1.4 MARPOL Annex I Regulations

Chapter 2 - Surveys and Certification

Regulation 7 Issue or Endorsement of Certificate


An International Oil Pollution Prevention Certificate shall be issued, after an
initial or renewal survey in accordance with the provisions of regulation 6 of this
annex, to any oil tanker 150 gross tonnage and above and any other ships of 400
gross tonnage and above which are engaged in voyages to ports or offshore
terminals under the jurisdiction of other Parties to the Convention.

This certificate shows compliance with MARPOL Annex I requirements.


COURSE MANUAL NORWEGIAN TRAINING CENTER - MANILA
(COMPENDIUM) NTC-M
™ of the
NMFPI
Bilge Water / Waste
Oil Operation Mgt. NORWEGIAN MARITIME FOUNDATION OF THE PHILIPPINES, INC

Section/Title Topic 1: Regulatory Framework


Revision No. 03 Effectivity Date 16 July 2007 Page No. 7 of 19

Regulation 10 Duration and Validity of Certificate


An IOPP Certificate shall be issued for a period specified by the Administration,
which shall not exceed five (5) years.

For extension and other provisions please refer to specifics of this Regulation.

Regulation 11 Port State Control on Operational Requirements


A ship when in a port or an offshore terminal of another Party is subject to
inspection by officers duly authorized by such Party concerning operational
requirements under this Annex, where there are clear grounds for believing that
the master or crew are not familiar with essential shipboard procedures relating to
the prevention of pollution by oil.

Based on the given circumstances the Port State shall take such steps as will
ensure that the ship shall not sail until the situation has been brought to order or
deficiency have been rectified.

Chapter 3 - Requirements for Machinery Spaces of all Ships

Regulation 13 Standard discharge connection


To enable pipes of reception facilities to be connected with the ship’s discharge
pipeline for residues from machinery bilges and from sludge tanks, the owner of
the ship shall ensure that both lines shall be fitted with a standard discharge
connection (reference to standard dimensions of flanges fro discharge
connections)

Regulation 14 Oil Filtering Equipment (OFE)


Except as specified in paragraph 3* of this regulation, any ship with 400 gross
tonnages and above but less than 10,000 gross tonnages shall be fitted with oil
filtering equipment complying with this regulation (that is, OFE shall be of a
design approved by the Administration and shall be such as will ensure that any
oily mixture discharge into the sea after passing through the system has an oil
content not exceeding 15ppm)

Any ships of 10,000 gross tonnages and above shall be provided with oil filtering
equipment complying with the same requirements stated above and with
arrangements for an alarm and for automatically stopping and discharge of oily
mixture when the oil content in the effluent exceeds 15ppm.
* Ships, such as hotel ships, storage vessels, etc., which are stationary except for non-cargo-carrying
relocation voyages need not be provided with oil filtering equipment.
COURSE MANUAL NORWEGIAN TRAINING CENTER - MANILA
(COMPENDIUM) NTC-M
™ of the
NMFPI
Bilge Water / Waste
Oil Operation Mgt. NORWEGIAN MARITIME FOUNDATION OF THE PHILIPPINES, INC

Section/Title Topic 1: Regulatory Framework


Revision No. 03 Effectivity Date 16 July 2007 Page No. 8 of 19

Regulation 15 Control of Discharge of Oil


This regulation is subject to regulation 4, chapter 1 of this annex and the
following regulatory requirements outlined below, this regulation, any discharge
into the sea of oil or oily mixtures from ships shall be prohibited.

a. Discharge outside special areas


b. Discharge in special areas
c. Requirements for ships of less than 400 gross tonnage in all areas except the
Antarctic area

For the purpose of this Annex, the special areas are:

Adoption, entry into force & date of taking effect of Special Areas
Date of Entry
Special Areas Adopted In Effect From
into Force
Mediterranean Sea 2 Nov 1973 2 Oct 1983 2 Oct 1983
Baltic Sea 2 Nov 1973 2 Oct 1983 2 Oct 1983
Black Sea 2 Nov 1973 2 Oct 1983 2 Oct 1983
Red Sea 2 Nov 1973 2 Oct 1983
“Gulfs” area 2 Nov 1973 2 Oct 1983
Gulf of Aden 1 Dec 1987 1 April 1989
Antarctic area 16 Nov 1990 17 Mar 1992 17 Mar 1992
North West
25 Sept 1997 1 Feb 1999 1 Aug 1999
European Waters
Oman area 15 Oct 2004 1 Jan 2007
Southern South
13 Oct 2006 1 March 2008
African waters
COURSE MANUAL NORWEGIAN TRAINING CENTER - MANILA
(COMPENDIUM) NTC-M
™ of the
NMFPI
Bilge Water / Waste
Oil Operation Mgt. NORWEGIAN MARITIME FOUNDATION OF THE PHILIPPINES, INC

Section/Title Topic 1: Regulatory Framework


Revision No. 03 Effectivity Date 16 July 2007 Page No. 9 of 19

Refer to the table below for summary of these requirements.

Discharge of Oil from Machinery Spaces


(Oil Tankers all sizes and other ships of more than 400 GRT)
Ship’s Location Discharge Criteria
Within Annex I Special Areas The discharge of oil collecting in machinery spaces is only permitted when the
following conditions are met:
1. The ship must be proceeding en route, and
2. The oil content of the effluent without dilution does not exceed 15 ppm, and
3. The ship has in operation oil filtering equipment with a 15 ppm !l10nitor and
automatic stopping device, and
4. bilge water is not mixed with oil cargo residue or cargo pump room bilges
(on oil tankers)
Outside Annex I Special Areas The discharge of oil collecting in machinery spaces is only permitted when the
following conditions are met:
1. The ship must be proceeding en route, and
2. The oil content of the effluent does not exceed 15 ppm, and
3. The ship has in operation oily-water separating Of filtering equipment with
a 15 ppm, and
4. bilge water is not mixed with oil cargo residue or cargo pump room bilges
(on oil' tankers)
Ship’s below 400 GRT (other than oil tankers)
Ship’s Location Discharge Criteria
Within Annex I Special Areas The discharge of oil collecting in machinery spaces is only permitted when the
oil content of the effluent without dilution does not exceed 15 ppm.
Outside Annex I Special Areas The discharge of oil collecting in machinery spaces is only permitted when the
Flag State considers that the following conditions are satisfied as far as practical
and reasonable:
1. The ship must be proceeding en route, and
2. The oil content of the effluent is less than 15 ppm, and
3. The ship has in operation MARPOL-compliant equipment suitable for
ensuring the above.

Regulation 17 Oil Record Book, Part 1: Machinery Space Operations


All ships shall be provided with an Oil Record Book Part (ORB) Part I.

ORB should be properly, accurately and completely filled up on a day to day


basis.

ORB shall be kept in such a place as to be readily available for inspection at all
reasonable times. Retention period is 3 years after the last entry has been made
COURSE MANUAL NORWEGIAN TRAINING CENTER - MANILA
(COMPENDIUM) NTC-M
™ of the
NMFPI
Bilge Water / Waste
Oil Operation Mgt. NORWEGIAN MARITIME FOUNDATION OF THE PHILIPPINES, INC

Section/Title Topic 1: Regulatory Framework


Revision No. 03 Effectivity Date 16 July 2007 Page No. 10 of 19

1.5 Basic Elements of Marine Oil Pollution Law

Some coastal States in the US consider that it is not their best interest to
participate in an international oil pollution liability and compensation regime.

Vessels engaged in Canadian trade need to have their Shipboard Oil Pollution
Emergency Plan (SOPEP) adapted to meet the Canadian Shipping Act.

In other country carrying an approved SOPEP one will be in compliance with said
law.

1.6 Limits of Owner/Operator Liability

The Brussels Convention relating to the


Limitation of the Liability of Owners, of
Seagoing Ships, 1957, enabled owners to limit
the liability for damage to property to $80 per
tonnage.

The Tanker Owners Voluntary Agreement


Concerning Liability for Oil pollution
(TOVALOP), came into force in 1969, It
accepted strict liability up to $160 per tonnage
with an upper limit of $16.8 Million per
incident.

The Oil industry contributed to a fund under the Contract Regarding an Interim
Settlement to Tanker Liability for Oil Pollution (CRISTAL) will cover $36
million per incident.

1.7 The US Spill Prevention Act and Related Regulations (US 33 CFR)

1989 Exxon Valdez incident was instrumental in inspiring the passage of the Oil
Pollution Act of 1990. The OPA Increased significantly the liability of the
responsible party of an oil spill in U.S. waters and the Exclusive Economic Zone,
including liability for all environmental damage

For nations that have accepted, ratified IMO CLC convention the owner may limit
his liability to a certain amount per gross tonnage. This liability for oil pollution
will be well within the Protection and Indemnity (P&I) Insurance with a standard
COURSE MANUAL NORWEGIAN TRAINING CENTER - MANILA
(COMPENDIUM) NTC-M
™ of the
NMFPI
Bilge Water / Waste
Oil Operation Mgt. NORWEGIAN MARITIME FOUNDATION OF THE PHILIPPINES, INC

Section/Title Topic 1: Regulatory Framework


Revision No. 03 Effectivity Date 16 July 2007 Page No. 11 of 19

coverage of $500 million. For tankers an additional cover of $200 million is


normal.

Under OPA 90 the internationally accepted limitations have been set aside leaving
the responsible party for a vessel from which the oil is discharged to be exposed
to unlimited liability that will only have an insurance coverage of $500 + $200
million.

Limitations and Problems with the OPA


• Broad damage and liability provisions have been very controversial
• Several international shipping companies have removed tankers from
US waters including A.P. Moiler, Petrofina, Teekay Shipping, and
Maersk.

Important Results of OPA


• great reduction in the number of illegal discharges of oil in the US
waters
• changes in operational procedures, safety provisions and inspection
routines implemented by the oil trades.

The Act to Prevent Pollution from Ships (APPS)


Under this act is class D Felony to knowingly violate the provisions of MARPOL.
A class D felony is punishable by up to 10 years imprisonment and a fine up to
$250,000 for an individual and $ 500,000 for a corporation for each violation

The Clean Water Act


This act prohibits the discharge of any pollutant by any person into navigable
water of the United States. A “knowing “violation of the act is felony. A
“negligent” violation is a misdemeanor. Failure to report is punishable by
imprisonment up to 5 years. The act also includes a “responsible corporate
officer”

The Rivers and Harbors Act


Under this act any discharge of refuse of any kind from a vessel into navigable
waters of United States is prohibited. A violation of the Act is misdemeanor. It is
a strict liability offense which does not require proof of either intent of
negligence. A person can be convicted of a misdemeanor violation under the act
based solely upon proof that the person places a banned substance into navigable
waters of United States
COURSE MANUAL NORWEGIAN TRAINING CENTER - MANILA
(COMPENDIUM) NTC-M
™ of the
NMFPI
Bilge Water / Waste
Oil Operation Mgt. NORWEGIAN MARITIME FOUNDATION OF THE PHILIPPINES, INC

Section/Title Topic 1: Regulatory Framework


Revision No. 03 Effectivity Date 16 July 2007 Page No. 12 of 19

The False Statement Act


This act states that providing a false statement to the US Government is illegal.
To sustain a conviction for a violation of the act the government must show
- that a statement or concealment was made
- the information was false
- the information was material
- the statement of concealment was made knowingly and willfully
- the statement or concealment falls within executive, legislative or judicial
branch jurisdiction

Responsible Corporate Officer Doctrine


A person may be criminally liable for the acts of another person in an
organization and is criminally liable when that person has knowledge of a
criminal violation committed by a subordinate, has the authority to stop or prevent
the violation, and fails to stop or prevent the violation.

Witness Tampering
Is when a person or company knowingly uses intimidation or physical force to
influence testimony, causes or induces a witness to withhold testimony, or alters,
destroys, conceals, and/or evades the legal process in connection with an ongoing
investigation of pollution and/or illegal discharge incidents then, he/she is
criminally liable.

Failure to Report a Discharge of Oil or Hazardous Substances Under the


Clean Water Act
Is when a person in charge of a vessel or facility from which oil or a hazardous
substance is discharged, in a quantity that may be harmful, fails to immediately
notify the federal government as soon as he has knowledge of the discharge then,
he/she, too, is criminally liable.

Willful Blindness
A person also may be criminally liable under the doctrine of willful blindness. If a
person is aware that there is a high probability that criminal activity is occurring,
but that person deliberately avoids learning the truth about the activity, then that
person may be considered to have acted knowingly for purposes of criminal
liability under the willful blindness doctrine.
COURSE MANUAL NORWEGIAN TRAINING CENTER - MANILA
(COMPENDIUM) NTC-M
™ of the
NMFPI
Bilge Water / Waste
Oil Operation Mgt. NORWEGIAN MARITIME FOUNDATION OF THE PHILIPPINES, INC

Section/Title Topic 1: Regulatory Framework


Revision No. 03 Effectivity Date 16 July 2007 Page No. 13 of 19

US Spill Liability Trust Fund


When the responsible party is unknown or refuses to pay, funds from the Oil Spill
Liability Trust Fund can be used to cover removal costs or damages resulting
from discharges of oil.

The primary source of revenue for the Fund is a five-cents-per-barrel fee on


imported and domestic oil.

1.8 Criminal Environmental Prosecutions in the Maritime Industry

During the 1990s, the United States’ use of criminal penalties to enforce
environmental laws, particularly as related to the maritime industry, was viewed
by the rest of the world as heavy handed and unnecessary. Today, however, like
the US, many countries are using criminal enforcement as an important tool in
their effort to protect the environment and achieve compliance through
deterrence. The historical inclination of regulatory authorities to emphasize
compliance over punishment is changing and punishment is increasingly taking a
greater role in environmental enforcement.

This is exemplified by the recently


adopted European Commission (EC)
ship pollution directive, focused on
criminal enforcement, whereas
previous European Union (EU)
environmental directives have focused
on policy-making aspects of
environmental laws and programs
while ignoring issues of
implementation and enforcement. On 5
March 2003, the EC adopted a ship-source pollution directive which, if adopted
by the European Parliament and Council, will lead to the imposition of criminal
sanctions for those responsible for ship pollution. According to an EC vice-
president, the ‘existing civil liability regimes for pollution by ships [do] not
provide sufficient financial disincentives for shipowners and others involved in
the transport of dangerous cargoes by sea to behave in the most responsible way’.

Article 6 of the proposed directive states that ‘intentional or grossly negligent’


pollution by vessels should be regarded as criminal offences. Sanctions will be
applicable to any person including the master, the owner, the operator and the
charterer of a ship and to the classification society who has been found to have
COURSE MANUAL NORWEGIAN TRAINING CENTER - MANILA
(COMPENDIUM) NTC-M
™ of the
NMFPI
Bilge Water / Waste
Oil Operation Mgt. NORWEGIAN MARITIME FOUNDATION OF THE PHILIPPINES, INC

Section/Title Topic 1: Regulatory Framework


Revision No. 03 Effectivity Date 16 July 2007 Page No. 14 of 19

caused or contributed to illegal pollution, intentionally or by means of gross


negligence. The penalties include fines and imprisonment.

The proposal is an effort by the EC to stop the discharge of waste, including cargo
residue, from ships in EU and international waters. Specifically, the directive
provides detailed rules for the discharge of polluting substances, including oil and
chemicals, and makes any violation of those rules illegal in EU waters. In
addition, the proposed directive prohibits pollution on the high seas, irrespective
of the flag of the ship.

This directive has drawn much criticism from the shipping industry. In response
to the directive, INTERTANKO, the International Chamber of Shipping, the
European Community Shipowners’ Association and the Oil Companies
International reacted on the above-mentioned directive.

Marine Forum have submitted a joint position paper to the European Parliament
highlighting potential problems with the proposal, including concern that some of
the criminal sanctions outlined in the directive would undercut internationally
agreed standards and be in direct conflict with the International Convention for
the Prevention of Pollution from Ships (MARPOL) and the United Nations
Convention on the Law of the Sea. This newfound aggressiveness of the EU rivals
that of the US, which has been criminally prosecuting environmental cases against
the maritime industry since the mid-1990s and continues to do so, more
aggressively than ever, through the United States Department of Justice’s (DOJ)
Vessel Initiative. The DOJ continues to focus on the maritime industry.
Government officials warn that the Vessel Initiative will continue until the
number of referrals ‘dwindles to zero’ and has recently stated that the pollution
problem is ‘so rampant and so pervasive within the maritime community’ that it
has ramped up enforcement and is prosecuting cases up and down all US coasts.

Source: BIMCO Review 2004

“Pollution doesn’t mean much to us unless or until it hits us from a legal or a


personal perspective, or both.”
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Section/Title Topic 1: Regulatory Framework


Revision No. 03 Effectivity Date 16 July 2007 Page No. 15 of 19

1.9 Bilge Water Monitoring Systems Onboard Ships

Low Capacity is mainly used for bilging of engine room spaces onboard all ships
above 400 GRT operating in a range of 15ppm. This is the system that is most
common known by port state inspectors. It consists of a bilge water separator with
a bilge alarm unit.

High Capacity is used onboard oil tankers above 150 GRT and above operating
in a variable range of ppm for bilging of pump room spaces, slop tanks and clean
ballast tanks.
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Section/Title Topic 1: Regulatory Framework


Revision No. 03 Effectivity Date 16 July 2007 Page No. 16 of 19

Examples of a suitable arrangement of a machinery space bilge-water handling system


in an existing ship based on IMO regulation
15 ppm Oil Content Detector

Overboard
O
Bilge Transfer Pump W
S

Type Approved
MEPC.60 (33)
Bilge Holding Tank Separated Oil Tank
Return line

15 ppm Oil Content Detector

Automatic Data Logger


Overboard
O
Bilge Transfer Pump W
S

Type Approved
MEPC.60 (33)
Bilge Holding Tank Separated Oil Tank
Return line
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Section/Title Topic 1: Regulatory Framework


Revision No. 03 Effectivity Date 16 July 2007 Page No. 17 of 19

1.10 Type approval requirements for OWS adopted by IMO

1. The first type approval was based on IMO resolution A.393(X)


“Recommendation on international performance and test specifications for
oil-water separating equipment and oil content meters” For equipment
installed onboard on or after 14th November 1978.

