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TYNE COAST COLLEGE & ROMANIAN NAUTICAL COLLEGE

HIGHER NATIONAL DIPLOMA – NAUTICAL SCIENCE

DECK OFFICER OF THE WATCH PROGRAMME


Year 1 / Block 2

MARINE CARGO OPERATIONS


Code F0LM 34

OUTCOME 4: Marine Pollution


WEEKS 11 and 12

All Rights Reserved to Tyne Coast College | Copyright 2017


Higher National Unit Specification

Unit title: Marine Cargo Operations

Unit code: F0LM 34


Outcome 4
Explain the precautions and procedures to be taken to prevent pollution of the marine
environment
Knowledge and/or skills
♦ International Convention for the Prevention of Pollution from Ships (MARPOL)
♦ Shipboard Marine Pollution Emergency Plans (SMPEP)
♦ Hazardous Goods
♦ Bunkering operations
Evidence Requirements
Candidates will need to provide evidence to demonstrate their knowledge and/or skills
by showing that they can:
♦ Explain for a sample of one of the following:
(a) the requirements of the MARPOL Convention and current legislation with
respect to preventing pollution of the marine environment
(b) pro-active and re-active policies with respect to marine pollution

♦ Explain the precautions and procedures to prevent pollution of the marine


environment for a sample of one of the following:
(a) Routine vessel operations
(b) Bunkering
(c) Carriage of hazardous substances on board
(d) Garbage and tank residue disposal

Where sampling is used a different sample must be used on each assessment occasion.

Marine Cargo Operation (F0LM 34) Outcome 4 – Marine Pollution 1


TABLE OF CONTENT

WEEK 11 SESSION 1 (3 hours)


1. MARPOL NOTES 3
2. REGULATION 14: OIL FILTERING EQUIPMENT 4
3. DISCHARGE FROM MACHINERY SPACES 5
4. REGULATION 34 CONTROL OF DISCHARGE OF OIL 6
5. REGULATION 37: SOPEP 7
6. POLLUTION PREVENTION METHODS ITEMISED ON THE TANKERS 8
SHIP SHORE SAFETY CHECKLIST
WEEK 11 SESSION 2 (3 hours)
7. ANNEX 2: SUBSTANCES INDICATED IN CHAPTER 17 OR 18 OF THE 10
INTERNATIONAL BULK CHEMICAL CODE
8. REGULATION 17: SMPEP 13
9. ANNEX 4: SEWAGE 14
10. ANNEX 5: GARBAGE 15
WEEK 12 SESSION 1 (3 hours)
11. A NEW CHAPTER FOR MARPOL ANNEX VI 23
12. BUNKERING OPERATIONS 30
13. MONITORING AND WATCH-KEEPING 30
14. RECORD KEEPING 30
WEEK 12 SESSION 2 (3 hours)
15. BALLAST WATER MANAGEMENT 32

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WEEK 11 SESSION 1 (3 hours)

1. MARPOL NOTES

Marpol is the International Convention for the Prevention of Pollution from


Ships, 1973 as modified by the Protocol of 1978/97. Marpol is one of the
most important international marine environmental conventions. It was
designed to minimize pollution of the seas, including dumping, oil and
exhaust pollution.

Objectives
To eliminate the pollution of the sea’s by oil, chemicals and other harmful
substances which might be discharged during the operation
To minimize the amount of oil that which is released due to accidents,
collisions, groundings etc.

Special Area:
Means a sea area where for recognised technical reasons in relation to
its oceanographical and ecological condition and to the particular
character of its traffic the adoption of special mandatory methods for
the prevention of sea pollution is required.
There are certain special areas on the IMO website which have asterisk in
the column for “with effect from”. This is to indicate that the local
government has not included the changes into the legislation or does not
have adequate shore reception facilities. Also to keep in mind that even if the
effective date is not applicable but if the flag state recognises the area as a
special area then the vessel has to abide, also if the coastal state has local
regulations the vessel will have to comply with those as well.

The 6 annexes of MARPOL


Annex 1: Regulation for prevention of pollution by oil
Annex 2: Regulation for prevention of pollution by noxious liquid substances
carried in bulk
Annex 3: Regulations for the prevention of pollution by harmful substances
carried in packaged form
Annex 4: Regulation for the prevention of pollution by sewage from ships
Annex 5: Regulation for the prevention of pollution by garbage from ships

Marine Cargo Operation (F0LM 34) Outcome 4 – Marine Pollution 3


Annex 6: Regulation of prevention of air pollution from ships

Annex 1
Special area as per annex 1

North West
Mediterranean
European
Sea
Waters
Oman area of
Baltic Sea
the Arabian Sea
Southern South
Black Sea
African waters
Red Sea Antarctic area
Persian Gulf
Gulf of Aden

2. REGULATION 14: OIL FILTERING EQUIPMENT

Vessels above 400 GT and less than 10000 GT shall have an oil filtering
equipment
Approved by the Administration
Will ensure that any oily mixture discharged into the sea after passing
through the equipment has an oil content not exceeding 15 ppm

Vessels above 10000 GT shall have an oil filtering equipment


In addition to the above, shall be provided with alarm arrangements
to indicate when the level cannot be maintained.
Also arrangements to ensure that any discharge of oily mixture is
automatically stopped when the oil content of the effluent exceeds 15
ppm

