How To Comply With MARPOL Annex 1

TECHNICAL BULLETIN
19/2005
Oily water separator maintenance/

operational recommendations
In the last three years, the Club has had It is illegal under MARPOL to sail from a
17 incidents in the USA (including the US port without a functioning OWS unit and
Virgin Islands) where the authorities have it is a requirement that sufficient spares
alleged irregularities in both the set up for the OWS must be maintained
and use of the ships 15 ppm oily water onboard.
separator (OWS) system. Only 4 of these
incidents have resulted in a fine and none All work performed on or around the
in a criminal conviction. However, the OWS and oil content meter should be
expenditure of investigating these carefully logged in the PMS and in the oil
incidents and defending the crew is in record book (ORB), entries in the ORB
excess of US$ 1,600,000, which is an being made under code letter I (general
average of around US$94,000 per remarks). A log entry could read as
allegation. follows:
To help Members avoid incurring such Opened and inspected OWS unit, filters
costs the Clubs ship inspectors offer the cleaned/renewed as required. Valves and
following advice. Clear to read piping on discharge side of OWS opened,
inspected and cleaned as required. After
It is recommended that the vessels maintenance OWS and oil content meter
planned maintenance system (PMS), and checked for proper operation.
companys standing instructions, include
inspection and cleaning of the OWS unit All log entries should be checked as
and all associated piping at least every six accurate and countersigned by the chief
months. It has been suggested that the engineer and the master. Consecutive
equipment filters should be cleaned logs should be kept onboard so that the
monthly where possible, especially prior full history of the equipment can be
to a prolonged period of coastal voyages. verified if required. It may also be
We advise that this work should not be beneficial to have a company wide
carried out immediately prior to entering instruction that the entries in the ORB are
port, as it may be construed as suspicious only made by the chief engineer after
by PSC or MARPOL inspectors. The oil cross referencing the engine log book,
content meter should also be tested PMS records and sounding records of all
annually and calibrated by a factory relevant tanks.
Full instructions posted
technician at least once every five years
(this is now a requirement in Canada and operating instructions and an operating The OWS should be operated during
will possibly be adopted by other diagram are posted on the OWS unit. normal engine room working hours.
countries). These should be as clear and simple as Engineers should not operate the
possible. It is a STCW convention OWS at night apart from during
Managers instructions and service requirement that engineering officers their regular watches. Units of
manuals concerning the OWS and related receive the mandatory minimum training measurement of volumes,
equipment should be maintained on the required by the provisions of Annex 1 of rates and capacities used
ship. It is mandatory that proper MARPOL 73/78. continued over
This document, and more, is available for download at Martin's Marine Engineering Page - www.dieselduck.net
in the engine room should be consistent. For tanks and equipment identified in the ships capacity stamped on the incinerators
example the units of measurement used in international oil pollution prevention identification plate. It is suggested that the
tank sounding tables should be the same as certificate (IOPP). On one ship a tank was certificates issued by flag state or class are
those used in recording volumes processed variously described in log entries as bilge checked to ensure they match the capacities
in the OWS. Care must be taken to ensure holding tank, bilge collecting tank, and stated in the vessels manuals and if there is a
that the quantity of water discharged BCT. Bilge tanks should also be identified discrepancy a request be made for the
overboard in any logged period does not by their location (frame number) and certificates to be amended accordingly.
exceed the certificated capacity of the OWS capacity as well as their correct title.
unit. If any such discrepancy should occur, a Ships personnel should be instructed that if
full explanation should be recorded in the Capacities of equipment and serial numbers they are asked questions by PSC or MARPOL
oil record book (ORB). noted on the IOPP certificate should be investigators they must give honest answers.
verified. It was found on one ship that the
Tank and equipment titles used in the ORB rated capacity of an incinerator on the ships If a ship is boarded by government
and in logbooks should match those of the IOPP Certificate was different from the investigators and it becomes apparent that
the inspection has been extended because
of problems arising from the training of
ships personnel, documentation or
equipment, the Club should be notified
immediately. The crew should never be
instructed to withhold information from
investigators. In the USA however they may
be told that the law does not require them to
speak to investigators if they choose not to
and that they are entitled to the presence of
a lawyer during questioning.
A recent development in the USA is for

officials to scrutinise the E/R alarm book and
compare the times recorded for bilge /
sludge tank alarms and subsequent
pumping out with the ORB times of
pumping bilges overboard, checking for any
discrepancies.
Sources of Information:
UK P&I Ship Inspection / Loss Prevention Department
OWS opened for maintenance John Giffin, Keesal Young & Logan
For further information please contact: Loss Prevention Department, Thomas Miller P&I Ltd
Tel: +44 20 7204 2307. Fax +44 20 7283 6517. Email: [email protected]
This document, and more, is available for download at Martin's Marine Engineering Page - www.dieselduck.net

How To Comply With MARPOL Annex 1

Uploaded by

Copyright:

Available Formats

How To Comply With MARPOL Annex 1

Uploaded by

Document Information

Original Description:

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

How To Comply With MARPOL Annex 1

Uploaded by

Copyright:

Available Formats

TECHNICAL BULLETIN

Oily water separator maintenance/

A recent development in the USA is for

You might also like