Required oil content in the effluent discharge: 100 ppm

2. The second update of the requirement took place by IMO resolution


MEPC.60(33) “ Guidelines and Specifications for pollution prevention
equipment for machinery space bilges of ships”. For equipment installed
onboard on or after April 30, 1994.

Required oil content in the effluent discharge: 15 ppm

3. The latest update of the requirements for type approval of bilge separators and
bilge alarm is laid down in MEPC Resolution 107(49) “Revised guidelines
and specifications for pollution prevention equipment for machinery spaces”.
Adopted on July 18, 2003 and is valid for equipment installed on or after
January 1, 2005.

Required oil content in the effluent discharge: 15 ppm (but can handle
emulsion)

Typical vessel type approved OWS Marinefloc OWS System


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Section/Title Topic 1: Regulatory Framework


Revision No. 03 Effectivity Date 16 July 2007 Page No. 18 of 19

Difference between MEPC.60 (33) and MEPC.107 (49) are:

1. Automatic data logging device


2. Performance compliance involving emulsified oil

New Requirements from 1st January 2005

Operational Requirements for 15 PPM Bilge Separators with 15 PPM Bilge Alarm
based on MEPC. 107(49):
• Equipment installed have to be type approved
based on this resolution
• Type approval certificate have to be onboard
• SOPEP manual have to be onboard
• IOPP certificate to be onboard
• Calibration certificate for the 15 PPM bilge
alarm
• Oil Record Book I

When in operation the following data shall be automatically recorded / available:


• date, time
• alarm status and operating status
• store data for at least eighteen months
• able to display or print a protocol for official inspections as required.

To prevent tampering:

9 Every access of the 15ppm Bilge Alarm beyond the essential requirements of
paragraph 4.2.8 requires the breaking of a seal.

9 The 15ppm Bilge Alarm should be so constructed that the alarm is always
activated whenever clean water is used for cleaning or zeroing purposes.
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Section/Title Topic 1: Regulatory Framework


Revision No. 03 Effectivity Date 16 July 2007 Page No. 19 of 19

Operational requirements for ODME separator with Bilge Alarm and Control
Equipment based on MEPC. 108(49)

• Equipment installed have to be type


approved based on this resolution
• Type approval certificate
• Operation and maintenance manual
• SOPEP manual
• IOPP Certificate
• Calibration certificate for the bilge alarm
• Oil Record Book II

When in operation the following data shall be automatically recorded


• Instantaneous rate of discharge of oil (liters per nautical mile)
• Instantaneous oil content (PPM)
• The total quantity of oil discharged
• Time and date (GMT)
• Ship’s speed in knots
• Ship’s position- Latitude and Longitude
• Effluent flow rate
• Status of the overboard discharge control or arrangement
• Oil type selector setting, where applicable
• Alarm condition
• Failure (i.e. manual override, flushing, calibration, etc.)

The Bilge Water Monitoring Equipment (OCM) and Oil Discharge Monitoring
Equipment (ODME) must never be mixed up. ODME is only for use with slop and
ballast water.

***
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Section/Title Topic 2: Introduction to OWS and Bilge Water System


Revision No. 03 Effectivity Date 16 July 2007 Page No. 1 of 24

TOPIC 2

Introduction to OWS and Bilge Water System
Content: Page

2.1 Introduction.........................................................................................................02
2.2 The Oily Water Separation System.....................................................................03
2.3 The Components of OWS System ......................................................................04
2.4 The problems with OWS System........................................................................05
2.5 Shifting emphasis................................................................................................05
2.6 Is this the machinery space you have onboard?..................................................06
2.7 Have you observed this on board? ......................................................................07
2.8 Different US agencies .........................................................................................09
2.9 What do they look for? .......................................................................................10
2.10 Basic principle of oil and water separation.........................................................15
2.11 Typical Oily Water Separator .............................................................................19
2.12 Some important regulations for OCM ................................................................19
2.13 Test method during Port State Control Inspection..............................................20
2.14 Limitations of gravity type coalescing separators ..............................................20
2.15 Main factors that affect oil water separator performance ...................................21
2.16 Bilge water generation ........................................................................................21
2.17 Bilge water composition .....................................................................................21
2.18 Emulsions are created in two ways.....................................................................22
2.19 Emulsion separation test .....................................................................................23
2.20 Typical bilge water treatment system process flow diagram..............................23
2.21 Waste oil collection, treatment and disposal.......................................................24
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Section/Title Topic 2: Introduction to OWS and Bilge Water System


Revision No. 03 Effectivity Date 16 July 2007 Page No. 2 of 24

TOPIC 2
Introduction to OWS and Bilge Water System
2.1 Introduction

The Bilge area is the lowest inner part of the ship’s hull where liquid from the
interior spaces and upper decks of the vessel drain. The primary sources of bilge
water are the main engine room and auxiliary machinery rooms. Untreated bilge
water is expected to contain high concentration of Oil and Grease and other oil-
soluble components. OWS systems have been installed on most vessels 400 Gross
Tonnage and above, part of the requirements of the international agreement on
pollution prevention from ships, MARPOL 73/78, ruled by the International
Maritime Organization (IMO). The IMO Resolution MEPC.107 (49), “Revised
Guidelines and Specifications for Pollution Prevention Equipment for Machinery
Space Bilges of Ships”, has been adopted on 18th July 2003 and applies to all oily
water separators and 15 ppm alarm monitor installed onboard on or after 1st
January 2005. Figure below shows a typical arrangement of oil filtering
equipment and oil content monitoring device installed on board ships today.
15ppm ALARM
MONITOR

OIL
WATER
SEPARATOR
(OWS) TO BHT
OVERBOARD
DISCHARGE
< 15ppm

BILGE
TRANSFER
PUMP

BILGE SEPARATED
HOLDING OIL TANK
TANK OR SLUDGE
(BHT) TANK

Typical arrangement of a machinery space bilge water treatment system in an existing ship
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Section/Title Topic 2: Introduction to OWS and Bilge Water System


Revision No. 03 Effectivity Date 16 July 2007 Page No. 3 of 24

The new resolution describes in detail the type approval procedures for OWS and
oil content monitoring devices. With the possibility of emulsified bilge water
always present, the OWS must be capable of separating the oil from the emulsion
to produce an effluent discharge with an oil content not exceeding 15 ppm. The
new resolution required performance compliance of oily water separator
involving oil-in-water emulsion. Existing shipboard OWS may not achieve this 15
ppm discharge requirements unless further steps are taken. Adaptation and
modification of some of the concepts of emulsion breaking are necessary to
improve bilge water treatment operation and to comply with the regulation.

2.2 The OWS System

An Oily Water Separation system, as compared to OWS equipment, is a wide-


ranging system that is not just confined to the vessel, but extends to regulatory
organizations and port engineering staff and shore based support contractors.

The objective of an OWS system is to separate the oil from bilge water, to pump
the clean bilge water overboard and to allow for storage and disposal of the waste
oil.

2.3 The components of OWS system

• Bilge water sources


• Bilge water contaminant sources
• Bilge water treatment, including the OWS
• Waste oil storage
• Waste oil disposal
• Oil Record Book (ORB)
• OWS system Operators (Human Factors)
• Regulatory enforcement agencies
• Waste oil receivers/incinerators
• Economic factors
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Section/Title Topic 2: Introduction to OWS and Bilge Water System


Revision No. 03 Effectivity Date 16 July 2007 Page No. 4 of 24

Bilge Water Contaminant Sources:


Bilge water can be contaminated by any material that is present aboard a vessel
and that can be pumped as a mixture with bilge water.

The following contaminants are often found aboard a vessel and therefore in the
bilges:
1. Old lube oil (from engine and equipment leaks)
2. New lube oil (from spills when filling equipment)
3. Soap (from engine room sinks)
4. Soot (in fine mist from engine exhaust)
5. Soot (in larger particles from boiler cleaning)
6. Bilge, tank and heat exchanger cleaners
7. Fuel oil purifier waste such as water and sludge
8. Fuel oil (from manifold leaks, equipment failure, etc.)
9. Wear products such as found in old lube oil
10. Rust
11. Antifreeze
12. Hydraulic oil (from leaks or filling)
13. Paint chips and residue (from painting activities or paint failure)
14. Solvents (from paints, spills and parts cleaning)
15. Biological contaminant (algae from strainer cleaning, and microbial
contamination)
16. Mud (from strainer and equipment cleaning)
17. Sewage (from leaks)

2.4 The problems with Oily Water Separation System

“It was an intimidating event, several years ago, when excessive penalties were
imposed on some shipping companies under, on suspicion of illegal use of OWS in
US ports. Since then the word “Punitive Damage” has taken on a frightening
meaning to us, when our vessels call at US ports”

“For the general public, the importance of Pollution Prevention as a measure to


reduce risk to environment and human health is also emphasized. Hopefully
cleaner air and seas will be made available to mankind as the ultimate
recompense.”
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Section/Title Topic 2: Introduction to OWS and Bilge Water System


Revision No. 03 Effectivity Date 16 July 2007 Page No. 5 of 24

2.5 Shifting Emphasis

PREVENTION

CONTROL PREVENTION

CLEAN UP CONTROL

CLEAN UP

(a) (b)

(a) This type of approach typically resulted in high, non-productive capital and
operational cost that added no value to the services provided to the public

(b) Pollution prevention programs encourage the kinds of changes that are likely
to lead to lower operating costs, fewer costly spills and result in increased
efficiencies and more effective protection of environment

“The proliferations of GREEN legislations and heightened environmental


expectations have resulted into the emergence of environmental performance as
an element of competitiveness.”
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Section/Title Topic 2: Introduction to OWS and Bilge Water System


Revision No. 03 Effectivity Date 16 July 2007 Page No. 6 of 24

2.6 Is this the machinery space you have onboard?

or this?
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Section/Title Topic 2: Introduction to OWS and Bilge Water System


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2.7 Have you observed this onboard?

9 Poor maintenance and housekeeping in the engine room


9 Deliberate discharge oily bilge water overboard
9 By-passing the OWS
9 Overriding sensors of OWS
9 Tampering with OWS monitoring equipment
9 False statements in the ship’s Oil Record Book

Have you observed this onboard?

(a)

(b)
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Section/Title Topic 2: Introduction to OWS and Bilge Water System


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(c)

(d)
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Section/Title Topic 2: Introduction to OWS and Bilge Water System


Revision No. 03 Effectivity Date 16 July 2007 Page No. 9 of 24

Identify what is in the picture…

2.8 US Agencies that might be involved in the investigation


9 Oily Water Separation Systems Task Force
9 USCG Investigative Service
9 US EPA Criminal Investigation Division
9 Environmental Crimes Section of US DOJ
9 US Attorney’s Office
9 Federal Bureau of Investigations
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Section/Title Topic 2: Introduction to OWS and Bilge Water System


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2.9 What do they look for?

(a)

(b)
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Section/Title Topic 2: Introduction to OWS and Bilge Water System


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OWS overboard

(c)

(d)
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Section/Title Topic 2: Introduction to OWS and Bilge Water System


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(e)

(f)
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(g)

(h)
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(i)

(j)
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Section/Title Topic 2: Introduction to OWS and Bilge Water System


Revision No. 03 Effectivity Date 16 July 2007 Page No. 15 of 24

What do they look for?


9 Crew lack of familiarity with Oily Water Separator system
9 Lack of sludge receipts for discharge ashore, inoperable or rarely used
incinerators
9 Oil Record Book irregularities
9 Evidence of oil leaking from valve stem packing or from gauges associated
with non-oil systems

2.10 Basic Principles of Oil and Water Separation

Heavy things sink ?

"water sinks in oil as water is denser than oil".


or
"oil floats on water as oil is less dense than water".

Density - Mass per unit volume

Water Oil

1 ton / m³ 0.85 ton / m³

Specific Gravity - ratio of the density of a substance to the density of water

Water Oil

1.0 0.85

No. 2 Tank has fuel oil with specific gravity of 0.85, No. 6 tank has fuel oil
with specific gravity of 0.95. Which of this substance rises faster when mix
with water?
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Section/Title Topic 2: Introduction to OWS and Bilge Water System


Revision No. 03 Effectivity Date 16 July 2007 Page No. 16 of 24

• SG of water – SG (fuel oil in no.2 tk ) = 0.15


• SG of water – SG (fuel oil in no.6 tk ) = 0.05

Fuel oil in No. 2 Tank will rise 3 times faster than fuel oil in N0 6 Tank mix with
water, if all parameters remain the same.

Viscosity - quality or property of a liquid that causes it to resist flow.

Stoke’s Law

The greater the difference in specific gravity (SG) between oil and water, the
faster the oil droplet will rise in water.

The lower the oil viscosity, the faster the oil will rise in water. Increasing the
temperature will significantly reduce the oil viscosity.

Oil droplets in water at 40oF will rise at only half the rate as it would be at 90⁰F,
if all parameters remain the same.

When 10 micron droplet is increased to 1000 micron droplet, the 1000 micron
droplet will rise 10,000 times faster than of 10 micron droplet during oil-water
separation
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Section/Title Topic 2: Introduction to OWS and Bilge Water System


Revision No. 03 Effectivity Date 16 July 2007 Page No. 17 of 24

90⁰F
40⁰F

The rise velocity of oil droplets in water increases as the square of droplets
diameter, if all other parameters are held the same.

Gravitational separation important factors


• Specific Gravity
• Viscosity
• Coalescence

Increasing oil globules diameter is far more effective in accelerating oil rise
velocity than modifying the specific gravity and viscosity of oil and water.
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Section/Title Topic 2: Introduction to OWS and Bilge Water System


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What is coalescing ?

“It mean uniting or growing together".

Coalescer media
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2.11 Typical Oily Water Separator

Oil Content Meter

2.12 Some important regulations for OCM as stipulated in MEPC.60(33)

Flow regulator
PPM display

Desicator
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• A ppm display should be provided


• It should not be necessary to calibrate the 15 ppm Bilge Alarm on board
ship.
• But onboard testing according to the manufacturers instruction shall be
permitted.
• The accuracy should be within ±5 ppm. The accuracy of a 15 ppm Bilge
Alarm should remain within the above limits despite the presence of
contaminants other than oil, and the power supply varying by 10% from the
design value, i.e. in respect of electricity, compressed air, etc.
• The response time should not exceed 5 seconds during sample alteration 15
ppm Bilge Alarm Monitor
• There should be a means of checking the instrument drift, repeatability of
the instrument reading, and the ability to re-zero the instrument.

2.13 Test method during Port State Control Inspection:


• to confirm zero ppm reading of the oil content meter when fresh water is
supplied, through the meter
• to sample the filtered water from the test cock of the oil filtering equipment
or the outlet of the oil content meter in a cup with a bilge pump supplying
bilge water to confirm no visible oil content;
• to carry out an "opening-out" examination of the oil filtering parts and
associated piping when the sampled water in contains visible traces of oil;
• to confirm the normal operation of the oil content meter taking account of
the condition of the sampled water, where the meter is fitted

2.14 Limitations of gravity type coalescing separators


• The most significant weakness of current OWS technologies is the inability
to reliably handle emulsified oils.
• These processes are effective in removing the free-phase oils, however they
do not easily break down a stable chemical or mechanical emulsion.
• Detergents and chemicals, transfer pumps, and the ship’s motion all
contribute to the emulsification of the oils so the OWS must be able to
handle this influent stream.
• In addition to emulsified oils, a bilge may contain fibers or other solids that
can clog filter media increasing maintenance cycles.
• Ceramic bead, coalescing media, and other filter based technologies require
high levels of maintenance and operational man hours driving up the overall
operating cost.
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Section/Title Topic 2: Introduction to OWS and Bilge Water System


Revision No. 03 Effectivity Date 16 July 2007 Page No. 21 of 24

2.15 Main Factors that affect oil-water separator performance:


• Flow rate
• Specific Gravity of Oil
• Viscosity of Oil
• Operating Temperature
• Fluid Characteristic: % of free oil, % of soluble oil, diameter of oil globules,
extent of mechanical emulsion
• pH of feed Stream
• Other contaminants present in feed stream

2.16 Bilge Water Generation

• Cleaning and maintenance • Water from purifier • Condensate from air


• Drains and leaks sludge tanks coolers
• Tank overflows • Water from waste oil
tank

Bilge Holding Tank

2.17 Bilge Water Composition

Fresh water
Water
Seawater

Heavy Fuel Oil


Emulsion,
Oil Lube oil
Hydraulic Oil Suspension
Organic
Particles Inorganic
Emulsifying, Corrosive
Chemicals Other
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Section/Title Topic 2: Introduction to OWS and Bilge Water System


Revision No. 03 Effectivity Date 16 July 2007 Page No. 22 of 24

Other media that can be present in the bilge holding tank


• Stern Tube Oil: Heavy Emulsifier
• M.E. and A.E. Lube Oil: Emulsifier
• Hydraulic Oil: Heavy Emulsifier
• Light Detergents: Heavy Emulsifier
• Heavy Duty Detergents: Heavy Emulsifier
• Cip-Liquid: Very Heavy Emulsifier
• Cooling Water form M.E.
• Boiler Water: High pH value
• Foam Liquid: Heavy Emulsifier
• Outer Special Oil
• Soot water: Low pH Value
• Parts of Metals
• Black Water: Chemical, Fibers, Colony of bacteria
• Grey Water: Different types of chemicals

2.18 Emulsions Are Created In Two Ways


1. Mechanical emulsion: In mechanical emulsions a common method of
creating the emulsion is by violent mixing or shearing of the oil droplet in
the wastestream with a high shear transfer pump, or other device that might
disperse the oil droplets into minute droplets. Given enough time, the
mechanical emulsion may break without any treatment.
2. Chemical emulsion: Are created when a surface-active chemical or
chemicals like detergents are used, such as alkaline cleaners containing
surfactants, soaps and detergents having ionic or nonionic characteristics.
These chemicals interfere with the natural coalescing of oil droplets and
generally create a permanently stabilized emulsion with little chance of
breaking by itself.