Marine Cargo Operation (F0LM 34) Outcome 4 – Marine Pollution 4


3. DISCHARGE FROM MACHINERY SPACES

In special Areas: (Regulation 15)


The ship proceeding is en route
The oily mixture is processed through an oil filtering system
The oil content of the effluent without dilution does not exceed 15ppm.
When the vessel is in the special area the oil filtering system apart from
having an alarm when the 15ppm cannot be maintained shall also be of a
design where the oil filtering system shall stop automatically when the oil
effluent exceeds 15ppm
Oily mixtures do not originate from the cargo pump room bilges in case
of oil tankers
Oily mixtures in case of oil tankers is not mixed with oil cargo residues

Outside special Area’s: (Regulation 15)


The ship proceeding is en route
The oily mixture is processed through an oil filtering system
The oil content of the effluent without dilution does not exceed 15ppm.
Oily mixtures do not originate from the cargo pump room bilges in case
of oil tankers
Oily mixtures in case of oil tankers is not mixed with oil cargo residues

Regulation 17 ORB PART 1


Ballasting or Cleaning of fuel oil tanks
Discharge of dirty ballast or cleaning water from fuel oil tanks
Collection , Transfer and disposal of oil residues
Non automatic starting of discharge overboard, transfer or disposal
otherwise of bilge water accumulated in machinery spaces
Automatic starting of discharge overboard, transfer or disposal
otherwise of bilge water accumulated in machinery spaces
Condition of the oil filtering equipment
Accidental or other exceptional discharges of oil
Bunkering of fuel or bulk lubricating oil
Additional operational procedures and general remarks

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Regulation 29 Slop Tanks
Oil tankers above 150 GT shall be provided with a slop tank arrangement
having the following provisions
Adequate means provided for cleaning of cargo tanks and transfer of
dirty ballast residues and tank washing from cargo tanks to slop tanks
Slop tank arrangement should be such to allow the transfer or
discharge of oily mixture in compliance with the discharge regulations
The slop tanks to have a capacity of min 3% of the total cargo carrying
capacity of the vessel. Maybe reduced to 2 or 1.5% if such an amount
is sufficient for carrying out tank cleaning operations without the
introduction of additional water into the system

Regulation 31: ODMCS


Tankers above 150 GT shall be fitted with an ODMCS
Must have a recording device to provide continuous record of the
operation showing the litres/nm, total quantity of oil discharge, the oil
content and the rate of discharge
Must be identifiable with date and time
Should come into operation when there is any discharge of effluents
to the sea and should be capable of stopping the operation if the
instantaneous rate of discharge exceeds 30 litres/nm
Failure to the system shall stop the operation
In case of failure, the system may be used on manual mode but the
defect to be repaired as soon as possible. Vessel maybe allowed to
undertake one ballast passage with the defective equipment

4. REGULATION 34 CONTROL OF DISCHARGE OF OIL

Outside special areas


Vessel should not be in a special area
Vessel should be en route
Vessel should be at least 50 miles from the nearest land
Any instantaneous discharge should not exceed more than 30
ltrs/nautical mile
Total oil residue discharged less than 1/30000 of the product carried for
tankers built after 31 Dec 1979

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The tanker has in operation an oil discharge monitoring and control
system and a slop tank arrangement
Discharge from cargo spaces while in Special Area (Regulation 34)
Any discharge into the sea of oil or oily residues from cargo spaces of an
oil tanker is prohibited when in special area

REGULATION 36 ORB part2


Part2 is carried by tankers and is for the cargo/ballast operations
Entries
Loading of oil cargo
Internal transfer of oil cargo while on voyage
Discharging of oil cargo
Ballasting of the cargo tanks and Ballasting of the dedicated clean ballast
tanks
Cleaning of cargo tanks including crude oil washing
Discharge of ballast except from the segregated ballast tanks
Discharge of water from the slop tanks
Closing of all applicable valves after slop tanks have been discharged
Closing of valves for isolation of dedicated clean ballast tanks from cargo
and stripping lines after slop tank discharge operations
Disposal of residues
Accidental discharge of any oil content and the reasons for the same
Conditions of the oil discharge monitoring system and the failures of the
same to be recorded too
All the entries made need to be signed by the responsible officer along with
the date and to be counter signed by the master. This record book needs to
be maintained onboard for 3 years.

5. REGULATION 37: SOPEP

1. Every oil tanker more than 150 grt. and ship other than a tanker more
than 400 grt. shall carry and shipboard oil pollution emergency plan
2. Procedures to be followed by the master or other persons having the
charge of the ship to report an oil pollution incident
3. List of authorities or persons to be contacted in event of any oil
spill/pollution incident

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4. Detailed description of the actions to be taken to reduce or control the
discharge of oil following the incident
5. Procedures and point of contact on the ship for co-ordinating the
shipboard actions with the national and local authorities in combating
the pollution
6. All oil tankers of 5000 tonnes deadweight or more shall have access to
computerised shore based damage stability and residual structural
strength calculation programs