“…often oily water separation equipment problems are caused by emulsions


resulting from cleaning chemicals and by fouled bilges”

To avoid problems caused by emulsions, use the cleansing agents which are
recommended by the manufacturer of oil filtering equipment or cleansing
agent that pass emulsion separation test.
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Revision No. 03 Effectivity Date 16 July 2007 Page No. 23 of 24

2.19 Emulsion separation test

1. Fill 2 bottles of approx. 0.5 ltrs. in size abt . 60% full of clean fresh water.
Add approx. 10% of oil, preferably fuel oil in both bottles, to one bottle
only add 2%, or an amount specified by cleansing agent to be tested shake
both bottle well by hand approx. 1 min. Let both bottle stand.
2. The bottle without cleansing agent should show clear water underneath the
oil within relatively short period of time. The other bottle will need more
time for separation; the time needed for this bottle is the so called separation
time which should be less than 1 hr. At the end of the separation time, the
mixture of this bottle should have water with light turbidity at least over half
the height of the bottle.
<Insert Picture of Result>

2.20 Typical Bilge Water Treatment System process flow diagram

OWS Overboard Discharge


< 15ppm

Pretreatment
System
NOx, SOx, CO, PM

BHT Sludge Tank Incinerator


Ash
or or
Port facility
Disposal
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Revision No. 03 Effectivity Date 16 July 2007 Page No. 24 of 24

2.21 Waste oil collection, treatment and disposal


1. Recovered liquid waste can be temporarily stored in leased collection
vessels, barges, large bladders, portable tanks, or tank trucks. The recovered
liquid will then be transferred to a central waste storage facility for longer-
term storage.
2. Liquids with low oil content may be transported to a wastewater treatment
or produced water treatment facility.
3. Liquids with high oil content, however, may be processed at the produced
water treatment facility, or incinerated.
4. Shore based treatment facilities develop ways to re-use oily waste products
from ships. (ex. as secondary liquid fuel used to fire cement kilns)

***
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Section/Title Topic 3: Bilge Water Treatment Technique


Revision No. 03 Effectivity Date 16 July 2007 Page No. 1 of 11

TOPIC 3

Bilge Water Treatment Techniques
Content: Page

3.1 Introduction.........................................................................................................02
3.2 Summary of oil-waste treatment technologies for shipboard application ..........02
3.3 Gravity type separators .......................................................................................03
3.4 Gravity type coalescing separators and membrane filtration..............................03
3.5 Emulsion Breaking Bilge Water Cleaning System from Marinefloc AB...........05
3.6 Shipboard Bio-Mechanical Oil Water Separator from Ensolve USA ................06
3.7 Principle of Coagulation and Flocculation .........................................................07
3.8 Important process parameters during flocculation..............................................09
3.9 Possible improved pre-treatment method of bilge water ....................................09
to comply with the regulation
3.10 Shipboard incinerator..........................................................................................10
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Section/Title Topic 3: Bilge Water Treatment Technique


Revision No. 03 Effectivity Date 16 July 2007 Page No. 2 of 11

TOPIC 3
Bilge Water Treatment Techniques
3.1 Introduction

There are various bilge water treatment methods and processes available
in order to comply with the regulation. The current treatment technologies
for bilge water are summarized below. However, the types and
arrangements of treatment processes and equipment used may vary from
ship to ship, depending on its classification and operation.

3.2 Summary of oily-waste treatment technologies for Shipboard Application

1. Physical Treatment Technologies


- make use of the waste physical properties to separate and/or concentrate
the waste, but do nothing to detoxify or change its chemical
characteristics.

Examples:
Sedimentation and Filtration

2. Chemical Treatment Technologies


- make use of the waste’s chemical characteristics to manipulate,
concentrate, transform and/or detoxify the pollutants.

Examples:
neutralization, electrolysis, chemical precipitation and flocculation, oxidation
and reduction

3. Thermal Treatment Technologies


- make use of heat to separate, concentrate, or destroy waste. Incineration is
undoubtedly the oldest waste treatment method.

- but, due to its tendency to form small amounts of harmful by-products,


incineration remains the most controversial method used for the
destruction of waste.

(Refer to MARPOL Annex VI for the operational requirements of waste


incinerator)
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Section/Title Topic 3: Bilge Water Treatment Technique


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4. Biological Treatment Technologies


- make use of living organism to separate, concentrate, or detoxify waste.

- used of bacteria and other microorganism to remove unwanted


hydrocarbons from contaminated waste water.

Example:
Bioremediation

3.3 Gravity type separators


The simplest separators of this type are nothing more than large holding tanks
which may be coupled together in series. The free phase oil float may be skimmed
or pumped off and the separated water is drained or pumped off from near the
bottom of the tank. When such tanks are coupled in series the oil from the top of
the first tank is fed into the second tank and any dispersed water remaining in the
oil will have additional opportunity to separate and of course the water quality
removed from the bottom of the second tank will exceed that of the first. For
cases where the pumping is continuous, the pumping rate determines the
residence time and this affects the degree of separation. However it is doubtful if
the effluent discharge will be less than 15 ppm at any pumping rate.

Gravity type separator

3.4 Gravity type coalescing separators and membrane filtration


When oily water is forced to pass through some type of oleophilic medium oil
droplets will tend to adhere and collect. They will join together by cohesive
attraction thereby increase their overall diameters and reduce the population
density of smaller droplets. The rate of separation of oil from water is directly
proportional to the square of droplet diameter this is the simplest and most
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significant action which can be taken to separate an oil-water mixture (Stoke’s


Law). Figure below displays an example of such a separator.

Gravity type coalescing separator (Source: Coffin World Water System)

Gravity separation followed by skimming


is effective in removing free phase oil
from oily wastewater. OWS such as the
IMO approved separator, shown in figure
below and its variations have found
widespread acceptance in the maritime
industry as a low cost primary treatment
of bilge water. However, it is not effective
in removing smaller oil droplets and
emulsions. Gravity type coalescing
separators are suitable for emulsions that
have been induced mechanically;
coalescing separators can remove free oil
droplets by gravity if they are larger than
20 microns.
Typical IMO type approved oil water
separator (source: JOWA AB)
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A typical OWS design consists of 50 plates, arranged in parallel on 2 cm, centers.


The plates are supported by a series of gutters, which isolate the collected
contaminants from the wastewater stream. As wastewater flows through the
coalescer media, oil droplets coalesce on the plate and rise to the surface. The
coalescing media pack is usually made of corrugated polyvinyl chloride,
fiberglass or poly propylene material. Sediments settle at the bottom.

Some of the problems presented when using this type of separator are: (1)
Ineffective separation when oil or emulsion content exceeds 40–50% of the
influent evidenced by an increase of free water in the oil effluent and higher
concentration of hydrocarbon in the water effluent; (2) Requires pre-filtering
system to facilitate removal of particles greater than 6mm in diameter that may
clog the coalescing media.

Membrane filtration processes such as microfiltration, ultrafiltration,


nanofiltration and reverse osmosis are increasingly being applied as secondary
treatment for treating oily wastewater. Membranes are most useful with stable
emulsions, particularly water-soluble oily wastes. However, it has been said that
concentration-polarization and membrane fouling is a serious problem in
membrane filtration. Chemical or physical influences can easily lead to a
permanent clogging and even chemical cleaning process cannot restore the
permeate flow.

3.5 Emulsion Breaking Bilge Water Cleaning System from Marinefloc AB

Key Technology: Chemical Treatment


Main Features:
• <3 PPM of Oil in the discharge water outlet
• An EBBWCS can be tailor-made for each ship
• Existing OWS can be used when necessary
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Marinefloc System Diagram

3.6 Shipboard Bio-Mechanical Oil Water Separator from Ensolve USA

Key Technology: Biological treatment method


Main Features:
• This automated bio-mechanical system is safe, reliable and requires low
maintenance.
• Unlike conventional oil water separators, the Bio-Mechanical OWS actually
destroys oil and grease using naturally occurring bacteria.
• It is specifically designed to treat oils emulsified by detergents or the ship's
motion. Emulsified oil is easier for the bacteria to consume because it
provides "bite size pieces" to the bacteria.
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Ensolve Biomechanical Oil Water Separator

3.7 Principle of Coagulation and Flocculation


In wastewater treatment operations, the
processes of coagulation and flocculation are
employed to separate suspended solids from
water. Although the terms coagulation and
flocculation are often used interchangeably, or
the single term "flocculation" is used to
describe both; they are, in fact, two distinct
processes. Knowing their differences can lead to a better understanding of the
clarification and dewatering operations of wastewater treatment.
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Finely dispersed solids (colloids) suspended in wastewaters are stabilized by


negative electric charges on their surfaces, causing them to repel each other.
Since this prevents these charged particles from colliding to form larger masses,
called flocs, they do not settle. To assist in the removal of colloidal particles from
suspension, chemical coagulation and flocculation are required. These processes,
usually done in sequence, are a combination of physical and chemical procedures.
Chemicals are mixed with wastewater to promote the aggregation of the
suspended solids into particles large enough to settle or be removed.

Coagulation is the destabilization of colloids by neutralizing the forces that keep


them apart. Cationic coagulants provide positive electric charges to reduce the
negative charge (zeta potential) of the colloids. As a result, the particles collide to
form larger particles (flocs). Rapid mixing is required to disperse the coagulant
throughout the liquid. Care must be taken not to overdose the coagulants as this
can cause a complete charge reversal and restabilize the colloid complex.

Flocculation, is the action of polymers to


form bridges between the flocs. and bind
the particles into large agglomerates or
clumps. Bridging occurs when segments
of the polymer chain adsorb on different
particles and help particles aggregate. An
anionic flocculant will react against a
positively charged suspension, adsorbing
on the particles and causing
destabilization either by bridging or
charge neutralization. In this process it is
essential that the flocculating agent be
added by slow and gentle mixing to allow
for contact between the small flocs and to
agglomerate them into larger particles. The newly formed agglomerated particles
are quite fragile and can be broken apart by shear forces during mixing. Care
must also be taken to not overdose the polymer as doing so will cause
settling/clarification problems. Anionic polymers themselves are lighter than
water. As a result, increasing the dosage will increase the tendency of the floc to
float and not settle.

Once suspended particles are flocculated into larger particles, they can usually be
removed from the liquid by sedimentation, provided that a sufficient density
difference exists between the suspended matter and the liquid. Such particles can
also be removed or separated by media filtration, straining or floatation. When a
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filtering process is used, the addition of a flocculant may not be required since the
particles formed by the coagulation reaction may be of sufficient size to allow
removal. The flocculation reaction not only increases the size of the floc particles
to settle them faster, but also affects the physical nature of the floc, making these
particles less gelatinous and thereby easier to dewater.

3.8 Important process parameters during flocculation:


1. Correct flocculant dosage (100 to 500ppm) ex. 0.1 – 0.5 Liter/ton
2. Correct bilge water pH level (pH7 – pH10)
3. Sufficient mixing operation (Rapid – Slow agitation)
4. Sufficient heat to facilitate phase separation (50°C ±5°C)
5. Sufficient settling time (60 mins)

3.9 Possible improved pre-treatment method of bilge water to comply with the
regulation
15ppm Oil Content Detector

Polyaluminiumchloride(PAC)

Overboard
Bilge Transfer Pump Treated Tank
O
Feed Pump W
S
AIR SUPPLY
2Bar
Filter
PRE-TREATMENT
IMO A.393(X)
Type Approved
MEPC.60 (33) Return line
Bilge Holding Tank Separated Oil Tank

EMULSIFIED OIL
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Effective separation using flocculation-flotation technique is necessary to overcome


the effects of detergent present in the bilge and allow coalescence to cause droplet
flocculation. With the addition of cationic coagulant polyaluminiumchloride (PAC) in
the bilge water the stabilization layer in the oil in water emulsion is disrupted and
coagulation will occur. This high molecular weight flocculant chemical will
agglomerate the finely divided oil droplets suspended in water. The particles that
bound together will settle or float more rapidly. The coagulant will increase the size
and settling rate of suspended particles. Using induced-air flotation even very small
or light suspended particles that settle slowly can be removed more completely and in
a shorter time.

If necessary perform pH adjustment using Sodium Hydroxide (NaOH) to increase


bilge water pH to its desired pH level (pH 7 – 10).

Typical rule of thumb for chemical dosage using dosing pump (0.05 to 0.1%/Vol):

Flowrate Dosing pump


(m3/hr) setting (ml/min)
1 8.33 - 16.67
2 16.67 - 33.34
3 25.00 - 50.00
4 33.33 - 66.66
5 41.67 – 83.33

3.10 Shipboard Incinerator

How can we burn waste oil


effectively?

What can be burned in the


incinerator?

What happens to ash from the


incinerator?
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Waste oil incineration procedures

1. Heating of waste oil 80-100oC for oil inlet temperature is required for easy
burning of oil. Heating will assist to evaporate water in the mixture. Waste oil
should be agitated before combustion for easy separation of oil and water.
2. No burning of plastics as they produce dangerous fumes.
3. Crockery, glass, metals, packing materials will not burn in incinerator.
4. Collect ashes and land ashore.

Shipboard Incinerator

***
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Section/Title Topic 4: Bilge Water/Oily Facility Familiarization and Operation


Revision No. 03 Effectivity Date 16 July 2007 Page No. 1 of 9

TOPIC 4

Bilge Water/Oily Waste Facility Familiarization
and Operation
Content: Page

Introduction..................................................................................................................01
4.1 Bilge Tank, Pumps and Valve Arrangement ......................................................02
4.2 Oil Water Separator and Oil Content Monitoring Device
System Function..................................................................................................03
4.3 Transfer of Bilge Water from Engine Room Bilge wells
to Oily Bilge Holding Tank ................................................................................06
4.4 Separation of Dirty Oil from Oily Bilge Holding Tank......................................06
4.5 Transfer of Bilge water to Bilge Holding Tank ..................................................06
4.6 Transfer of Dirty Oil to Incinerator Waste Oil Service tank ..............................06
4.7 Drain of Water Content from the Incinerator Waste Oil Service Tank ..............07
4.8 Transfer of Separated Oil to Port Facilities ........................................................07
4.9 Transfer of Bilge Water from the Bilge Holding Tank
to Cascade Tanks ................................................................................................08
4.10 Re-circulation of Bilge Water thru the Activated Carbon Filters
for Decolorization Process..................................................................................08
4.11 Pumping Operation of Bilge Water from Treated Tank
to Oil Water Separator ........................................................................................08
4.12 Pumping Operation of Treated Bilge Water from Oil Water Separator
to Activated Carbon Filters.................................................................................08
4.13 Transfer of Drain Water from F.O. /D.O. / L.O.
Settling / Service / Storage Tanks to Drain Tanks..............................................09
4.14 Transfer of Drain Water to Bilge Holding Tank.................................................09
4.15 Re-zeroing of Oil Content Monitoring Device ...................................................09

APPENDIX: NTC-M Bilge Water System Facility Diagram


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Section/Title Topic 4: Bilge Water/Oily Facility Familiarization and Operation


Revision No. 03 Effectivity Date 16 July 2007 Page No. 2 of 9

TOPIC 4
Bilge Water/Oily Waste Facility Familiarization and
Operation
Introduction

This particular chapter mainly deals with the fundamental highlights of the
familiarization activity of the training institutions facility for Bilge Water/Oily
Waste Operations Management Course. The succeeding items tackle the setup,
arrangement and device specifications of the said training facility for training
purposes.

For specific guidelines as regards to the actual application requirement onboard


ship, this manual approvingly refer the DNV Rules for Classification, Part 4-
Chapter 1, Section 4: Ship Piping System, Item H: Bilge Pumping and Piping.

4.1 Diagram of Bilge Tanks, Pumps and Valve Arrangement

Bilge tanks, pumps and valves are the principal building block of bilge water
and oily waste facility. Arrangements of which are presented in the appendix of
this topic. By and large, these arrangements are depicted in the four main
transfer/process lines, namely:

Diagram No. Transfer/Process Lines


1 Bilge Water Transfer Line
2 Oily-waste Inceneration Process Line
3 Bilge Water Process Line
4 Sludge/Oily Waste Transfer Line
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As a general reference, below is the legend for the interpretation of the various
symbols/figures used in the diagram:

- Pipeline

- Valve

- Pump

4.2 Oil Water Separator and Oil Content Monitoring Device System Function

The Oily Water Separator

The Oily-Water Separator is a single vertical cylindrical vessel utilizing the dual
capabilities of gravity assisted separation and coalescence to separate and
remove insoluble oil, solids and entrained air from water. An oily Content
Detector (OCD) mounted directly to the system is provided to detect the oil
content of the processed water discharge.

The system which can process oily water at its rated capacity is designed for
continuous and intermittent operation without the need for chemical or other
additives. After the system has started it is capable of automatic operation.

The system design incorporates three stages of oil-water in a single vertical


cylindrical pressure/vacuum vessel. The stages of separation include:

1.) separation due to the difference in specific gravity between oil and water
and a reduces flow velocity of the influent;
2.) coalescence of oil as it flows over a separating media matrix of corrugated
parallel plates; and
3.) coalescence of residual oil droplets as fluid flows through a polishing pack
of polypropylene.

This design provides the most efficient and effective means of separating oil
from water, and eliminates the expense associated with the replaceable media
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such as coalescer filter elements. The separating media, parallel plates and
beads, do not require replacement.

Oily Water Separator – HELI-SEP Model 500-OCD (Front View)


(As indicated by the Product Manual)

Component Name
A. Separator Vessel J
B. Pump Suction Drain Plug I
C. Test Plug K
D. Drain / Solid Dump L
H
Valve
E. Vessel Pressure Relief Q
Valve
F. Oily Water Inlet Valve
G. Clean Water Inlet Valve
M
H. Sample Valve
I. Lifting Eyes
J. Oil Sensing Probe N
K. Combination Vacuum / G
Pressure Gauge O
L. Oil Outlet Valve
F
M. Control Box
N. Pump Discharge Pressure P
Relief Valve
O. Pressure Gauge E
P. System Pump
Q. Oil Content Detector, B
D C A
Bilge Alarm OCD CM

Oil Content Detector (OCD)

The OCD has been designed specifically for use in conjunction with 15-PPM
oily-water separator units and has a specification and performance which meets
the requirement of the International Maritime Organization specifications for
Oil Content Detectors contained in Resolution MEPC 60 (33).
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The OCD is a very robust instrument ideally suited to the aggressive


environments for marine engine rooms. The measuring cell is a sealed unit set
to the right hand side of the enclosure. The inlet pipe is situated on the bottom
of the cell and the outlet pipe is situated on the top right hand of the cell. A
desiccator to eliminate moisture around the outside glass tube and a throttle to
regulate and maintain pressure is also fitted to the cell.