6. POLLUTION PREVENTION METHODS ITEMISED ON THE TANKERS


SHIP SHORE SAFETY CHECKLIST

vessel should be securely moored


effective ship shore communication system established
emergency signals to be used by the ship and shore to be decided and
understood
cargo hoses are properly rigged and not damaged
SOPEP equipment standby
Scupper plugs in place
High level alarms of the tanks to be operational
Checklist will also contain
Firefighting equipment to be kept standby
Effective deck watch to be maintained to check any overflow
No unauthorised persons onboard
No unauthorised work to be carried out
No naked lights and flames
Tanks inerted and the inert gas systems checked
All doors to accommodation to be closed and the air conditioning systems
to be on internal circulation
Appropriate lights and flags shown

Certificates issued under annex 1


International Oil Pollution Prevention Certificate
Surveys: Initial, Annual, Annual /Intermediate, Intermediate/Annual,
Annual & Renewal
Attachments:

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Form A: Listing equipment, arrangement & procedures in machinery
spaces
Form B: Listing equipment, arrangement & procedures in cargo
spaces

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WEEK 11 SESSION 2 (3 hours)

7. ANNEX 2: SUBSTANCES INDICATED IN CHAPTER 17 OR 18 OF THE


INTERNATIONAL BULK CHEMICAL CODE

Regulation 6: Categories of substances

Category X: NLS which if discharged into the sea from tank cleaning or
deballasting operations are deemed to present a major hazard to either the
marine environment or human health and therefore justify the prohibition
of discharge into the marine environment

Category Y: NLS which if discharged into the sea from tank cleaning or
deballasting operations are deemed to present a hazard to the marine
environment or to human health or cause harm to the uses of the sea
therefore limitations are applied on the quantity and quality of discharge
into the marine environment

Category Z: NLS which if discharged into the sea from tank cleaning or
deballasting operations are deemed to present a minor hazard to the marine
environment or human health or marine resources and therefore less
stringent restrictions apply on the quality and quantity of discharge into the
marine environment

Other Substances: NLS other than X, Y & Z which at the moment do not pose
any threat to the marine environment or human health on discharge into the
sea from tank cleaning or deballasting operations.

Regulation 13: Discharge standards for Annex 2 (NLS) within and


outside the Special area (applies to category X, Y & Z)
The discharge of these substances into sea is permitted with following
discharge standards
The ship is en route and doing a speed of at least 7 knots in case of a self-
propelled ship or at least 4knots in case of a non-self-propelled ship

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The discharge is made below the water line through the underwater
discharge outlets and not exceeding the rate by which the underwater
discharge outlets are designed
The discharge is made at a distance of not less than 12 nautical miles from
the nearest land and in the depth of water of not less than 25 metres.

Discharge Criteria for category X


Tank from which category X substance has been unloaded shall be
subjected to a pre wash before the vessel leaves the port of unloading.
The residues shall be discharged to port reception facilities until the
concentration falls to 0.1% by weight by analysis. All remaining tank
washings to be transferred until tank is empty. Entries to be made in
the cargo record book
Any water subsequently added maybe discharged into the sea
Where it is not possible to find the concentration of the effluent
without delaying the ship then alternate procedures maybe adopted
to find the concentration provided that
a) Tank is pre washed in accordance with the procedure adopted by
the administration
b) Appropriate entries are made into the cargo record book

Discharge Criteria for category Y & Z

If the unloading of the substance is not carried out in accordance with


the manual, a pre wash to be carried out prior the vessel leaves the
port of unloading. The tank washings to be discharged to shore
reception facilities.
For high viscosity or solidifying substances in cat Y
a) Pre wash to be carried out
b) The residue to be discharged to shore reception facilities until tank
is empty
c) Any subsequent water introduced into the tank maybe discharged
at sea

Special areas for annex 2:


Antarctica (No discharge in special area , south of 60 deg )

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Regulation 14: P & A manual

Every ship certified to carry CAT X, Y & Z shall have an approved P&A
manual.
The main purpose being to help identify the physical arrangements
and all the operational procedures w.r.t
a) cargo handling
b) tank cleaning
c) slops handling
d) cargo tank ballasting and deballasting.

8. REGULATION 17: SMPEP

Every ship above 150 GT certified to carry NLS to have an approved SMPEP
Procedures to be followed to report a NLS pollution incident
List of authorities and persons to be contacted
Detailed description of actions to be taken to reduce or control the
discharge of NLS
Procedures and point of contact on the ship for co-ordinating
shipboard action with national and local authorities
Entries in the cargo record Book
Loading of cargo
Internal transfer of cargo
Unloading of cargo
Mandatory pre wash in accordance with the ships P & A manual
Cleaning of cargo tanks except mandatory prewash
Discharge into the sea of tank washings
Ballasting of cargo tanks
Discharge of ballast water from cargo tanks
Accidental or exceptional discharge
Control by authorised surveyors
Additional operational procedures and remarks

Certificates issued under annex 2


Certificate of Fitness
Surveys: Initial, Annual, Annual /Intermediate, Intermediate/Annual,
Annual & Renewal

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Annex3: Applies to substances listed as marine pollutants in the IMDG
code

This annexe gives requirements for the standard of packing, marking,


packaging, labelling documentation, stowage and quantity limitation for
prevention of pollution by harmful substances
No dangerous goods to be carried by the ships unless a marine pollutant
or a dangerous goods declaration has been issued to the master
Any dangerous goods carried onboard should be detailed in a stowage
plan
Packaged goods shall not be accepted unless they are properly marked
No packaged goods to be carried unless the ship has an cargo securing
manual