The main electronics are all contained within the enclosure on two printed
circuit boards additionally a small PBC containing transmitters and sensors is
contained within the measuring cell.

The front of the monitor is fitted with a membrane user interface containing
three push buttons and window for the LED displays.

The Oil Content Detector (Overall View)


(As indicated by the Product Manual)

Component Name
1. PPM Display
2. Seconds LED
3. PPM LED
4. Alarm 1 Indication LED
5. Alarm 2 Indication LED
6. Alarm 1 Adjust LED
7. Alarm 2 Adjust LED
8. Set/Zero Key
9. Up Key
10. Down Key
11. Membrane Overlay
12. Sample Inlet Fitting
13. Cell Assembly
14. Desiccator
15. Sample Outlet Fitting
16. Sample Flow Throttle
17. Cell Cap
18. Display PCB
19. Main PCB
20. Clear Safety Cover
21. Cell leaning Bottle
Brush
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4.3 Transfer of Bilge Water from Engine Room Bilge wells to Oily Bilge
Holding Tank

The mechanism involved in transferring the bilge water collected in the


machinery spaces bilge wells is through the function of the Bilge Transfer Pump
(Pump No. 1). Switch ON this pump and it automatically enables the transfer of
bilge water from an open valve bilge well to the Oily Bilge Holding Tank.

4.4 Separation of Dirty Oil from Oily Bilge Holding Tank

Separation of dirty oil from the Oily Bilge Holding Tank is made possible
through the provision of suction pump located in the high level portion of the
tank. This suction pump is known as the High Suction Pump.

Since oil substance is lighter than most of the liquids normally collected in the
bilge well, its placement in the liquid deposit is naturally on the top layer of the
deposit. Thus, through the function of Bilge/Sludge Transfer Pump (Pump No.
2), it triggers the High Suction Pump to drain off/spill out most of this top layer
bilge deposit (which is dirty oil) in the Oily Bilge Holding Tank and pour them
to the Separated Oil Tank.

4.5 Transfer of Bilge water to Bilge Water Holding Tank

Transfers of bilge water from Oily Bilge Holding Tank to Bilge Water Holding
Tank take the similar process as of the item 4.4. However, in this process, to
enable such transfer of bilge water (since the placement of water by natural law
is at the bottom of the bilge deposit) a suction pump placed at the lower level of
the Oily Bilge Holding Tank, known as the Low Suction Pump, allows such
transfer to take place.

4.6 Transfer of Dirty Oil to Incinerator Waste Oil Service tank

There is a setup of pipe line that interconnects the Separated Oil Tank and the
Incenerator Waste Oil Service Tank. Accordingly, provided that Pump No. 2 is
running, open the valve in the Separated Oil Tank that facilitates the flow of its
dirty oil deposits directly to the Incenerator Waste Oil Service Tank.

As a safety mechanism, since an overflow in the waste oil service tank might
occur due to continuous flow of oil from Separated Oil Tank, a float apparatus
is devised to sense if the service tank is already full. Such apparatus is
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electromechanically linked to the Acoustic and Visual Alarm system. The siren
of the alarm system sounds once the service tank is about to be filled. When it
occurs, open the valve that leads to the Thermal Process Unit to pump out some
deposits in the service tank. This draining process causes the alarm bell to stop.

4.7 Drain of Water Content from the Incinerator Waste Oil Service Tank

As explained in the last sentence of item 4.6, it is construed that there is a


pipeline connection from the bottom of the Incenerator Waste Oil Service Tank
way down to the opening of the Thermal Process Unit. Opening of the valve in
this pipeline causes the bilge deposit at bottom layer of the service tank to pump
out way in to the Thermal Process Unit, thus, draining occur.

Liquid (which is more of water substance) collected in the Thermal Process


Unit as a result of the above draining process is directed to the Bilge Holding
tank.

4.8 Transfer of Separated Oil to Port Facilities

Collected waste oil as result of the process described in item 4.6 shall be
transferred to a separate holding tank intended to facilitate transfer of separated
oil to port facilities.

4.9 Transfer of Bilge Water from the Bilge Holding Tank to Cascade Tanks

Collected bilge water in the Bilge water Holding Tank as result of the process in
item 4.5 is transferred to Cascade Tanks through the service of the Cascading
Pump (Pump No. 3). Running of this pump causes the movement of water
deposit in the holding tank way up to Cascade Tank No. 1, then to Cascade
Tank No. 2 and subsequently to the Flocculating Process Tank.

The drive of the cascade mechanism in this process intends to gradually lessen/
remove the oil substance in the water as it flows in the cascade tanks. Through
this mechanism, water collected in the Flocculating Process Tank is assumed to
be of almost-free from oil substances as is suitable for water treatment. In such
treatment, an agent is used such as chemical flocculant and a mechanism is
activated to enable the flocculating process. Treated water as result of this
process is then transferred to Treated Tank.
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4.10 Re-circulation of Bilge Water thru the Activated Carbon Filters for
Decolorization Process

Collected treated water in the Treated Water Tank is further subjected to


purification by means of filtration, etc. Another pump called Re-circulating
Pump facilitates the transfer of water from the Treated Tank to the carbon filter
membranes for decoloration process, then, back to the Treated Tank.

4.11 Pumping Operation of Bilge Water from Treated Tank to Oil Water
Separator

The Oil Water Separator has a built-in and integrated pumping system. Upon
running of which, it automatically facilitates the pumping out of water from the
Treated Tank way in to the separator device.

The Oil Water Separator is a simple and yet sophisticated device to effectively
and efficiently remove and separate oil substances in water. In point of fact,
water deposits in the Bilge Water Holding Tank could go directly to
Flocculating process then to the Oil Water Separator. However, the cascading
components explained in item 4.9 highly reduce the amount of oil in the water.
Thus, when the water is subjected for Oil/Water Separation, the said device
shall operate on a minimal processing, which would consequently result into its
low maintenance outlay.

4.12 Pumping Operation of Treated Bilge Water from Oil Water Separator to
Activated Carbon Filters

Collected treated water in the Treated Water Tank is further subjected to


purification by means of filtration. Another pump called Re-circulating Pump
facilitates the transfer of water from the Treated Tank to the carbon filter
membranes for decoloration process, then, back to the Treated Tank.

4.13 Transfer of Drain Water from F.O. /D.O. / L.O. Settling / Service / Storage
Tanks to Drain Tanks

Oil deposits of respective tanks for fuel oil (FO), diesel oil (DO) and lube oil
(LO) has a pipeline and valves setup intended for draining process due to the
suspected water content of the oil deposits. Below these tanks is another set of
tanks, accordingly labeled as L.O. Drain Tank and F.O. Drain Tank, designed to
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Revision No. 03 Effectivity Date 16 July 2007 Page No. 9 of 9

correspondingly hold the flow/drain of liquid from the storage/settling/service


tanks of the three forms of oil mentioned above.

Draining method simply requires opening of the oil deposit tanks drain valves.
This causes the liquid on the bottom layer of the oil tanks to flow downwards to
the drain tanks, thus, draining takes place.

4.14 Transfer of Drain Water to Bilge Holding Tank

As result of the draining process describe in item 4.13, opening of respective


valves of drain water tanks routes the liquid deposits from these tanks way in to
the Bilge Holding Tank.

4.15 Re-zeroing of Oil Content Monitoring (OCD) Device

The OCD device integrated in the Oil Water Separator, upon processing,
indicates the oil contents of the processed bilge water in terms of PPM. Before a
new process is to be undertaken, the PPM reading of the device should be reset
to zero (0).

This process, known as re-zeroing of the OCD, requires the occurrence of fresh
water. A separate line and valve mounted in the device facilitates the flow of
water from the Fresh Water Container to the OCD Water Line. The device shall
then measure the oil content for the water. Since the liquid is fresh water, it is
guaranteed that the liquid is free from any other liquid substances particularly
oil. Thus, the device shall not indicate any measure of PPM (or only within 2
PPM as per factory set value). In this regard, the OCD is safe and ready to
RESET to zero by simply pressing the Zeroing button.

For the specific procedures and guideline, refer to the OCD Operating Manual
about “Calibrating for Clean Water.”
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BILGE WATER TRANSFER LINE


Diagram 1
PUMP NO. 1
BILGE
TRANSFER
PUMP

LSH

FROM FRESH WATER


HYDROPOR TANK

SEPARATED OILY BILGE BILGE WATER


OIL TANK HOLDING TANK HOLDING TANK
(11 m3) (14 m3) (19 m3)

ENGINE CARGO BOILER


BILGE HOLD BILGES
WATER BILGE MICS.
SPACE TUNNEL SPACE

Legend:
- Pipeline
- Valve

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OILY-WASTE INCENERATION PROCESS LINE


Diagram 2
LSH

INCENERATOR
WASTE OIL HOLDING TANK
TANK TO PORT
FACILITIES

INCENERATOR UNIT

LSH

SEPARATED OILY BILGE BILGE WATER PUMP NO. 2


OIL TANK HOLDING TANK HOLDING TANK SLUDGE/BILGE
(11 m3) (14 m3) (19 m3) TRANSFER
PUMP

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BILGE WATER PROCESS LINE


Diagram 3

OCD

OILY WATER
SEPARATOR

OWS PUMP

CASCADING TANK 1
(SEPARATED TANK 1)
TREATED TANK
CASCADING TANK 2
PUMP NO. 3 (SEPARATED TANK 2)
Flocculating Process Tank
(SEPARATED TANK 3)

LSH

PUMP NO. 4

SEPARATED OILY BILGE BILGE WATER


OIL TANK HOLDING TANK HOLDING TANK
(11 m3) (14 m3) (19 m3)

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SLUDGE/OILY-WASTE TRANSFER LINE


Diagram 4

L.O. L.O. D.O. D.O. F.O. F.O.


Storage Storage Settling Service Settling Service
Tank 1 Tank 2 Tank Tank Tank Tank

L.O. F.O.
PURIFIER PURIFIER
L.O. L.O.
Drain Drain
Tank Tank

LSH LSH LSH

L.O. F.O.
SEPARATED OILY BILGE BILGE WATER PURIFIER PURIFIER
OIL TANK HOLDING TANK HOLDING TANK SLUDGE SLUDGE
(11 m3) (14 m3) (19 m3) TANK TANK

PUMP No. 2

TOPIC 4 APPENDIX Facility Diagram: Bilge Water & Waste Oil Operational Management Course
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Section/Title Topic 5: Correct Entries in the Oil Record Book – Part 1


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TOPIC 5

Correct Entries in the Oil Record Book – Part I
Content: Page

5.1 Introduction...........................................................................................................2
5.2 Who is directly in charge of the Oil Record Book – Part I? .................................5
5.3 Two approaches in controlling pollution ..............................................................5
5.4 Concentrated Inspection Campaigns.....................................................................5
5.5 Example of CIC check list ....................................................................................6
5.6 Guide for correct entries in the Oil Record Book – Part I ....................................8
5.7 Description and record keeping ............................................................................8
5.8 Inspection of Oil Record Books............................................................................9
5.9 Frequently reviewed by PSCO............................................................................10
5.10 MARPOL Annex I, Appendix III .......................................................................11
5.11 List of items to be recorded ................................................................................12
5.12 Frequently found failures....................................................................................20
5.13 Example ORB entries .........................................................................................22
5.14 Sampling in the machinery spaces .....................................................................28
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TOPIC 5

Correct Entries in the Oil Record Book – Part I


5.1 Introduction

Annex I of the MARPOL Convention grew out of


a long history of efforts to reduce oil pollution at
sea. These efforts included the OILPOL
Convention of 1954 and its amendments of 1962,
1969 and 1971. In this Convention, ships were
prohibited from discharging significant quantities
of oil (over 100 parts per million - ppm) within 50
miles of land. Furthermore, signatories were
required to promote the development of port
reception facilities for oily wastes. These two
elements of oil pollution prevention – the reduction
of oily effluent discharge at sea and the
development of port reception facilities, still serve to frame the IMO's efforts to
prevent operational oil pollution. The 1954 convention also underscored the fact
that, despite catastrophic oil spills resulting from tanker groundings and/or losses
at sea, the principal source of ship-source oil pollution was, and remains, routine
operational discharges. Many of the OILPOL clauses were incorporated into the
first annex of the 1973 International Convention for the Prevention of Pollution
from Ships (MARPOL). Annex I of this Convention, as amended in subsequent
years, sets out rules for ship construction and operation in order to reduce the risk
of oil pollution.
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Source: IMO, 1989, US NRC, 2002

The Paris MOU's data for 2000 provides more detailed insight into the exact nature of
MARPOL violations. The table reveals that the overwhelming majority of MARPOL
violations discovered during port State inspections concern principally Annex I (Oil)
and most deficiencies pertains to the oil record book entries
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5.2 Who is directly in charge of the Oil Record Book – Part 1?

• First, Masters are responsible for the maintenance of this logbook, not the
Chief Engineer, not the Chief Mate, nor the Cargo Officer.
• They may designate others to perform specific duties regarding the logbook.
And that designated person(s) could also be punished in case of an offense.
Ultimately though, they are accountable for its maintenance and accuracy.
• Second, in the event of an oil spill in your vessel's vicinity, regardless of the
guilty party or vessel, an accurate ORB is your first and best line of defense
during an investigation.

"An improperly kept ORB may be used as evidence against a ship suspected of an
illegal oil discharge, while a correctly maintained record could establish a
successful defense to an alleged violation."

5.3 Two Approaches in Controlling Pollution


1. Procedures and processes that must be adhered to in order to ensure the
minimum released of oil into the sea.
a. Certification
b. Record keeping
c. Discharge procedure
d. Other criteria regulating shipboard operation
These involved the responsibility of the crew and flag / port state in
insuring compliance

2. Technical design specification that must be adhered to in order to minimize


accidental or operational discharge of oil.
This involved the structural make-up of the ship- design and
equipment

5.4 Concentrated Inspection Campaigns

The purpose of the inspection campaign is to investigate the operability of the Oil
Filtering Equipment (OFE) systems installed on board ships, and to find out
whether sludge has been discharged into port reception facilities, burnt in an
incinerator or in an auxiliary boiler suitable for burning oil residuals.
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The following documents are needed to perform the inspection:


- The IOPP certificate of the vessel
- Certificate for the separating/filtering equipment
- Certificate for the oil content meter
- The Oil Record Book, Part I - Machinery Space Operations

Concentrated inspection campaigns have been a particular feature of the Paris


MOU in recent years, and are also now starting to be conducted by the Tokyo
MOU. They focus on specific areas where high levels of deficiencies have been
encountered by PSCOs, or where new convention requirements have recently
entered into force. The Paris MOU has so far always announced its campaigns
well in advance, both in the press and on its web site. The campaigns have
typically been concentrated over periods of about 3 months and recent campaigns
have centered on the ‘oil record book’, ‘living and working conditions on ships’,
the ‘implementation of the ISM code for phase-one ships’, ‘bulk carrier safety’
and ‘oil tankers older than 15 years’. Campaigns regarding ‘cargo securing
manuals’ and the ‘implementation of the ISM code for phase-two ships’ are
expected to follow.

5.5 Example of CIC Check List (February 2006 to April 2006)

Concentrated Inspection Campaign (CIC) on MARPOL Annex I Requirements


Check List
1. Is the oil filtering equipment (OFE) onboard type-approved according to the
IOPP certificate?
2. Is the OFE system effectively inspected, tested and maintained in accordance
with the planned maintenance system (PMS) on board?
3. Is the 15 ppm oil content alarm correctly adjusted and operating properly?
4. Is the automatic 3-way valve or stopping device at the outlet of the OFE
functioning?
5. Is the OFE system free of illegal bypasses or unauthorized modifications?
6. If the incinerator is designed for burning oil residues, has it been marked in
the IOPP certificate?
7. If the auxiliary boiler is designed for burning oil residues, has it been marked
in the IOPP certificate?
8. Are the sludge tanks free of illegal direct connections overboard?
9. Is there a standard discharge connection to enable sludge to be discharged to
shore reception facilities?
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10. Is there evidence that sludge and/or bilge water has been discharged to port
reception facilities?
11. If sludge has not been discharged into port reception facilities, has the
incinerator or the auxiliary boiler been used for burning sludge on board?
12. Is there sufficient capacity remaining in the sludge and/or bilge water tanks
for the intended voyage?

It can be seen on this check list that most of the items need the Oil Record
Book (ORB) to serve as evidence to prove that a ship has complied with
pollution prevention regulations.

In accordance with the International Convention for the Prevention of Pollution


from Ships, as modified by the Protocol of 1978 relating thereto (MARPOL
73/78), Oil Record Books shall be kept on every ship of 400 gross tonnage and
above, and on every oil tanker of 150 gross tonnage and above, as required by
Regulation 20 of Annex I. Such records are necessary for the enforcement of
pollution regulations and fulfill the same role as entries in the deck and engine
room logs in case a ship is suspected of violation. It is therefore very important
that all entries are made carefully and precisely.

An improperly kept Oil Record Book could be used as evidence against a


suspected ship. On the other hand a correctly maintained record could acquit a
suspected ship. Even though the Master is entrusted with the overall responsibility
of his ship, officers designated by him to perform specific duties also become
punishable in case of an offense under the laws. It is therefore very important that
the Oil Record Book is completed carefully and precisely. The responsibility of
the Master or the designated person for making entries in the Oil Record Book is
no less than that for the ship's official log books.

Oil Record Book has been modified so as to accord with the new requirements
regarding equipment and thus with new procedures on board ships. The entries
are now required to be made in chronological order as in ship's log books.

All officers concerned with operations to minimize pollution should familiarize


themselves with the basic concept of these operational procedures and the
equipment provided on board to facilitate and improve such operations. Various
manuals found on board should be carefully studied to provide a better
understanding of the list of operations provided at the beginning of each part of
the Oil Record Book.
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5.6 GUIDE FOR CORRECT ENTRIES IN THE OIL RECORD BOOK (ORB) -
PART I

MARPOL 73/78

This book gives advice for the entries in the OIL RECORD BOOK – Part I, in
accordance with the MARPOL 73/78 (as amended), Annex I Chapter I Reg. 4,
Chapter 3 Reg. 15 & 17, and Chapter 6 Reg. 38 as well as the relevant Flag
Administration requirements and is structured in a way to match with/refers to the
individual documented management system of the ship management company.

Annex I Chapter 1, Regulation 04 : EXCEPTIONS


Annex I Chapter 3, Regulation 15 : CONTROL OF DISCHARGE OF OIL FOR
MACHINERY SPACES
Annex I Chapter 3, Regulation 17 : OIL RECORD BOOK Part I
Annex I Chapter 6, Regulation 38 : RECEPTION FACILITIES

5.7 Description and Record Keeping

The Oil Record Book contains both Part I for machinery space operations and
Part II for cargo/ballast operation in a single bound book. Consequently, on
tankers, two Oil Record Books shall be provided. One Oil Record Book shall be
dedicated to recording only Part I activities and will normally be kept in the
engine room, while the other Oil Record Book shall be dedicated to recording
only Part II activities and will normally be kept in the cargo control room. On
ships other than oil tankers only Part I of the Oil Record Book (machinery space
operations) need be kept, unless the ship is fitted with cargo spaces constructed
and utilized for the carriage of oil in bulk of an aggregate capacity of 200 cubic
meters or more, then it must also maintain Part II of the Oil Record Book which
covers cargo/ballast operations.

The first pages in each Oil Record Book show a comprehensive list of items of
operations. The items are grouped into operational sections, each of which is
denoted by a letter code. When making entries in the Oil Record Book, the date,
operational letter code and item number shall be inserted in the appropriate
columns and the required particulars shall be recorded chronologically in the
blank space. The entries in the Oil Record Book for ships holding an IOPP
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Certificate shall be in English or French. Other ships shall make entries in the
official language of the State whose flag the ship is entitled to fly.

Each completed operation shall be signed and dated by the officers(s) in charge,
and each completed page shall be signed by the Master of the ship.

The following should be observed when making entries in the Oil Record Book:

a. If a wrong entry is made it should be struck by a single line still making the
wrong entry legible. The wrong entry is signed and the correct entry follows.

b. The entries must be made in indelible ink and the Oil Record Book must be
preserved for a period of three years after the date of last entry.

c. As soon as the operation is completed the officer or the officers in charge of


the operation(s) shall make entries in the Oil Record Book. In the case of an
unavoidable delay, the Oil Record Book, the entries shall be made at the
earliest opportunity.

d. As soon as each page is completed the Oil Record Book shall be presented to
the Master for his signature at the bottom of the page.

e. If in the opinion of an officer (of the ship) it is considered that certain events
must be noted down in the Oil Record Book even though such an entry is not
listed, a list of items under column “I” should be developed to enter such
operations or events.

The items to be recorded in the Oil Record Book must be kept to the absolute
minimum required to reconstruct a situation or sequence of events.

5.8 Inspection of Oil Record Books

Under MARPOL 73/78, the Oil Record Books may be inspected at a port, and
may be made available in any judicial proceedings as evidence of facts stated in
the entries MARPOL 73/78 further provides for a system whereby port authorities
may, if the inspection of the Oil Record Book indicated that an unauthorized
discharge might have occurred, detain and inspect the ship to find more evidence
of the suspected contravention.
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5.9 Frequently Reviewed by PSCO

1. Operations stipulated in MARPOL 73/78 as amended, Annex 1, Chapter II,


Reg. 20 are properly recorded in the ORB.

2. Entry is correct, as per format stipulated in MARPOL 73/78 as amended,


Annex I, Chapter IV, Appendix III, operations are properly recorded and in
line with the other logs on board and properly signed.

3. Documents readily available:


a. ORB with records up to the last day, and filed for 3 years.
b. IOPP certificate.
c. Bilge water separator/incinerator certificates and manual.
d. Bilge water 15 ppm automatic stopping device certificate and manual.
e. Bilge piping diagram. Any modification should be approved by the class

4. Oil filtering equipment and incineration system operational condition.


5. Records of maintenance.
6. Standard spare parts for oil filtering / waste disposal equipment.
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5.10 MARPOL Annex I, Appendix III

Forms of Oil Record Book (with examples and explanation)

OIL RECORD BOOK


PART I- Machinery Space Operation
(All Ships)
Name of Ship: ________________________________________________

Distinctive number or letters: ____________________________________

Gross tonnage: _______________________________________________

Period from: ______________ to: ____________

Introduction
(First 4 paragraphs)

The following pages of this section show a comprehensive list of items of


machinery space operation which are, when appropriate, to be recorded, in
accordance with the regulation 17 of Annex I of the International Convention for
the Prevention of Pollution from Ships, 1973, as modified by the Protocol of 1978
relating thereto (MARPOL 73/78). The items have been grouped into operational
sections, each of which is denoted by a letter code.

When making entries in the Oil Record Book Part I, the date, operational letter
code and item number shall be inserted in the appropriate columns and the
required particulars shall be recorded chronologically in the blank spaces.

Each completed operation shall be signed for and dated by the officer(s) in
charge. The master of the ship shall sign each completed page.

The ORB Part I contains many references to oil quantity. The limited accuracy of
tank measurement devices, temperature variations and tank clingage will affect
the accuracy of these readings. The entries in the ORB Part 1 should be
considered accordingly.
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Example of Detailed Entry Format

• Sludge Transfer From LO Purifier Sludge Tank to Separated Oil Tank


**When making entries in the ORB, the date, the operational letter code and item number shall
be inserted in the appropriate columns and the required particulars shall be recorded
chronologically in the blank spaces (record of operations).

C. COLLECTION AND DISPOSAL OF OIL RESIDUE (SLUDGE)


12. Methods of disposal of residue.
State quantity of oil residue dispose of, the tank(s) empties and the quantity of
content retained, in M3:
.1 to reception facilities (identify port);
.2 transferred to another (other) tank(s) (indicate tank(s) and the total contents
of tank(s);
.3 incinerated (indicate total time of operation);
.4 other method (state which)

DATE CODE ITEM RECORDS OF OPERATIONS / SIGNATURE


LETTER NUMBER OF THE OFFICER IN CHARGE
20/06/2004 C 12.2 0.60M3 FROM LO PURIFIER SLUDGE TANK
CAP. 4.00M3/ RETAINED 0.50M3
TRANSFERRED TO SEPARATED OIL TANK
CAP 11.00M3 / TOTAL CONTENT 9.00M3
(RANK & SIGN. OF RESPONSIBLE OFFICER)

5.11 LIST OF ITEMS TO BE RECORDED

A. BALLASTING AND/OR CLEANING OF FUEL OIL TANKS

In the past, different ship designed to store ballast water directly in cargo/
bunker tanks. Following MARPOL 73/78, tankers were required to designate
“Clean” cargo tanks (CBT) to serve as ballast tanks.

1. Identity of tank(s) ballasted.


2. Whether cleaned since it last contained oil and, if not, type of oil
previously carried.
3. Cleaning process:
.1 position of ship and time at the start and completion of cleaning;
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.2 identify tank(s) in which one or another method has been employed


(rinsing through, steaming, cleaning with chemicals, type and quantity
of chemicals used, in cubic metres);
.3 identity of tank(s) into which cleaning water was transferred.

4. Ballasting:
.1 position of ship and time at the start and completion of ballasting;
.2 quantity of ballast if tanks are not cleaned, in cubic metres.

B. DISCHARGE OF DIRTY BALLAST OR CLEANING WATER FROM


FUEL OIL TANKS REFERRED UNDER SECTION (A).

5. Identity of tanks(s).
6. Position of ship at start of discharge.
7. Position of ship at completion of discharge.
8. Ship’s speed(s) during discharge.
9. Method of discharge:
.1 through 15 ppm equipment;
.2 to reception facilities.
10. Quantity discharged, in cubic metres

C. COLLECTION AND DISPOSAL OF OIL RESIDUES (SLUDGE)

11. Collection of oil residues.


Quantities of oil residues (sludge and or other residues) retained on
board. The quantity should be recorded weekly*. (This means that the
quantity must be recorded once a week even if the voyage lasts more than
one week)
.1 identity of tank(s)
.2 capacity of tank(s) in cubic metres
.3 total quantity of retention in cubic metres.

*Tank listed in item 3.1 of forms A and B of the Supplement in the IOPP Certificate used
for sludge.
Anticipated daily quantity of sludge produced will be 1% of HFO daily consumption plus
0.5% of DO daily consumption.
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CAPACITY OF SLUDGE TANK


To assist the Administrations in determining the adequate capacity of sludge tanks,
the following criteria may be used as guidance. These criteria should not be construed
as determining the amount of oil residues which will be produced by the machinery
installation in a given period of time

V1=K1 x C1 x D(M3)

Where:

V1 - Minimum capacity of sludge tank

K1 - 0.01* for ships where HFO is purified for main engine use,
or 0.005** for ships using DO or HFO which does not require
purification before use.

C1 - Daily HFO consumption (metric tons).

D - Maximum period of voyage between ports where sludge can be


discharged ashore (days). In the absence of precise data a figure of 30
days should be used.

* 1% OF HFO CONS.
** 0.5% OF DO CONS.

SLUDGE CALCULATED (C11.1)


1 The inspecting authorities simply wish to be able to see clearly that the total
oil shipped plus the oil already on board, less the main engine consumption
for that voyage equals the total oil remaining on board (ROB) plus the sludge
ROB.
( ROB + bunkered fuel ) – ME cons. = ROB + sludge
A B
It is a simple arithmetic to add up the amount that should be on board
compared with the amount “said to be” disposed.
A => B ---------- no question
A < B ---------- where is the oil? (In this case you’re guilty unless
you prove you’re innocence)

Source: UK P&I CLUB “ Oil Record Book Checking (Fines)- Worldwide


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ENTRIES UNDER C11

Sludge retention and the entries required at the end of a voyage (or weekly if the
vessel is on short sea trade)

This is for two reasons:


1. It is required by MARPOL and Oil Record Book- Section C11
2. If any pollution was to occur during the vessel stay in that particular port you have written proof of
what the ship had onboard in terms of sludge- tank by tank. A quick sounding of these tanks by the
Authorities will prove that you are not the culprit. If the entries are not made then again you are
guilty until you can prove your innocence. This will mean getting the local Club correspondent
involve, Surveyors to attend, Club involvement and of course in the end totally unnecessary cost
incurred by the Shipowner.

Source: UK P&I CLUB “Oil Record Book Checking (Fines)-Worldwide

Revised Entry as per MSA no. 38-05

C. Collection and disposal of oil residues (sludge and other oil residues)
11. Collection of oil residues.
Quantities of oil residues (sludge and other oil residues) retained on
board. The quantity should be recorded weekly: (This means that the
quantity must be recorded once a week even if the voyage lasts more
than one week.)
.1 - identity of tank(s) ...................…..
.2 - capacity of tank(s) .................…..m3
.3 - total quantity of retention .............m3

12. Method of disposal of residue.

State quantity of oil residues disposed of, the tank(s) emptied and the
quantity of contents retained:
.1 To reception facilities (identify port);

Ship’s master should obtain from the operator of the reception facilities, which
includes barges and tank trucks, a receipt or certificate detailing the quantity of tank
washings, dirty ballast, residues or oily mixtures transferred, together with the time
and date of the transfer. This receipt or certificate, if attached to the Oil Record
Book Part I, may aid the master of the ship in proving that his ship was not
involved in an alleged pollution incident. The receipt or certificate should be kept
together with the Oil Record Book Part I.
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.2 transferred to another (other) tank(s) (indicated tank(s)) and the


total content in the tank(s);
.3 incinerated (indicate total time of operation);
.4 other method (state which).

D. NON-AUTOMATIC DISCHARGE OVERBOARD OR DISPOSAL


OTHERWISE OF BILGE WATER WHICH HAS ACCUMULATED IN
MACHINERY SPACES

Bilge water is any liquid accumulated from the engine room bilge transferred
to the holding tank and or from the holding tank processed thru the 15ppm oil
filtering equipments.

13. Quantity discharged or disposed of, in cubic metres.


In case of discharge of disposal of bilge water from holding tanks(s), state identity and
capacity of holding tank(s) and quantity retained in holding tank.
14. Time of discharge or disposal (start and stop):
15. Method of discharge or disposal:
.1 through 15 ppm equipment (state position at start and end);
.2 to reception facilities (identify port).
Ship’s master should obtain from the operator of the reception facilities, which
includes barges and tank trucks, a receipt or certificate detailing the quantity of tank
washings, dirty ballast, residues or oily mixtures transferred, together with the time
and date of the transfer. This receipt or certificate, if attached to the Oil Record
Book Part I, may aid the master of the ship in proving that his ship was not involved
in an alleged pollution incident. The receipt or certificate should be kept together
with the Oil Record Book Part I.
.3 transfer to slop tank or holding tank (indicate tank(s); state the quantity
retained in tank(s), in cubic metres).
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ENTRIES UNDER CODE D


Disposal overboard of bilge water frequently do not contain the time of
stopping and the two geographical position required or an inaccurate estimate
of the amount disposed overboard
Ref: UK P&I CLUB “ Oil Record Book Checking (Fines)- Worldwide

For an accurate measurement of overboard disposal, always process bilge


water thru Oil Filtering Equipment from the Holding Tanks and not directly
coming from the ER bilge well.

E. AUTOMATIC DISCHARGE OVERBOARD OR DISPOSAL


OTHERWISE OF BILGE WATER WHICH HAS ACCUMULATED IN
MACHINERY SPACES

This section will be used if the bilge pump is started automatically by a


float switch activating bilge water transfer from the engine room bilge
well to bilge water holding tank or float switch fitted to the bilge water
holding tank starting the 15ppm oil filtering equipment processing water
overboard.

16. Time and position of the ship when put into automatic mode of operation
for discharge overboard, through 15ppm equipment.
17. Time when the system was put into automatic mode of operation for
transfer of bilge water to holding tank (identify tank).
18. Time when the system has been put into manual operation.

F. CONDITION OF THE OIL FILTERING EQUIPMENT

This section is used to record the maintenance carried-out on the 15ppm oil
filtering equipment. “unplanned (break-down) or planned”,

19. Time of system failure.


The condition of the oil filtering equipment covers also the alarm and automatic stopping
devices, if applicable.
20. Time when the system has been made operational.
21. Reason for failure.
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G. ACCIDENTAL OR OTHER EXCEPTIONAL DISCHARGE OF OIL

22. Time of occurrence.


24. Place or position of the ship at the time of occurrence.
25. Approximate quantity and type of oil.
26. Circumstances of discharge or escape, the reason therefore and general
remarks.

Accident or Incident report pertaining to the discharge of any oily mixture on


deck or engine machinery space should also be stated in this section. E.g.
burst deck crane hose, overflow of purifier sludge tank.

H. BUNKERING OF FUEL OR BULK LUBRICATING OIL

26. Bunkering:

.1 Place of bunkering.
.2 Time of bunkering.
.3 Type and quantity of oil and identity of tank(s) (state total quantity
added, in tones, and total content of tank(s)).
.4 Type and quantity of lubricating oil and identity of tank(s) (state
quantity added, in tones, and total content of tank(s)).

ENTRIES UNDER H
1 Required information requested by the Oil Record Book was not frequently
given. I.e. total shipped, total shipped into each tank and the total ROB after
completion. Read the instruction…

Ref: UK P&I CLUB “ Oil Record Book Checking (Fines)- Worldwide


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Revision No. 03 Effectivity Date 16 July 2007 Page No. 19 of 30

I. ADDITIONAL OPERATIONAL PROCEDURES AND GENERAL


REMARKS.

Maintenance (planned or unplanned) of any oily waste disposal equipment


other than Oil Filtering Equipment, e.g. Incinerator

If in the opinion of an officer in-charge, it is considered that certain events


must be noted down in the Oil Record Book even though such an entry is not
listed, a list of items should be made in this section to enter such operations or
events.

Name of ship …………………………………………………………………..


Distinctive number of letter ………………………………………………….

MACHINERY SPACE OPERATIONS

Code Item Record of operational / signatures of officer in


Date
(letter) (number) charge
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5.12 FREQUENTLY FOUND FAILURES

A. IOPP Certificate
1. Supplement to IOPP Certificate:
Form A for ships other than oil tanker or Form B for oil tankers.
- Bilge separators throughput is stated in paragraph 2.5 and should be
verified with the manufacturer’s manual and certificate.
- Oil residue (sludge) tanks are listed in paragraph 3.1. HFO/DO/LO
separators sludge tanks, stuffing box LO drain tank etc. should be
recorded including incinerator sludge tank,
- Bilge water holding tanks are listed in paragraph 3.3 unless a waiver of
Reg. 16 is valid; tanks are listed in paragraph 2.6.2.
- Oil residue (sludge) incinerator capacity is stated in paragraph 3.2.1 and
should be verified with the manufacturer’s manual and certificate.
- For auxiliary boiler to burn Oil residue (sludge) paragraph 3.2.2 should
be marked and this should be verified with burner’s manual and piping
system.

B. SLUDGE Collection- Pumping- Incineration

1. C11.1: Entry of all tank listed in paragraph 3.1 of the supplement of the
IOPP certificate every week, of total retained quantity on board.
Sludge on board = Sludge produced – (sludge incinerated and/or burned in
aux. Boiler)
2. Sludge daily quantity from purifiers will be anticipated.
3. Increased level in FO leak tanks, stuffing box oil drain tank, etc. when the
engine is running will be anticipated.
4. Separated oil from 15 ppm bilge water separator during operation.
5. C12.3: Sludge incinerated: Incinerator capacity as per IOPP Certificate,
Form A or B 3.2.1.
6. C12.4: Sludge burned in aux boiler only when IOPP Certificate, Form A
or B 3.2.3 is ticked.
7. E17, D13: Bilge water separator capacity as per IOPP Certificate Form A
2.5
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C. Bilge Water Discharge Overboard

1. D15.2, E19.1: Bilge water separator capacity as per IOPP Certificate


Supplement Form A or B 2.5.
2. D15.2, E19.1: At any overboard discharge quantity must be less than the
maximum separator throughput.
3. D15.3: There is not any specific requirements on the frequency of this
operation, but is recommended for an entry at least once per week of
transfer and ROB for bilge water.
4. Discharge within special area as defined in MARPOL 73/78 as amended,
Annex I, Chapter 3, Regulation 15, Item B.
5. Section E should be recorded only in case of auto-start of system
activation by floater switches in bilge wells or bilge water holding tank.