9. ANNEX 4: SEWAGE

Sewage means
Drainage and other wastes from any forms of toilets and urinals
Drainage from medical premises ,wash tubs and scuppers located in these
premises
Drainage from spaces containing living animals
And other waste waters mixed with drainage as above

Regulation 10: Standard discharge connections


OD: 210 mm
ID: as per pipe OD
Bolt dia.: 170mm
Slots in flange: 4 hole 18mm
Flange thickness: 16mm
Bolts and nuts: 4 x 16mm

Regulation 11 - Discharge of sewage


1 Subject to the provisions of regulation 3 of this Annex, the discharge of
sewage into the sea is prohibited, except when:
.1 the ship is discharging comminuted and disinfected sewage using a
system approved by the Administration in accordance

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with regulation 9.1.2 of this Annex at a distance of more than 3
nautical miles from the nearest land, or sewage which is not
comminuted or disinfected at a distance of more than 12 nautical
miles from the nearest land, provided that, in any case, the sewage
that has been stored in holding tanks shall not be discharged
instantaneously but at a moderate rate when the ship is en route and
proceeding at not less than 4 knots; the rate of discharge shall be
approved by the Administration based upon standards developed
by the Organization; or
.2 the ship has in operation an approved sewage treatment plant which
has been certified by the Administration to meet the operational
requirements referred to in regulation 9.1.1 of this Annex, and
.2.1 the test results of the plant are laid down in the ship's International
Sewage Pollution Prevention Certificate; and
.2.2 additionally, the effluent shall not produce visible floating solids nor
cause discoloration of the surrounding water.

Special area for annex 4


Baltic sea
Certificates issued under annex 4
International Sewage pollution prevention Certificate
Surveys: Initial & Renewal

10. ANNEX 5: GARBAGE

Regulation 1

Definitions

For the purposes of this Annex:

1 Animal carcasses means the bodies of any animals that are carried on
board as cargo and that die or are euthanized during the voyage.
2 Cargo residues means the remnants of any cargo which are not covered by
other Annexes to the present Convention and which remain on the deck or

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in holds following loading or unloading, including loading and unloading
excess or spillage, whether in wet or dry condition or entrained in wash
water but does not include cargo dust remaining on the deck after sweeping
or dust on the external surfaces of the ship.
3 Cooking oil means any type of edible oil or animal fat used or intended to
be used for the preparation or cooking of food, but does not include the food
itself that is prepared using these oils.
4 Domestic wastes means all types of wastes not covered by other Annexes
that are generated in the accommodation spaces on board the ship. Domestic
wastes does not include grey water.
5 En route means that the ship is underway at sea on a course or courses,
including deviation from the shortest direct route, which as far as
practicable for navigational purposes, will cause any discharge to be spread
over as great an area of the sea as is reasonable and practicable.
6 Fishing gear means any physical device or part thereof or combination of
items that may be placed on or in the water or on the sea-bed with the
intended purpose of capturing, or controlling for subsequent capture or
harvesting, marine or fresh water organisms.
7 Fixed or floating platforms means fixed or floating structures located at sea
which are engaged in the exploration, exploitation or associated offshore
processing of sea-bed mineral resources.
8 Food wastes means any spoiled or unspoiled food substances and includes
fruits, vegetables, dairy products, poultry, meat products and food scraps
generated aboard ship.
9 Garbage means all kinds of food wastes, domestic wastes and
operational wastes, all plastics, cargo residues, cooking oil, fishing
gear, and animal carcasses generated during the normal operation of
the ship and liable to be disposed of continuously or periodically
except those substances which are defined or listed in other Annexes
to the present Convention. Garbage does not include fresh fish and
parts thereof generated as a result of fishing activities undertaken
during the voyage, or as a result of aquaculture activities which involve
the transport of fish including shellfish for placement in the
aquaculture facility and the transport of harvested fish including
shellfish from such facilities to shore for processing.
10 Incinerator ashes means ash and clinkers resulting from shipboard
incinerators used for the incineration of garbage.

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12 Operational wastes means all solid wastes (including slurries) not
covered by other Annexes that are collected on board during normal
maintenance or operations of a ship, or used for cargo stowage and handling.
Operational wastes also includes cleaning agents and additives contained in
cargo hold and external wash water.
Operational wastes does not include grey water, bilge water, or other similar
discharges essential to the operation of a ship, taking into account the
guidelines developed by the Organization.
13 Plastic means a solid material which contains as an essential ingredient
one or more high molecular mass polymers and which is formed (shaped)
during either manufacture of the polymer or the fabrication into a finished
product by heat and/or pressure. Plastics have material properties ranging
from hard and brittle to soft and elastic. For the purposes of this annex, "all
plastics" means all garbage that consists of or includes plastic in any form,
including synthetic ropes, synthetic fishing nets, plastic garbage bags and
incinerator ashes from plastic products.
14 Special area means a sea area where for recognized technical reasons in
relation to its oceanographic and ecological condition and to the particular
character of its traffic the adoption of special

Annexe 5 special areas (Regulation 5)


Mediterranean
Antarctic area
Sea
Wider Caribbean
region including the
Baltic Sea
Gulf of Mexico and
the Caribbean Sea
Black Sea
Red Sea
"Gulfs" area
North Sea
Antarctic area
(south of
latitude 60
degrees south)

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Simplified overview of the discharge provisions of the revised MARPOL
Annex V (resolution MEPC.201 (62)) which entered into force on 1
January 2013
(For the full text of the respective discharge requirements please refer to the
text of the revised MARPOL Annex V, and for more detailed guidance please
consult the 2012 Guidelines for the Implementation of MARPOL Annex V
(resolution MEPC.219 (63))
SEE CHART BELOW
1 These substances must not be harmful to the marine environment.