D. Discrepancies between Deck Log and ORB

1. All entries properly signed with the time start/end identical between the
two logs
2. Each page of the ORB to be signed by the Master.
3. All entries in the ORB to be done in CAPITAL letters with INDELIBLE
INK. Not pencil.
4. For all entries Category B, D, E following must be entered:
- position and time at start and stop

E. Prior Arrival in Port

1. ORB must be:


- stamped by Flag Administration, as required
- readily available, filed for 3 years
- duly filled in and signed till the date arriving in port
2. Engine bilges/sludge overboard valve sealed/locked
3. Clean filters- check availability of spare filter
4. 15 ppm 3- way valve tested
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5. Incinerator test- familiarization of all engine officers


6. Flange for ashore connection properly maintained
7. Certificate available for incinerator, ODME, bilge water separator, 15 ppm
control equipment.

5.13 Example ORB Entries

A. Bilge water from BWHT Discharge Overboard Through 15 ppm Bilge


Water Separator
CODE ITEM
DATE RECORDS OF OPERATIONS
LETTER NUMBER
20/06/2004 D 13 4M3 FROM BWHT / RETAINED
10.00M3
14 STARTED 0800H / STOPPED 1200H
15.1 15 PPM / START LAT__o__’
LONG__o__’
END LAT__o__’ LONG__o__’
Note: If during the separator operation the sludge collecting valve has been
activated and the collected sludge has been turned into the sludge tank, the
following entry has to be carried out in the ORB.
20/06/2004 C 11.2 0.2M3 FROM 15PPM EQUIPMENT
OPERATION TO SEPARATED OIL
TANK /
CAPACITY 11.M3 / RETENTION
0.8M3
(RANK & SIGN. OF RESPONSIBLE
OFFICER)
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B. Transfer of ER bilge to BWHT


CODE ITEM
DATE RECORDS OF OPERATIONS
LETTER NUMBER
20/06/2004 D 13 2M3 FROM ENGINE ROOM BILGE
14 STARTED 0800H / STOPPED 1200H
15.2 TRANSFERRED TO BWHT / TOTAL
CONT. 9.00M3
(RANK & SIGN. OF RESPONSIBLE
OFFICER)

Note: The name of the tanks should be exactly the same with the tanks listed in
the Supplement of the IOPP certificate.

C. Delivery of Bilge Water from Bilge Water Holding Tank to Shore


Facilities.
CODE ITEM
DATE RECORDS OF OPERATIONS
LETTER NUMBER
20/06/2004 D 13 4M3 FROM BWHT / RETAINED
1.00M3
14 STARTED 0800H / STOPPED 1200H
15.2 GOTHENBURG RECEPTION
FACILITIES
RECEIPT NO. __________
(RANK & SIGN. OF RESPONSIBLE
OFFICER)
Note: Vessel for which the requirement for installation of oil bilge water
separator is waived should have only bilge holding tank and as per note
recorded in IOPP certificate, dispose of oily bilge water to shore facilities
during dedicated days.
The Master should request receipt from shore facilities stating quantity of bilge
water disposed off, date and time.
This should be attached to the ORB
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D. Sludge Transfer From LO Purifier Sludge Tank To Separated Oil Tank


CODE ITEM
DATE RECORDS OF OPERATIONS
LETTER NUMBER
20/06/2004 C 12.2 0.60M3 FROM LO PURIFIER
SLUDGE TANK
CAP. 4.00M3/ RETAINED 0.50M3
TRANSFERRED TO SEPARATED
OIL TANK
CAP 11.00M3 / TOTAL CONTENT
9.00M3
(RANK & SIGN. OF RESPONSIBLE
OFFICER)

E. Sludge Evaporated From the Tank.


CODE ITEM
DATE RECORDS OF OPERATIONS
LETTER NUMBER
20/06/2004 C 12.4 0.20M3 FROM WASTE OIL TANK
CAP. 2.00M3/ RETAINED 0.80M3
EVAPORATED
(RANK & SIGN. OF RESPONSIBLE
OFFICER)
Note: Temperature of the tank should not exceed 95oC or temperature setting
should not be deviated from the standard setting.
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F. Waste oil Incineration


CODE ITEM
DATE RECORDS OF OPERATIONS
LETTER NUMBER
20/06/2004 C 12.3 0.5M3 FROM INCINERATOR WASTE
OIL
TANK CAP. 2.0M3/ RETAINED 0.6M3
INCINERATED, TOTAL TIME 4
HOURS.
(RANK & SIGN. OF RESPONSIBLE
OFFICER)
Note: The quantity recorded as incinerated should be equal to the capacity of
the incinerator multiplied by the operation time.
Sludge incineration is permitted only if para. Of IOPP certificate supplement
Form A or Form B is duly marked.
The sludge tanks recorded here should be exactly the same as the tanks
recorded in the IOPP supplement Form A or Form B.

G. Bilge Separator / Oil Content Meter Failure (Unplanned)


CODE ITEM
DATE RECORDS OF OPERATIONS
LETTER NUMBER
20/06/2004 F 19 1600 HRS.
20 2100 HRS
21 OIL CONTENT METER ALARM FAILED
/ FITTED
NEW SPARE.
(RANK & SIGN. OF RESPONSIBLE
OFFICER)
Note: If the failure is not rectified the same day, code F (condition of discharged
monitoring and control system) is being entered the day of rectification using code
F21 and F22.
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H. Bilge Separator / Coalescer Replacement (Planned)


CODE ITEM
DATE RECORDS OF OPERATIONS
LETTER NUMBER
20/06/2004 F 19 1600 HRS.
20 1700 HRS
21 REPLACED COALESCER FILTER WITH
NEW
SPARE.
(RANK & SIGN. OF RESPONSIBLE
OFFICER)
Note: If the failure is not rectified the same day, code F (condition of discharged
monitoring and control system) is being entered the day of rectification using code
F21 and F22.

I. Bilge Separator / Burned Electric Motor (Unplanned)


CODE ITEM
DATE RECORDS OF OPERATIONS
LETTER NUMBER
20/06/2004 F 20 0900H
21 BURNED BILGE PUMP MOTOR /
ORDERED NEW
MOTOR
(RANK & SIGN. OF RESPONSIBLE
OFFICER)
Note: If the failure is not rectified the same day, Code F being entered the day of
rectification using item 21 and 22.
25/06/2004 F 20 0800H
21 FITTED NEW MOTOR
(RANK & SIGN. OF RESPONSIBLE
OFFICER)
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J. Burst Hydraulic Hose


CODE ITEM
DATE RECORDS OF OPERATIONS
LETTER NUMBER
20/06/2004 G 22 1500 HRS.
23 ALONG SIDE JETTY NO.2 / YUSO,
KOREA
24 APPROXIMATELY 20 LITERS
HYDRAULIC OIL
25 OIL SPILL AT THE STARBOARD MAIN
DECK DUE
TO BURST HYDRAULIC HOSE OF
DECK CRANE,
OIL SPILL CONTAINED WITHIN THE
MAIN DECK.
(RANK & SIGN. OF RESPONSIBLE
OFFICER)
Note: Entry on this code should also be recorded on the incident report, e.g. SAFIR.

K. Oil Residue / Sludge Retained On Board

CODE ITEM
DATE RECORDS OF OPERATIONS
LETTER NUMBER
20/06/2004 C 11.1 SEPARATED OIL TANKS
11.2 11.00 m3
11.3 7.00 m3
C 11.1 OILY BILGE HOLDING TK
11.2 14.00 m3
11.3 8.00 m3
C 11.1 L.O. PURIFIER SLUDGE TK
11.2 4.00 m3
11.3 0.70 m3
C 11.1 F.O. PURIFIER SLUDGE TK
11.2 4.00 m3
11.3 0.70 m3
C 11.1 INCINERATOR WASTE OIL TK
11.2 2.00 m3
11.3 1.50 m3
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CODE ITEM
DATE RECORDS OF OPERATIONS
LETTER NUMBER
C 11.1 BILGE HOLDING TK
11.2 19.00 m3
11.3 10.70 m3
(RANK & SIGN. OF RESPONSIBLE
OFFICER)
Note: The tanks recorded here should be exactly the same as the tanks listed in the
IOPP supplement From A or Form B. This record should be kept once per week.

L. MAINTENANCE OF WASTE OIL INCINERATOR


CODE ITEM
DATE RECORDS OF OPERATIONS
LETTER NUMBER
20/06/2004 I OVERHAULED FUEL AND SLUDGE
BURNERS
AS PER INSTRUCTION MANUAL.
TESTED FOR 15 MINUTES.
(RANK & SIGN. OF RESPONSIBLE
OFFICER)
Note: If in the opinion of an officer (of the ship) it is considered that certain events
must be noted down in the Oil Record Book even though such an entry is not listed,
a list of items should be made in this section to enter such operations or events.
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5.14 Sampling in the Machinery Spaces

1. Check if the ship has an IOPP certificate and


note if the ship is exempted from any
requirements regarding equipment. Make a
copy of the certificate.

2. Study the Oil Record Book for the engine


room and copy the pages that can be of
interest.

3. Check levels and content, and take samples


from the following tanks.
- Bilge sumps
- Bilge water tank
- Separator oil tanks
- Empty bunker tanks used for ballast
water
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4. Also take samples from:


4.1 Fuel day tanks
4.2 Bilge water separator outlet (15 ppm or
100 ppm)
4.3 Sludge pump outlet

5. Examine the bilge water separator. Check


the liquid in the plug cock and require, upon
suspicion, that the filtering unit is opened.

6. Examine the tank top for sludge.


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Section/Title Topic 6: Port State Control Inspection


Revision No. 03 Effectivity Date 16 July 2007 Page No. 1 of 29

TOPIC 6

Port State Control Inspections

Content: Page

6.1 Port State Control...........................................................................................................02


6.2 The role of the flag state.................................................................................................02
6.3 Right of a port state ........................................................................................................02
6.4 Rules that govern port state control activity...................................................................03
6.5 Selection of ship for inspection......................................................................................04
6.6 Targeting inspection.......................................................................................................06
6.7 Owner / Operator ...........................................................................................................06
6.8 Charterer.........................................................................................................................06
6.9 Flag.................................................................................................................................06
6.10 List of targeted flag state................................................................................................07
6.11 Classification society .....................................................................................................07
6.12 PSC history ....................................................................................................................08
6.13 Ship type and age ...........................................................................................................08
6.14 Overriding factor for targeting inspection......................................................................09
A. Ship that have been reported ...................................................................................09
B. Ship reported as having outstanding deficiency ........................................................09
C. Where operational concern to ship exist....................................................................09
6.15 Ship suspended from class .............................................................................................09
6.16 USCG boarding priority matrix .....................................................................................10
6.17 Inspection process ..........................................................................................................11
6.18 Preparing for inspection .................................................................................................11
6.19 The Port State Control Officer .......................................................................................11
6.20 Dealing with the PSCO ..................................................................................................11
6.21 Initial inspection.............................................................................................................12
6.22 Clear Ground..................................................................................................................14
6.23 More detailed inspection ................................................................................................14
6.24 Suspension of an inspection ...........................................................................................15
6.25 Deficiencies....................................................................................................................15
6.26 Corrective action within a specified time period ...........................................................17
6.27 Permit to sail ..................................................................................................................17
6.28 Suspension of ships operation........................................................................................17
6.29 Detention order ..............................................................................................................18
6.30 Banning order.................................................................................................................18
6.31 Sample PSCI Checklist ..................................................................................................19
6.32 Sample Inspection reporting Form.................................................................................29
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TOPIC 6
Port State Control Inspections
6.1 PORT STATE CONTROL
Port States have the right to check that visiting foreign
ships met the required international safety and pollution
prevention standards for many years. Over the last
twenty years or so, rather than approaching the task
individually, port States have developed regional
agreements and now much of the world is covered.

Port State control and the impact it is having on ships, is


growing. Port States in their regional groupings are
becoming more organized and professional in their
approach to ship investigations, and when detentions
occur, ships are ‘named and shamed’ in public. Ships
and shipping companies with a history of detentions will
begin to find it difficult to trade unhindered.

6.2 THE ROLE OF THE FLAG STATE


The United Nations Convention on the Law of the Sea, 1982 (UNCLOS)
establishes the general rights and obligations of the flag State. Within the United
Nations two specialized agencies deal with maritime affairs, the International
Maritime Organization (IMO) (www.imo.org) and the International Labour
Organization (ILO) (www.ilo.org), and they have a responsibility for devising and
developing conventions and guidelines under which ships can be regulated. In
general, matters concerning safety at sea, pollution prevention and the training of
seafarers are dealt with by IMO, whereas the ILO deals with matters concerning
working and living conditions at sea. While IMO and ILO set the international
regulatory framework for ships, each member State bears the responsibility for
enforcing the international conventions it has ratified on the ships flying its flag.

6.3 RIGHT OF A PORT STATE


Coastal States have certain rights to exercise authority over ships in their waters.
In addition, a port State has the authority to check that foreign ships visiting its
ports meet all the appropriate convention standards. Indeed, the origins of port
State control can be traced back to the 1929 SOLAS Convention. Convention
control provisions can now also be found in MARPOL, the Load Line
Convention, STCW and the ILO Convention No. 147.
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A State may also enact its own domestic laws and impose additional national
rules and regulations on foreign ships entering its waters. The United States, for
example, has enacted the Oil Pollution Act, 1990 (OPA 90).

6.4 RULES THAT GOVERN PORT STATE CONTROL ACTIVITY


In November 1995, IMO adopted resolution A.787(19) – Procedures for port
State control. The resolution was amended in 1999 by resolution A.882(21) and
will no doubt be further amended in the future.

The Procedures are intended to provide basic guidance on how port State control
inspections should be conducted and how to identify deficiencies in a ship, its
equipment, or its crew, with the purpose of ensuring that convention control
provisions are consistently applied across the world from port to port.
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GEOGRAPHICAL VIEW OF PORT STATE CONTROL REGION

6.5 SELECTION OF SHIP FOR INSPECTION


To help port States identify suitable ships for inspection, port arrival listings,
shipping schedules and ship position reports are monitored. Central regional
databases such as the SIRENAC and APCIS databases managed by the Paris and
Tokyo MOUs respectively are also used by port States to access data on ships,
including reports of previous inspections. While such databases only hold
information and inspection reports on ships that have undergone an inspection
within any one region, international databases also now exist where port State
control information from all the regions is consolidated and published. EQUASIS
(www.equasis.org) is one such database. The European Commission and a
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number of quality-minded maritime administrations (France, Japan, Singapore,


Spain, the UK and the US) established EQUASIS in 2000.

[Source: 2005 Annual Report of the Paris MOU]


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6.6 TARGETING INSPECTION


Certain selection criteria such as the ship’s flag, age and type, are believed to
directly influence how well a ship is likely to be operated and in what condition a
ship is likely to be found. By allocating points to each criteria a scoring system
can be employed and a ship can be assigned a targeting factor. The Paris MOU,
for example, assigns an overall targeting factor to ships, whereas the US Coast
Guard (USCG) has developed a boarding priority matrix for the purpose of
calculating a targeting factor. Up-to-date information on the targeting factors used
by the various port State regions is widely published, including on their respective
web sites.

6.7 OWNER / OPERATOR


The USCG, in particular, targets owner / operators of ships with a bad detention
record. A Shipowners’ List is updated regularly and published on its web site.

6.8 CHARTERER
There are also moves to identify publicly the chatterers of ships that have been
detained. As more information is collected concerning chatterers then these
criteria may also become a regular factor used in the targeting of ships.

6.9 FLAG
Three-year rolling average tables of above average detentions are published
annually by the main port State regions. Ships of flag States whose detention
ratios exceed average detention ratios for all flag States can expect to be
especially targeted, as can ships from the flag States that have not ratified the
main conventions. In some cases, the port State control Authority might consider
the fact that a ship was registered to a targeted flag State as clear grounds for
proceeding directly, on boarding, with a more detailed inspection of the ship.
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6.10 LIST OF TARGETED FLAG STATE

[Source: 2003 USCG Port State Control Report]

6.11 CLASSIFICATION SOCIETY


Class-related detention figures for each classification society are also compared
against the average figure. Ships classed with a society that has a poor detention
ratio would be most affected, as would ships classed by a society that was not a
member society of IACS.
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6.12 PSC HISTORY


Ships visiting a port State region for the first time or after an absence of at least 6
months would be likely to receive particular attention, as would ships with
outstanding deficiencies and a record of detentions. A ship that has been
specifically permitted to sail to another port to rectify deficiencies would also be
targeted should it not arrive at that appropriate port within an agreed or reasonable
period of time.

6.13 SHIP TYPE AND AGE


These criteria generally follow those used to decide whether or not a ship is of a
type or age to justify it undergoing an expanded inspection. In general, tankers
(oil, gas and chemical), bulk carriers and passenger ships are the ones likely to be
targeted for such inspections. Any ship over 10 years old should also expect to be
targeted.

TYPE OF SHIP INSPECTED

[Source: 2005 Annual Report of Port State Control in Tokyo MOU]


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6.14 OVERRIDING FACTOR FOR TARGETING INSPECTION


Irrespective of targeting factors, campaigns and the like, there are a number of
circumstances or overriding factors that would take a ship to the top of the
inspection list and would result in the PSCO proceeding directly to a more
detailed inspection of the ship.

A. SHIP THAT HAVE BEEN REPORTED


Ships that have been reported by a pilot, port authority or another State can expect
to be directly targeted. Other complaints could similarly result in the ship being
specifically targeted. While a complaint could originate from the ship, or any
other person or organization with a legitimate but external interest in the ship, the
PSCO is not required to reveal his source and has no legal obligation to do so.

B. SHIP REPORTED AS HAVING OUTSTANDING DEFFICIENCY


Where a PSCO has allowed the ship to sail on condition that deficiencies are
rectified within a period of time, usually 14 days, and this stipulation will be
recorded in the regional port State database to be followed up in another port.

C. WHERE OPERATIONAL CONCERN TO SHIP EXIST

Operational incidents that could give rise to an inspection include:

i. collision, grounding or stranding on the way to the port;


ii. an alleged pollution violation;
iii. erratic or unsafe maneuvering, particularly around routing measures or
where safe navigation practices and procedures have not been followed;
iv. failure to comply with reporting procedures; or
v. the emission of a false alert that was not followed by proper cancellation
procedures.

6.15 SHIP SUSPENDED FROM CLASS


Ships that have been suspended or withdrawn from their class for safety reasons
in the previous 6 months could expect to be inspected.
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6.16 USCG BOARDING PRIORITY MATRIX

[Source: The USCG 2003 Port State Control Report]


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6.17 INSPECTION PROCESS


All port State control visits to a ship should start with the PSCO conducting an
initial inspection, unless overriding factors exist to allow the PSCO to proceed
directly to a more detailed inspection. If during that initial inspection the PSCO
finds evidence of a major problem with the ship, its crew or its operation, the
PSCO would have clear grounds for proceeding to a more detailed inspection of
the ship with a view to establishing its real condition. The existence of a
concentrated inspection campaign or an expanded inspection program would also
effectively result in the PSCO undertaking a level of inspection, over and above
that required of an initial inspection. Deficiencies may be identified at any stage
of the inspection process, and a detention order might follow.

6.18 PREPARING FOR INSPECTION


Because inspections are unannounced it is difficult for a ship to make any special
preparations for an inspection, except in cases where one could be anticipated. A
ship should therefore be ready to face an inspection at any port, at any time.

6.19 THE PORT STATE CONTROL OFFICER


The PSCO should be an experienced person qualified as a flag State surveyor and
able to communicate with the master and key crewmembers in English. He need
not, however, have sailed as master or chief engineer or have had any seagoing
experience. He should have no commercial interest in the port, the ship or be
employed by or on behalf of a classification society. Should he lack the necessary
expertise in some area of inspection an expert in that field could assist him. The
PSCO is issued with an identity card as evidence of his authority to carry out
inspections. All PSCOs should also carry a copy of the General Procedural
Guidelines for PSCOs from IMO resolution A.787(19) for ready reference when
carrying out inspections.

6.20 DEALING WITH THE PSCO


It is probably best assumed that the PSCO is fully qualified, well-trained and
familiar with ships although of course this may not always be the case. The
master should select a room for the initial meeting that is quiet, comfortable and
have all the certificates and documentation readily available. The reports of
previous port state inspections should also be at hand. All questions asked by the
PSCO should be responded to in an honest and straightforward manner.

When the PSCO is ready to make an inspection of the ship, a senior and
knowledgeable officer should be assigned to accompany him. That person should
be familiar with the ship and have the necessary keys with him so ensuring that
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ready access to all spaces is possible. If a spare crewmember or a cadet is


available, his attendance is also recommended. If things need immediate attention
or assistance needs to be called, that person can attend to such matters and the
flow of the inspection can remain unaffected.

It must be remembered that the master always has the right to query the direction
that an inspection is taking should he believe that the inspection could interfere
with the safety of the crew or indeed cause crew fatigue. Unreasonable requests
for drills while the ship is cargo handling or bunkering should always be
questioned.

6.21 INITIAL INSPECTION


• FIRST IMPRESSION
• CERTIFICATE CHECK
• “WALK AROUND” TO CHECK ON THE OVERALL CONDITON OF
THE SHIP
SAMPLE INITIAL INSPECTION CHECKLIST
First impressions (on boarding):
†
External condition of the:
. hull
. freeboard marks
. accommodation ladder
. mooring arrangements
Certificate check (in the master’s cabin):

As regards the general status of certificates / documentation - verify:


. missing or expired †
. not translated or posted up, as required
. discrepancies
. outdated or unsigned endorsements
. uncertified copies of original certificates
. inconsistencies or omissions in record books
. certificates issued by non-recognised organisations

As regards safe manning – verify:


. compliant manning levels †
. minimum rest periods applied

As regard crew certification – verify:


. presence of original and valid certificates †
. English translation
. medical certificates
. minimum age requirement complied with

As regards the ISM code – check:


. crewmembers are familiar with the Company ‘Safety and environmental protection policy’ †
. the ‘Safety management system’ documentation is readily available
. status of interim certificates
. the ship type is covered in the DOC
“Walk around” (to check on the overall condition of the ship):
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PSCO would be likely to verify the general condition of:


Exposed decks: †
. deck plating
. bulwark and stays
. guard rail
. hatch coamings and covers
. piping and vents
. presence of improper temporary repairs
. presence of recent welding / hot work
. presence of liquid seepage’s

Cargo handling gear:


. cargo gear and additional equipment †
. cargo securing devices

Navigation and radiocommunication equipment:


. navigational equipment †
. management of voyage charts / publications
. hand-over procedures for watch and control of ship
. bridge visibility
. record of steering gear tests / drills
. radio installation and equipment
. reserve radio batteries
. record of operation and maintenance
. fire detection and alarm systems

Lifesaving appliances (LSA):


. Lifeboats, rescue boats and liferafts †
. launching arrangements
. personal lifesaving appliances
. record of periodic inspections and testing / drills
. management of emergency plans and instructions
. consistency of mustering practice with that in the Plan

Fire fighting arrangements (FFA):


. fire doors †
. means of escape
. fire pumps
. fire main, hydrants and hoses
. fire extinguishers
. record of periodic inspections and testing / drills
. management of fire control plan and instructions

Machinery spaces:
. main and auxiliary engines †
. piping, pumps and valves
. electrical generators
. cables, terminations and joint arrangements
. lighting
. cleanliness of spaces
. emergency escape routes

Pollution prevention arrangements:


. oily-water separator and associated equipment †
. SOPEP
. garbage arrangements

Living and working conditions:


. condition and sufficiency of food and potable water supply †
. arrangements and cleanliness of food stores, galley, pantries, refrigerated chambers and
mess
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rooms
. sanitary arrangements, including condition of doors, flooring and drainage
. operation and maintenance of ventilation, lighting, heating and water supply
. medical facilities, including medicines and equipment
. record of accommodation inspections
. availability of personal protective equipment

6.22 CLEAR GROUND


Clear grounds for proceeding to a more detailed inspection exists if, during the
initial inspection the PSCO found evidence that:

1. The ship, its equipment, or its crew did not appear to correspond substantially
with the requirements of the relevant conventions; or
2. The master or crewmembers were not familiar with the essential shipboard
operational procedures that related to the safety of the ship or pollution
prevention.

Once the PSCO believes that a more detailed inspection is justified he is required
to inform the master giving reasons for his decision.

6.23 MORE DETAILED INSPECTION


A more detailed inspection is an in-depth inspection covering the ship's
construction, equipment, manning, living and working conditions and compliance
with on-board operational procedures. The purpose of a more detailed inspection
of the ship is to establish its real condition where doubts exist.

The nature and extent of the inspection required would determine how many
PSCOs were needed to attend the ship for the inspection. Inspections can involve
more than one person.

While at first instance the inspection should focus only on the areas of original
concern, it is often expanded to check that essential shipboard operations are
capable of being properly carried out by crewmembers. Any inspection should not
unnecessarily delay or impose undue physical demands on the ship that could
jeopardize safety. While the master would be entitled to query excessive
inspection demands, particularly those that could interfere with the running of his
ship, it is recommended that the master always remains positive and cooperative
in his dealings with the PSCO.
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EXAMPLES OF CLEAR GROUND


1 Evidence of inaccuracies in the certificates and other documentation during their
examination, including evidence that the oil record book has not been properly kept and †
absent or inaccurate ISM Code certification, where appropriate

2 Indications that crewmembers are not able to communicate adequately with each other
†
3 Evidence of shipboard operations, such as cargo work, are not being conducted safely
and in accordance with IMO guidelines †
4 Absence of an up-to-date muster list, fire control plan and a damage control plan, and
evidence that crewmembers are not aware of their fire fighting and abandon ship duties †
5 The absence of, or serious deficiencies in, the principal safety and pollution prevention
equipment or arrangements required by conventions †
6 Excessively unsanitary conditions on board the ship
†
7 Evidence that serious hull or structural deterioration or deficiencies exist that may place at
risk the structural, watertight or weathertight integrity of the ship. The absence on board of the †
survey report file, where appropriate, or the failure to keep the file up to date may also
constitute clear grounds

8 Evidence that the master or crew is not familiar with essential shipboard operations relating
to the safety of the ship or the prevention of pollution, or that such operations have not been †
carried out

9 Evidence that the ship’s log books, manual etc are not properly, or are falsely maintained
†
6.24 SUSPENSION OF AN INSPECTION
In exceptional circumstances, where the overall condition of a ship, its equipment
or the working or living conditions of the crew were found to be obviously
substandard, the PSCO may suspend an inspection.
In such cases, the port State should notify the flag State of the suspension without
delay. The suspension would continue until the deficiencies identified by the
PSCO have been rectified, as instructed.
6.25 DEFICIENCIES
A deficiency exists when a condition is found on a ship that is not in compliance
with the requirements of a convention. When deficiencies are found the nature of
the deficiency and the corresponding action to be taken by the ship is recorded on
the “Report Form B”. The number and nature of the deficiencies found by the
PSCO determine the corrective action that the ship needs to take and whether or
not the ship is to be detained.
It is important that the master fully understands what the deficiencies are, and the
rectification measures that the ship needs to take. The master must check that the
deficiency details entered on Form B are correct, and seek clarification from the
PSCO, where necessary.
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DIAGRAM SHOWING WHAT HAPPENS IF DEFICIENCES ARE FOUND

Deficiencies
sufficient to
detain ship
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6.26 CORRECTIVE ACTION WITHIN A SPECIFIED TIME PERIOD

There are three basic options available to the PSCO to take:

1. Require the rectification of deficiencies before the ship sails – the PSCO may
decide to return to the ship to check that the deficiencies have been correctly
rectified;

2. Permit the ship to sail on condition that the deficiencies are rectified at the
next port – he would then inform the next port of his decision; or

3. Require deficiencies to be rectified within 14 days, or in the case of ISM


nonconformity, within 3 months. The PSCO is then likely to report the
deficiencies as being ‘outstanding’ and, until the endorsement is lifted, the
ship can expect to be targeted for inspection at subsequent ports.

6.27 PERMIT TO SAIL


When a deficiency needs to be rectified but where proper repair facilities or docks
are not available at the port of inspection, the ship may be allowed to sail to the
nearest appropriate repair port. In assessing whether or not a ship is safe to
proceed to sea and onto a repair port, the PSCO would consider:

1. The length and nature of the intended voyage;


2. The size and type of ship;
3. The nature of the cargo being carried; and
4. Whether or not the crew were sufficiently rested.

It is essential that the ship reach the repair port, as instructed. Failure to do so
might result in a banning order being placed on the ship by the port State.

6.28 SUSPENSION OF SHIPS OPERATION


If the deficiencies found make cargo operations unsafe or threaten the marine
environment, the PSCO might suspend ship operations, such as cargo work or
bunkering. The following deficiencies might lead to a suspension:

1. Incomplete oil transfer procedures when bunkering;


2. Incomplete SOPEP arrangements;
3. Incomplete information on the cargo; or
4. A non-compliant cargo loading plan.
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6.29 DETENTION ORDER


A ship is detained where a PSCO decides that it is unsafe to proceed to sea or
because the deficiencies are so serious that they need to be rectified before the
ship sails. When deficiencies pose no reasonable threat to the environment and do
not seriously affect the safety of the ship or its crew, the ship should not be
detained.

6.30 BANNING ORDER


In general, if a ship leaves an inspection port with deficiencies and is ordered to
proceed to a nominated repair port, and either fails to comply with any of the
conditions imposed or fails to arrive at that port, a banning order will be imposed
on that ship.

In the case, for example, of a ship being detained in the absence of valid ISM
certification and the detention order being lifted to elevate port congestion, a
banning order would then be automatically applied and remain in force until that
ship could demonstrate full ISM compliance. A banning order would typically
apply to all ports within a port State region and would remain in force until the
shipowner could prove that all deficiencies had been rectified.
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6.31 Sample PSCI Checklist

EXAMPLES OF DETAINABLE DEFICIENCES

Under SOLAS:
• failure of the main propulsion, electrical, pumping and steering systems †
• poor cleanliness of engine room, excessive amounts of oily-water in the bilges, pipework
insulation contaminated by oil
• absence, insufficient capacity or poor condition of LSA equipment
• absence, non-compliance or poor condition of FFA equipment, ventilation valves, fire
dampers and quick closing devices
• absence, non-compliance or poor condition of navigation lights, shapes and sound signals
• absence or failure of mandatory navigation systems and equipment
• absence of corrected nautical charts and publications
• absence or failure of radiocommunication systems
• number, composition or certification of crew not corresponding to safe manning certificate
• serious deficiency of crew's operational competence (see checklists)

Under LOAD LINES:


• significant areas of damage or corrosion, or pitting of plating and associated stiffening in †
decks
and hull effecting seaworthiness, unless proper temporary repairs for a voyage to a port for
permanent repairs have been carried out
• insufficient stability or ability to calculate stability conditions
• absence or poor condition of hull closing devices such as hatchcovers and watertight doors
• overloading
• absence or inability to read the draught marks

Under MARPOL (Annex I):


• absence, poor condition or failure of oily-water filtering equipment, oil discharge monitoring †
and control systems and alarms
• remaining capacity of slop and/or sludge tank insufficient for intended voyage
• no oil record book

Under STCW:
• lack of or insufficient crewmember certificates/endorsements †
• inadequate navigational or engineering watch arrangements/personnel
• crewmember competency not adequate for the duties assigned for the safety of the ship and
the prevention of pollution
• insufficient rested crewmembers for first watch and relieving watch duties at the
commencement of the voyage

Under ILO Conventions:


• insufficient food or potable water for next voyage †
• excessively unsanitary conditions on board
• no heating in accommodation if ship operating in low temperature areas
• excessive garbage, blocked passageways
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Section/Title Topic 6: Port State Control Inspection


Revision No. 03 Effectivity Date 16 July 2007 Page No. 20 of 29

MUSTERING

1 Are crewmembers aware of their duties indicated in the muster list and aware of the location
where to perform those duties? †
2 Are muster lists exhibited in conspicuous places throughout the ship, including on the
bridge, in the engine room and in the crew accommodation space? †
3 Does the muster list show the duties assigned to different crewmembers?
†
4 Does the muster list specify which officers are assigned to ensure that LSA and FFA
equipment is maintained in good condition and available for immediate use? †
5 Does the muster list specify substitutes for key persons that might become disabled?
†
6 Is the format of the muster list approved?
†
7 Is the muster list up-to-date and in conformity with the crew list?
†
8 Are the duties assigned to crewmembers manning the survival craft (boats or rafts) in
accordance by SOLAS chapter III, part B? †
9 Are the persons placed in charge of each survival craft and their substitutes named?
†
10 Are the operating instructions for the survival craft
†
COMMUNICATION

11 Are key persons able to communicate with each other?


†
12 Which languages are the working languages used onboard?
†
13 Are key persons able to understand each other during inspections or drills?
†
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Section/Title Topic 6: Port State Control Inspection


Revision No. 03 Effectivity Date 16 July 2007 Page No. 21 of 29

ABANDON SHIP DRILLS AND LSA EQUIPMENT

14 Is the correct alarm used for summoning crewmembers to the muster station(s) and are
crewmembers familiar with that alarm? †
15 During drills, are the survival craft correctly manned and operated by the assigned
persons? †
16 Do crewmembers dress suitably for drills and know how to correctly don lifejackets?
†
17 Is at least one lifeboat lowered after the necessary preparations, and launched with its
assigned crew into the water at least once every 3 months? †
18 Can crewmembers start and operate the lifeboat engine(s) satisfactorily?
†
19 Can crewmembers operate the davits (cranes) used for launching liferafts acceptably?
†
20 Are crewmembers familiar with their assigned duties during abandon ship operations?
†
21 Have crewmembers in charge of survival craft complete knowledge of the operation and
equipment of the craft? †
22 Can two crewmembers undertake the preparations for embarking and launching survival
craft beundertaken in less than 5 minutes? †
23 Does the performance of crewmembers on the drills suggest that the ship could be
abandoned in 30 minutes? †
24 Is the condition of the survival craft, their contents (food, water etc) and launching
arrangements (including davits, falls, winches and brakes) satisfactory? †
25 Is the condition of the side lighting, emergency communication means, operating
instructions (posters / signs) and embarkation ladder arrangements satisfactory? †
26 Are the liferafts correctly serviced, stowed and connected to the ship by hydrostatic
releases? †
27 Is the number and stowage of lifejackets ( including immersion suits and thermal protective
aids, where appropriate) correct, and the number, condition and validity of life-buoys, rockets, †
smoke signals and SARTs?
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Section/Title Topic 6: Port State Control Inspection


Revision No. 03 Effectivity Date 16 July 2007 Page No. 22 of 29

FIRE DRILLS AND FFA EQUIPMENT

28 Do the crewmembers know how to activate the fire alarm?


†
29 Do the crewmembers understand the procedure for reporting a fire, once detected, to the
bridge and/or damage control centre? †
30 When the crew alarm is sounded, do the fire fighting parties promptly muster at their
stations? †
31 During the course of fighting a simulated fire, do the fire fighting parties correctly bring into
action, don and effectively use all the appropriate equipment? †
32 Do the fire fighting team leaders give effective orders and report adequately to the bridge
and/or damage control centre? †
33 Do the medical teams correctly take care of injured persons and handle the stretchers in
an acceptable manner through narrow passageways, doors and stairways? †
34 Do the appropriate crewmembers known how to operate the emergency generator, CO2
room, sprinkler and emergency fire pumps correctly? †
35 Do the appropriate crewmembers understand the operation of manually-operated fire
doors, watertight doors and fire dampers? †
36 Do the following function correctly:
. fire doors, including their remote operation if appropriate †
. fire dampers and smoke flaps
. quick-closing remotely operated valves
. emergency stops of fans and fuel oil pumps
. fire detection and fire alarm system
. fixed systems in engine room and cargo spaces (servicing dates)
. main and emergency fire pumps

37 Do the fire fighting appliances comply with the fire control plan?
†
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Section/Title Topic 6: Port State Control Inspection


Revision No. 03 Effectivity Date 16 July 2007 Page No. 23 of 29

DAMAGE AND FIRE CONTROL PLANS

38 Are the damage and fire control plans (or booklets) provided?
†
39 Are the crewmembers familiar with their duties according to, and information given on the
control plans? †
40 Can key persons explain the actions to be taken in various damage conditions?
†
41 Are key persons knowledgeable in respect of watertight bulkheads and the openings
therein , the means of closing and the positions of any controls? †
42 Can key persons explain arrangements for the correction of any list due to flooding?
†
43 Can key persons explain the effect of trim and stability in case of damage to and the
consequential flooding of a compartment and the countermeasures to be taken? †
44 Are the fire control plans permanently exhibited, up-to-date, and is one copy readily
available in an accessible position? †
45 Are key persons familiar with the principal structural members forming part of the various
fire sections and the means of access to the different compartments? †
MANUAL AND INSTRUCTIONS