2 According to regulation 6.1.2 of MARPOL Annex V, the discharge shall


only be allowed if: (a) both the port of departure and the next port of
destination are within the special area and the ship will not transit
outside the special area between these ports (regulation 6.1.2.2); and (b)
if no adequate reception facilities are available at those ports (regulation
6.1.2.3).

Offshore platforms and all


Type of garbage Ships outside special areas Ships within special areas ships within 500 m of such
platforms

Discharge permitted ≥3 nm Discharge permitted ≥12


Food waste comminuted from the nearest land and en nm from the nearest land Discharge permitted
or ground route and en route ≥12 nm from the nearest land

Discharge permitted ≥12 nm


Food waste not from the nearest land and en Discharge prohibited Discharge prohibited
comminuted or ground route

Cargo residues1 not


Discharge prohibited Discharge prohibited
contained in wash water
Discharge permitted
≥12 nm from the nearest land Discharge only permitted in
1 and en route
Cargo residues specific circumstances2 and
Discharge prohibited
contained in wash water ≥12 nm from the nearest land
and en route

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Discharge only permitted in
Cleaning agents and
specific circumstances2 and
additives1 contained in Discharge prohibited
≥12 nm from the nearest land
cargo hold wash water
and en route
Discharge permitted
Cleaning agents and
additives1 contained in
Discharge permitted Discharge prohibited
deck and external
surfaces wash water

Carcasses of animals
Discharge permitted as far
carried on board as cargo
from the nearest land as Discharge prohibited Discharge prohibited
and which died during
possible and en route
the voyage

All other garbage


including plastics,
domestic wastes, cooking
Discharge prohibited Discharge prohibited Discharge prohibited
oil, incinerator ashes,
operational wastes and
fishing gear

When garbage is mixed with or contaminated by other substances prohibited from discharge or
Mixed garbage
having different discharge requirements, the more stringent requirements shall apply

The entries to be made in the garbage record book


Entries to be made are as follows
When garbage discharged at sea
When Discharged at port
When incinerated
Accidental discharge

REGULATION 9: Garbage management plans


Every ship more than 12m or more in length shall display placards which
notify the crew and passengers for the disposal requirements of regulations.
The placards shall be written in the working language of the ship, shall also
be English, French, or Spanish.
1. Every ship of 400 grt. and above and every ship which is certified to
carry 15 persons shall carry a garbage management plan. This plan
shall have written procedures for collecting, storing, processing and
disposing of the garbage including the use of the equipment onboard.
2. Every ship of 400 grt. and above and which is certified to carry 15
persons should have a GARBAGE RECORD book

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CATEGORY OF GARBAGE
A Plastics
B Food wastes
C Domestic Wastes
D Cooking Oil
E Incinerator ashes
F Operational wastes
G Cargo residues
H Animal Carcass(es)
I Fishing Gear

Column Headings

NEW TABLE LAYOUT AS BELOW


Date/Time Position of the Category Estimated To To Incineration Certification
Ship/Remarks Amount Sea Reception / Signature
(e.g., accidental Discharged Facility
loss) or
Incinerated

Annex 6

Emission Control area: Means an area where the adoption of special


mandatory measures for emissions from ships is required to
prevent, reduce and control air pollution from NOx & SOx &
particulate matter.

Vessels carrying ozone depleting substances (ODS) shall maintain an


ozone record book. Entries to be made in terms of mass of substance.
Entries should be as follows
a) Recharge (full or partial) of equipment containing ODS
b) Repair or maintenance on equipment containing ODS
c) Discharge of ODS deliberate or non-deliberate
d) Discharge of ODS to land based reception facilities
e) Supply of ODS to ship

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NOx: regulation applies to engines > 130 kW and not to engines used
solely for the purpose of emergencies, related to the emissions from
the engines. The manufacturer would provide a technical manual for
the engines specifying the settings in order to comply with the
regulations.
NOx emissions are controlled by Tier I, II & III
ECA for NOx
North
American
Area
United States
Caribbean Sea
ECA

SOx: Relates to the emission due to the sulphur content in the fuel
Under the revised MARPOL Annex VI, the global sulphur cap is
reduced initially to 3.50% effective from 1 January 2012
Then progressively to 0.50% effective from 1 January 2020.
The limits applicable in ECAs for SOx and particulate matter were
reduced to 1.00%, beginning on 1 July 2010
Being further reduced to 0.10 %, effective from 1 January 2015.
As per EU directives the limits applicable are 0.10% in EU ports
Baltic Sea (SOx)
North Sea (SOx)
North American area (SOx, and NOx and PM)
United States, Caribbean Sea ECA (SOx, NOx and PM)

Bunker Delivery notes to be retained for a period of 3 yrs and the sample
sent ashore for analysis. Bunkers to be obtained only from MCA approved
suppliers.

Volatile organic compounds (VOC): A tanker carrying crude shall have and
implement onboard a VOC management plan. The plan should provide
Written procedures for minimising VOC emissions during loading, sea
passage and discharging
Consideration given to additional VOC generated during COW

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Identify person responsible for implementing the plan
Be written in the working language of foreign going ships

Shipboard Incinerator: incineration of the following items are not allowed


Residues of cargo subject to annex I, II & III
Polychlorinated biphenyls (PCB)
Garbage having traces of heavy metals
Refined petroleum products containing halogen compounds
Sewage sludge and sludge oil not generated onboard
Exhaust gas cleaning systems

Certificates issued under annex 6


International Air Pollution Prevention Certificate with supplement with
details on the above 5 criteria
Surveys: Initial, Annual, Annual /Intermediate, Intermediate/Annual,
Annual & Renewal

International Energy Efficiency certificate


Shipboard Energy Efficiency Management Plan

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WEEK 12 SESSION 1 (3 hours)

11. A NEW CHAPTER FOR MARPOL ANNEX VI – REQUIREMENTS FOR


TECHNICAL AND OPERATIONAL MEASURES TO IMPROVE THE ENERGY
EFFICIENCY OF INTERNATIONAL SHIPPING

By Edmund Hughes, Technical Officer, Marine Environment Division,


IMO
February 2013

New regulations aimed at improving the energy efficiency of international


shipping entered into force on 1 January 2013.
The amendments to the International Convention for the Prevention of
Pollution from Ships (MARPOL) were adopted in July 2011.They add a new
chapter 4 Regulations on energy efficiency for ships to MARPOL Annex VI,
to make mandatory the Energy Efficiency Design Index (EEDI), for new
ships, and the Ship Energy Efficiency Management Plan (SEEMP) for all
ships. Other amendments to Annex VI add new definitions and the
requirements for survey and certification, including the format for the
International Energy Efficiency Certificate.
The regulations apply to all ships of 400 gross tonnage and above. However,
under regulation 19, the Administration may waive the requirements for
new ships up to a maximum of 4 years.
The EEDI is a non-prescriptive, performance-based mechanism that leaves
the choice of technologies to use in a specific ship design to the industry. As
long as the required energy efficiency level is attained (regulations 20 and
21), ship designers and builders would be free to use the most cost-efficient
solutions for the ship to comply with the regulations.
The SEEMP establishes a mechanism for operators to improve the energy
efficiency of ships. Regulation 22 requires ships to keep on board a ship
specific Ship Energy Efficiency Management Plan (SEEMP).

Enhancing energy efficiency


Shipping is permanently engaged in efforts to optimize fuel consumption.
And, while ships are universally recognized as the most fuel-efficient mode

Marine Cargo Operation (F0LM 34) Outcome 4 – Marine Pollution 22


of bulk cargo transportation, the Second IMO GHG Study, published in 2009,
identified a significant potential for further improvements in energy
efficiency, mainly through the use of already existing technologies such as
more efficient engines and propulsion systems, improved hull designs and
larger ships: or, in other words, through technical- and design-based
measures that can achieve noteworthy reductions in fuel consumption and
resulting CO2 emissions on a capacity basis (tonne-mile). The study also
concluded that additional reductions could be obtained through
operational measures such as lower speed, voyage optimization, etc.
The EEDI addresses the former type of measure by requiring a minimum
energy efficiency level for new ships; by stimulating continued technical
development of all the components influencing the fuel efficiency of a ship;
and by separating the technical and design-based measures from the
operational and commercial ones.
The SEEMP provides a management framework that may form part of the
ship’s safety management system, for improving the energy efficiency of a
ship whilst operating at sea and in port.

Applicability
The EEDI formula – as presently drafted – is not supposed to be applicable
to all new ships of 400 gross tonnes and above engaged in international
trade. Indeed, it is explicitly recognized that it is not suitable for all ship
types (particularly those not designed to transport cargo) or for all types of
propulsion systems (e.g., ships with diesel-electric, turbine or hybrid
propulsion systems will need additional correction factors).
Indeed, the first iteration of the EEDI has been purposefully developed for
the largest and most energy-intensive segments of the world merchant
fleet, thus embracing approximately 70 per cent of emissions from new
ships and covering the following ship types: tankers, gas carriers, bulk
carriers, general cargo ships, refrigerated cargo carriers and container
ships.
For ship types not covered by the current formula, suitable formulae will
be developed in due course to address the largest emitters first. IMO’s
Marine Environment Protection Committee (MEPC) is poised to consider
the matter in detail at future sessions, with a view to adopting further
iterations of the EEDI.