46 Do key crewmembers understand manuals, instructions etc. relevant to the safe condition
and operation of the ship and its equipment? †
47 Is the following information provided in a language understood by the crew and are the
crewmembers aware of the contents and able to respond accordingly to:

. instructions concerning the maintenance and operation of FFA equipment and installations? †
. instructions to be followed in the event of an emergency? †
. posters and signs illustrating the purpose of controls and the procedures for operating
survival craft launching controls?
†
. instructions for on board maintenance of LSA equipment? †
. training manuals containing instructions and information on the LSA equipment provided? †
. the shipboard oil pollution emergency plan (SOPEP)? †
. the stability booklet, associated plans and information contained therein? †
48 Are key crewmembers aware of the requirements for maintenance, periodic testing,
training, drills and logbook entries? †
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Section/Title Topic 6: Port State Control Inspection


Revision No. 03 Effectivity Date 16 July 2007 Page No. 24 of 29

ISM

49 Is there a Company safety and environmental protection policy and are key personnel
familiar with it? †
50 Is the safety management documentation and manual readily available onboard?
†
51 Is the relevant documentation on the safety management system (SMS) in a working
language or a language understood by crewmembers? †
52 Can key personnel identify the company responsible for the operation of the ship and does
this correspond with the Company named on the ISM certificates? †
53 Can key personnel identify the “designated person”?
†
54 Are procedures in place for establishing and maintaining contact with shore management
in an emergency? †
55 Are there programmes available onboard for drills and exercises to prepare crewmembers
for emergency actions? †
56 Is documentation available to show how new crewmembers have been made familiar with
their duties? †
57 Can the Master provide documented proof of his responsibilities and authority, and allow
for, and sit comfortably with, his overriding authority? †
58 Have non-conformities been reported to the Company and has corrective action been
taken by the Company? †
59 Does the ship have a maintenance routine and are records available?
†
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Section/Title Topic 6: Port State Control Inspection


Revision No. 03 Effectivity Date 16 July 2007 Page No. 25 of 29

BRIDGE AND RADIO OPERATIONS AND EQUIPMENT

60 Is the OOW familiar with the bridge control and navigational equipment, changing the
steering mode from automatic to manual and the ship’s manoeuvring characteristics? †
61 Does the OOW have knowledge of the location and operation of all safety and navigational
equipment, including fire detection and alarm panels? †
62 Is the OOW familiar with collision avoidance procedures, the COLREGS, the radar, ARPA
controls and capable of obtaining acceptable radar picture? †
63 Is the OOW familiar with the procedures applying to the navigation of the ship in all
circumstances, including: †
. management of nautical charts and nautical publications
. bridge procedures, instructions and manuals
. voyage planning
. periodic tests and checks of equipment
. compass error checks
. preparations for arrival and departure
. signalling
. communications
. emergencies
. logbook entries

64 Is the GMDSS radio operator(s) able to use all components of the radio arrangement
including its test functions? †
65 Is the GMDSS operator(s) able to explain the correct procedures for cancelling a false
distress alert? †
66 Is the GMDSS equipment compliant for the sea areas the ship is trading, and if an
Exemption certificate is issued, does the ship comply with the special requirements imposed †
by the exemption?

67 Does the ship receive Navtex MSI messages?


†
68 Are the following satisfactory:
. EPIRB installation †
. Radar transponder installation
. Antenna condition
. Radio batteries
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Section/Title Topic 6: Port State Control Inspection


Revision No. 03 Effectivity Date 16 July 2007 Page No. 26 of 29

CARGO OPERATIONS
69 Are personnel assigned with specific duties related to the cargo and any cargo handling
equipment familiar with those duties? †
70 Are such personnel familiar with any dangers posed by the cargo or cargo operations?
†
71 Are the oxygen analysers and other personal protection devices used during cargo
operations in good working order? †
72 Are Ship / Shore Safety Checklists used?
†
73 Are bending stresses with maximum limits calculated?
†
74 Are cargo / ballasting operations carried out in accordance with the Loading / Discharging
Plan and cargo stowage conditions being observed? †
75 Are the responsible crewmembers familiar with the Cargo Securing Manual and other
Codes of Practice, where relevant? †
76 If the Bulk Carrier Booklet has been endorsed with any restrictions on the cargoes that can
be carried, are those restrictions being observed? †

OPERATION OF MACHINERY

77 Are key engineering personnel familiar with their duties related to the operation of
essential machinery, such as: †
. Emergency and stand-by sources of electrical power
. Auxiliary steering gear
. Bilge and fire pumps
. any other equipment essential in emergency situations

78 Are such personnel familiar with:


. the emergency generators †
. actions necessary before the main engine can be started
. different possibilities of starting the main engine in combination with the source of starting
energy
. procedures when the first attempt to start the main engine fails

79 Are such personnel familiar with:


. the stand-by generator engine †
. possibilities of starting the stand-by engine automatically and/or by hand
. blackout procedures
. load sharing system

80 Are such personnel familiar with:


. which type of auxiliary steering gear system applies to the ship †
. how it is indicated which steering gear unit is in operation
. what action is needed to bring the auxiliary steering gear into operation

81 Are such personnel familiar with:


. bilge pumps †
. number and location of bilge pumps, including emergency bilge pumps
. starting procedures for all these bilge pumps
. appropriate valves to operate
. most likely causes of failure of bilge pump operation and the possible remedies
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Section/Title Topic 6: Port State Control Inspection


Revision No. 03 Effectivity Date 16 July 2007 Page No. 27 of 29

. fire pumps
. number and location of fire pumps, including emergency fire pump
. starting procedures for all fire pumps and appropriate valves to open?

82 Are such personnel familiar with the starting and maintenance of lifeboat / rescue boat
engines? †
83 Are such personnel familiar with the local control procedures for those systems which are
normally controlled from the bridge? †
84 Are such personnel familiar with the maintenance procedure for batteries?
†
85 Are such personnel familiar with emergency stops, dampers, fire detection and alarm
systems, the operation of watertight and fire doors? †
86 Are such personnel familiar with the change of control from automatic to manual for
cooling water and lube oil systems for the main and auxiliary engines? †

BUNKERING OPERATIONS

87 Are bunkering transfer procedures posted, available and understood by all relevant
personnel? †
88 Are an appropriate number of personnel on duty for bunkering?
†
89 Are there means of communication between ship’s bunkering personnel and between ship
and ashore / barge? †
90 Are there procedures to report and deal with oil discharges?
†
CONTROL OF OILY MIXTURE FROM MACHINERY SPACES

91 Have all the operational requirements of MARPOL Annex I been met, taking into account:
. the quantity of oil residues generated †
. the capacity of sludge and bilge water holding tanks
. the capacity of the oily water separator?

92 Have all the correct entries been made in the Oil Record Book?
†
93 Has the correct use been made of reception facilities, and have any alleged inadequate
facilities been noted and reported by the Master to the flag State? †
94 Are the responsible personnel familiar with the procedures for handling sludge and bilge
water? †
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Section/Title Topic 6: Port State Control Inspection


Revision No. 03 Effectivity Date 16 July 2007 Page No. 28 of 29

CONTROL OF GARBAGE

95 Have all the operational requirements of MARPOL Annex V and national legislation been
met? †
96 Has the correct use been made of reception facilities, and have any alleged inadequate
facilities been noted and reported by the Master to the flag State? †
97 Are all ship’s personnel familiar with the principle of minimising the amount of potential
garbage and the shipboard procedures for handling and storing garbage as contained in the †
Garbage Management Plan?

98 Are ship’s personnel familiar with the disposal and discharge requirements under
MARPOL Annex V inside and outside a special area? †
99 Are they aware of the areas determined as special areas?
†
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Section/Title Topic 6: Port State Control Inspection


Revision No. 03 Effectivity Date 16 July 2007 Page No. 29 of 29

6.32 SAMPLE INSPECTION REPORTING FORM

INTERCARGO has developed this form for ships to report their experiences of port State
control inspections where the performance / practice of the Port State Control Officer (PSCO)
has caused concern to the ship. Confidentiality is assured, unless INTERCARGO is
requested to investigate.

GENERAL DETAILS (as recorded on "Report Form A" by the PSCO)

1 Reporting authority of 2 Name of ship


11 Place of inspection 6 IMO number
10 Date of final report 7 Gross tonnage

INSPECTION PRACTICE / PERFORMANCE

Interval between inspections: †


. Less than six months since last "clean" inspection (no recorded deficiencies)

Timing of the inspection during scheduled port stay: †


. Did the PSCO attend the ship at an unreasonable / unnecessarily inconvenient
time? i.e. within hours of the ship's scheduled departure time

Charging policy imposed:


. Excessive level of charges †
. Unfair application of charges †
Unreasonable attitude of the PSCO:
. The PSCO proceeded with a "more detailed inspection" despite the lack of clear †
grounds
. The PSCO required corrective actions not called for by class or convention regulation
. The PSCO imposed undue demands on the routine operation of the ship
†
. The actions of the PSCO unnecessarily delayed the ship †
†
Identification of deficiencies:
. The PSCO showed poor professional judgement †
. The PSCO exaggerated the severity of the deficiencies †
. The nature of the deficiencies identified and the corrective actions needed to clear the
†
deficiencies were not clearly explained

Detention order:
. The opportunity to consult owner, class or flag State was not provided †
. The detention was unfair / unreasonable †
. The PSCO gave no information on the right to appeal his decision
†

REASONS (please give experiences not listed, or expand on any of the points raised above)

Master: __________________________ Company: _______________________


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Section/Title Topic 7: Seafarers Role & Attitudes in Pollution Prevention


Revision No. 03 Effectivity Date 16 July 2007 Page No. 1 of 8

TOPIC 7

Seafarers Role and Attitude in Pollution Prevention

Content: Page

7.1 Seafarers Role in Waste Management ................................................................02


7.2 Shipboard Waste Management System ..............................................................02
7.3 What is attitude? .................................................................................................02
7.4 What affects our behavior? .................................................................................03
7.5 Attitude indicators: Hazardous thoughts.............................................................03
7.6 Attitude indicators: Safe thoughts.......................................................................03
7.7 The role of senior management on board ...........................................................04
7.8 Guidelines to minimize environmental liability .................................................06
7.9 Some suggested areas of investigation for OWS system ...................................07
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Section/Title Topic 7: Seafarers Role & Attitudes in Pollution Prevention


Revision No. 03 Effectivity Date 16 July 2007 Page No. 2 of 8

TOPIC 7
Seafarers Role and Attitude in Pollution Prevention
7.1 Seafarers’ role in waste management

The shipboard personnel are involved in the process of waste generation and
management from a number of different perspectives:

• As operator and maintenance personnel of different machineries onboard that


will definitely produce waste products.
• As initiators of the waste management chain by transferring of waste materials
for treatment and disposal.
• As initiator of illegal discharges of oil and other solid waste materials at sea.

7.2 Shipboard Waste Management System

• Seafarers must understand what Shipboard Waste Management System can


achieve in terms of the quantities of waste dealt with and the benefits and
disadvantages to human health and the environment associated
• They must understand how their actions can reduce the amount of waste
requiring treatment or disposal
• All waste management options have their advantages and disadvantages and
gauging the seafarers’ views of each will play an important part in developing
and implementing effective waste management plans.

7.3 What is an attitude?

• The configuration of all of a person’s expectancies about an object, or the


organization of concepts, beliefs, habits and motives associated with the
object.
• The way you look upon the world around you. If you see a negative or a
positive world depends on your attitudes.
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Section/Title Topic 7: Seafarers Role & Attitudes in Pollution Prevention


Revision No. 03 Effectivity Date 16 July 2007 Page No. 3 of 8

7.4 What affects our behavior?

Personality

Attitudes

7.5 Attitude indicators: Hazardous thoughts


• I can do it
• We’ve always done it that way
• It won’t happen to me
• Do something quickly
• It’s not my job
• I thought
• It won’t make any difference
• Don’t tell me

7.6 Attitude indicators: Safe thoughts


• I can do it – Why take chances?
• We’ve always done it that way – Then it’s about time we reviewed it
• It won’t happen to me – It could happen to me
• Do something quickly - Not so fast… think!
• It’s not my job – We’re all on the same ship
• I thought - Check
• It won’t make any difference – Don’t give in
• Don’t tell me - Follow the rules
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Section/Title Topic 7: Seafarers Role & Attitudes in Pollution Prevention


Revision No. 03 Effectivity Date 16 July 2007 Page No. 4 of 8

7.7 The role of senior management on board the ship

General
The Role of Master, Chief Engineer and senior officers in the engine department
should:

• Promote awareness that any attempt to circumvent MARPOL requirements is


totally unacceptable
• Determine the most appropriate procedures to maintain equipment and
systems
• Minimize and if possible eliminate leakage through good housekeeping
• Correctly maintain the oil record book (ORB) and the record of discharges of
oily water separator effluent into the sea
• Ensure that all routine shipboard and ISM safety meetings include time to
discuss a specific agenda item on environmental matters
• Use sign on/off check lists for duty personnel.

Use of Oily Water Separators


The Master, Chief Engineer and senior officers in the engine department should:

• Instruct users of OWS equipment and verify the standard achieved


• Verify that maintenance schedules are being followed
• Ensure that audits include operational tests and a reconciliation of records
• Ensure that scheduled tank sounding logs are maintained and signed for
• Keep records of verification of correct operation through testing at sea
• Ensure that on board spares are adequate to meet the demand
• Create a culture where complacency in operation and maintenance standards
is unacceptable.
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Section/Title Topic 7: Seafarers Role & Attitudes in Pollution Prevention


Revision No. 03 Effectivity Date 16 July 2007 Page No. 5 of 8

Record keeping
The Master, Chief Engineer and senior officers in the engine department should:

• Ensure that all entries in the tank sounding log, ORB (oil record book†) and
incinerator logs are completed by the crew member who performed the task
• Ensure that the ORB is examined and signed by the Chief Engineer and/or the
Master
• Require signatures from those conducting overboard discharges and
operational tests
• Ensure that ship familiarization procedures verify that company
environmental policy and operability of equipment are understood and
followed
• Require the status of pollution prevention equipment to be recorded in the
handover notes of the responsible engineer and the Chief Engineer
• Record the independent verification of the correct operation of the oil
discharge monitoring equipment
• Raise awareness of the need for an open chain of command and accurate
record keeping that can be substantiated with Port State Control.

Tracking waste and maintenance

The Master, Chief Engineer and senior officers in the engine department should:

• Conduct analyses of waste disposal records


• Compare waste output to volumes purchased
• Compare waste disposal records with maintenance records
• Remove disincentives to off-loading waste, or purchasing additional material
or parts related to safety and the environment.
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Section/Title Topic 7: Seafarers Role & Attitudes in Pollution Prevention


Revision No. 03 Effectivity Date 16 July 2007 Page No. 6 of 8

7.8 Guidelines to minimize environmental liability:

• Reduce the amount of oil getting into the bilges. Contain and eradicate oil
leaks promptly and efficiently
• Ensure that the oily water separation, monitoring, and control equipment on
board is operating in accordance with MARPOL.
• Consider option of increasing storage tank capacity for oily water, which will
reduce the need to use the oily water separator
• Ensure that no illegal by-pass piping or other arrangements are provided in
violation of, Regulation 9 and 16 of MARPOL 73 /78 , Annex - I
• Ensure that the emergency bilge discharge valves and other overboard
discharge valves of a similar nature that are normally closed are sealed in the
closed position.
• Cleaning agent used in machinery spaces can cause oily water to emulsify.
Use recommended cleaning agent by OWS manufacturer.
• Ensure Bilge systems are maintained in accordance with the plans approved
by the vessel's classification Society
• Verify by independent audit on regular basis performance of OWS and in
particular oil Content Meter calibration is accurate
• Ensure complete records are maintained for the shipboard transfer, storage,
and disposition of oil and oily wastes, including sludge in holding tanks, bilge
holding/separated oil tanks and by incineration;
• Ensure all shore-side discharges of oil and oily wastes, including sludge, are
supported by receipts which account for the amount and type of waste
discharged as well as the date and place of discharge ;
• Ensure the Oil Record Book is properly maintained and that it is checked for
consistency with other shipboard log books. Repairs, testing, and routine
maintenance of Oily Water Monitoring and Control System and Oil Filtering
Equipment are to be duly noted in the oil Record Book.
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Section/Title Topic 7: Seafarers Role & Attitudes in Pollution Prevention


Revision No. 03 Effectivity Date 16 July 2007 Page No. 7 of 8

7.9 Some suggested areas of investigation for OWS system


1. Human factors
• Would well-paid union protected crew members violate the law?
• What makes it difficult for engine room crews to use OWS properly from
a psychological point of view?
• What incentives can be provided to make engine room crews use OWS
properly?
• How can third world crews protect themselves against dishonest
shipowners?
• Is more or different training needed?
• Go aboard and observe crews in action

2. System design

• Are ships properly designed to deal with oily waste?


• Should the OWS be located in a different part of the ship?
• Are the bilges and slop tanks located in the best part of the ship?

3. Equipment design

• Do the OWS actually do what they are advertised to do?


• How can OWS be altered to make them more user friendly to shipboard
crews in the ship environment?
• Is there other oil/water separation technology out there?

4. Maintenance

• Ship’s crews are small and overworked. Let’s not make it worse
• What should a properly operating OWS look like?
• What is a proper OWS operating process?
• What is a proper OWS maintenance routine?
• What are “standard” waste oil generation rates?
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Section/Title Topic 7: Seafarers Role & Attitudes in Pollution Prevention


Revision No. 03 Effectivity Date 16 July 2007 Page No. 8 of 8

5. Conversion

• What do proposed changes cost?


• When should proposed changes be made?
• Are proposed changes realistic from a conversion/cost/schedule point of
view?

A final thought
Today, there are crew members and owners who break the
law, and who are being punished for polluting our oceans.

At the same time there are almost certainly Crew members


and Owners who are innocent and who are being unjustly
punished.
As knowledgeable and concern seafarers let’s see if we can
stop the guilty and protect the innocent.

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