Marine Cargo Operation (F0LM 34) Outcome 4 – Marine Pollution 23


All existing ships of 400 gross tonnes and above engaged in international
trade are required to implement and maintain a SEEMP which establishes
a mechanism for operators to improve the energy efficiency of ships. This
should be achieved by monitoring the energy efficiency performance of a
ship’s transportation work and at regular intervals considering new
technologies and practices to improve energy efficiency.
The SEEMP will offer operators of existing ships the chance to reduce costs
immediately by saving fuel. As the regulation does not set any energy
efficiency requirements it will be up to the industry to proactively utilize
SEEMP to ensure they optimize the fuel saving benefits. In the end it is in
the industry’s best interests to utilize the SEEMP as with fuel accounting for
over 50% of operational costs, keeping fuel costs in check is a major factor
in the industry’s economic health. Such an approach will be important to
achieving both sustainable development and economic goals for the
industry going forward.
A set of such guidelines was adopted by MEPC 63 (March 2012) intended
to assist in the implementation of the mandatory regulations on Energy
Efficiency for Ships in MARPOL Annex VI:
• resolution MEPC.212(93) – 2012 Guidelines on the method of
calculation of the attained Energy Efficiency Design Index
(EEDI) for new ships;
• resolution MEPC.213(93) – 2012 Guidelines for the
development of a Ship Energy Efficiency Management Plan
(SEEMP);
• resolution MEPC.214(93) – 2012 Guidelines on survey and
certification of the Energy Efficiency Design Index (EEDI); and
• resolution MEPC.215(93) – Guidelines for calculation of
reference lines for use with the Energy Efficiency Design Index
(EEDI).

Minimum propulsion power

The need for a minimum propulsion power to be incorporated into the


EEDI formula has been duly acknowledged and, to that end, regulation 21.5
of MARPOL Annex VI states that
“For each ship to which this regulation applies, the installed propulsion
power shall not be less than the propulsion power needed to maintain the

Marine Cargo Operation (F0LM 34) Outcome 4 – Marine Pollution 24


manoeuvrability of the ship under adverse conditions as defined in the
guidelines to be developed by the Organization.”
It should, therefore, be clear that IMO fully supports the view that a
minimum installed power to maintain safe navigation in adverse (weather)
conditions is of critical importance to ensure both the safety and efficiency
of international shipping. While the EEDI instrument therefore contains the
standard to be achieved on this matter, implementation of that standard
will be enabled through guidelines that are also to be adopted. IMO circular
MSC-
MEPC.2/Circ.11 provides “Interim Guidelines for determining minimum
propulsion power to maintain the manoeuvrability of ships in adverse
conditions”.

Fuel efficiency and engine power


Although the easiest way to improve a vessel’s fuel efficiency is, indeed, to
reduce speed – hence the move to slow steaming by a significant number of
ships – there is a practical minimum at which fuel efficiency will decrease
as a vessel is slowed down further. There are other technical ways to
improve fuel efficiency, such as waste heat generators, which do not impact
on speed (they impact on auxiliary engines). Indeed, improvements in road
transport efficiency have been made through advances in technology that
have, however, not led to a sacrifice in speed; rather, quite the opposite.
It has been (wrongly) argued that the EEDI limits installed power and so
induces owners to use small-bore high-rpm engines, thereby increasing
fuel consumption. However, a reduction of installed power does not require
a reduction in engine bore and increasing rpm.
The easiest way to reduce power would be to “de-rate” the exact same
engine by limiting the “maximum” rpm (remember, horsepower = torque
multiplied by rpm). This would have the impact of increasing propeller
efficiency (if the exact same propeller is installed), as propeller efficiency
will generally improve as rpm decreases. Another practical way to reduce
installed horsepower is to install an engine with one cylinder fewer. This
would have no impact on specific fuel consumption or rpm. Such engines
can be identified by reference to the catalogues of major engine
manufacturers.
Of course, there are “economies of scale” in ships’ fuel efficiency. The larger
the ship (at a given speed), the lower the fuel consumption per unit of cargo.

Marine Cargo Operation (F0LM 34) Outcome 4 – Marine Pollution 25


However, such economies of scale are limited by trade considerations,
physical port limitations (generally, draft) or cargo logistics issues.
Therefore, ships tend to be designed to be as large as practical for a given
trade.

Effectiveness of EEDI and SEEMP in reducing emissions from ships

The EEDI, in establishing a minimum energy efficiency requirement for


new ships depending on ship type and size, provides a robust mechanism
that may be used to increase the energy efficiency of ships, stepwise, to
keep pace with technical developments for many decades to come. It is a
non-prescriptive mechanism that leaves the choice of which technologies
to use in a ship design to the stakeholders, as long as the required energy-
efficiency level is attained, enabling the most cost-efficient solutions to be
used.
Such technologies have been comprehensively considered in the 2009 IMO
GHG Study and are now frequently highlighted by the shipping media. A
consequence of the new regulations, and the growing interest and demand
for innovative energy efficiency improving technologies, is leading to
significant investment in research and development.
Fuel oil consumption represents a significant element of the cost of
operating a ship today. The effective implementation of SEEMP onboard a
ship could lead to a reduction in fuel used, and so could be considered a
commercial imperative, as much as a regulatory one, for those seeking to
manage a ship in today’s market. To enable the ship’s energy efficiency
performance is be optimised the operational energy efficiency measures
employed either at sea or in port need to be robustly monitored and
appropriate benchmarking tools used. Comparing the energy efficiency
performance of one ship with that of a similar ship on the same trading
route is also possible but this is more complicated as energy efficiency of
different ships can be affected by many variables, not least, the weather and
sea conditions they each experience. A proactive approach to energy
management of a ship should deliver cost improvements for the business
and a reduction of emissions from ships for wider society.

Marine Cargo Operation (F0LM 34) Outcome 4 – Marine Pollution 26


Special areas under MARPOL are as follows:
Adoption, entry into force & date of taking effect of Special Areas
Date of Entry
Special Areas Adopted # In Effect From
into Force
Annex I: Oil
Mediterranean
2 Nov 1973 2 Oct 1983 2 Oct 1983
Sea
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 1 Aug 2008
Gulf of Aden 1 Dec 1987 1 Apr 1989 *
Antarctic area 16 Nov 1990 17 Mar 1992 17 Mar 1992
North West
European 25 Sept 1997 1 Feb 1999 1 Aug 1999
Waters
Oman area of
15 Oct 2004 1 Jan 2007 *
the Arabian Sea
Southern South
13 Oct 2006 1 Mar 2008 1 Aug 2008
African waters
Annex II: Noxious Liquid Substances
Antarctic area 30 Oct 1992 1 Jul 1994 1 Jul 1994
Annex IV: Sewage
Baltic Sea 15 Jul 2011 1 Jan 2013 **
Annex V: Garbage
Mediterranean
2 Nov 1973 31 Dec 1988 1 May 2009
Sea
Baltic Sea 2 Nov 1973 31 Dec 1988 1 Oct 1989
Black Sea 2 Nov 1973 31 Dec 1988 *
Red Sea 2 Nov 1973 31 Dec 1988 *
"Gulfs" area 2 Nov 1973 31 Dec 1988 1 Aug 2008
North Sea 17 Oct 1989 18 Feb 1991 18 Feb 1991

Marine Cargo Operation (F0LM 34) Outcome 4 – Marine Pollution 27


Antarctic area
(south of
16 Nov 1990 17 Mar 1992 17 Mar 1992
latitude 60
degrees south)
Wider
Caribbean
region
including the 4 Jul 1991 4 Apr 1993 1 May 2011
Gulf of Mexico
and the
Caribbean Sea
Annex VI: Prevention of air pollution by ships (Emission Control
Areas)
Baltic Sea (SOx) 26 Sept 1997 19 May 2005 19 May 2006
North Sea (SOx) 22 Jul 2005 22 Nov 2006 22 Nov 2007
North
American
26 Mar 2010 1 Aug 2011 1 Aug 2012
(SOx, and NOx
and PM)
United States
Caribbean Sea
ECA 26 Jul 2011 1 Jan 2013 1 Jan 2014
(SOx, NOx and
PM)

Marine Cargo Operation (F0LM 34) Outcome 4 – Marine Pollution 28


A Particularly Sensitive Sea Area (PSSA) is an area that needs special
protection through action by IMO because of its significance for recognized
ecological or socio-economic or scientific reasons and which may be
vulnerable to damage by international maritime activities. The criteria for
the identification of particularly sensitive sea areas and the criteria for the
designation of special areas are not mutually exclusive. In many cases a
Particularly Sensitive Sea Area may be identified within a Special Area and
vice versa.

List of adopted PSSAs


The following PSSAS have been designated:
- The Great Barrier Reef, Australia (designated a PSSA in 1990)
- The Sabana-Camagüey Archipelago in Cuba (1997)
- Malpelo Island, Colombia (2002)
- The sea around the Florida Keys, United States (2002)
- The Wadden Sea, Denmark, Germany, Netherlands (2002)
- Paracas National Reserve, Peru (2003)
- Western European Waters (2004)
- Extension of the existing Great Barrier Reef PSSA to include the Torres
Strait (proposed by Australia and Papua New Guinea) (2005)
- Canary Islands, Spain (2005)
- The Galapagos Archipelago, Ecuador (2005)
- The Baltic Sea area, Denmark, Estonia, Finland, Germany, Latvia,
Lithuania, Poland and Sweden (2005)
- The Papahānaumokuākea Marine National Monument, United States
(2007)
- The Strait of Bonifacio, France and Italy (2011)
- The Saba Bank, in the North-eastern Caribbean area of the Kingdom of
the Netherlands (2012)

Marine Cargo Operation (F0LM 34) Outcome 4 – Marine Pollution 29


12. BUNKERING OPERATIONS

Safety and Environmental Protection:


• Know and use the appropriate Safety Management System checklists and
procedures for bunkering, and if applicable, for Ship to Ship operations
• Know the ship’s Shipboard Oil Pollution Emergency Plan (SOPEP) or
Shipboard Marine Pollution Emergency Plan (SMPEP)
• Ship’s oil spill equipment is to be ready and available in accordance with
the SOPEP/SMPEP
• Ensure that proper lines and means of communication internally and
externally are established prior to commencing operations, including
particularly agreement on how ship stop or supplier stop instructions will
be given, acknowledged and implemented
• Any spill in connection with a bunkering operation must immediately and
in accordance with the SOPEP/SMPEP be reported to the appropriate
bodies, including but not limited to:
• Port Authorities
• Port State Authorities
• Owners/Operators/Managers
• Ship’s P&I Club
• Oil Spill Contractors/Qualified Individual, if applicable
• Ship’s Flag State
Prior to bunkering the staff and crew involved must be aware of:
• The quantity and grades of fuel to be received.
• The method of delivery (pipeline, barge or road tanker).
• The tanks and pipeline systems on board that will be used during the
operation,
• The order in which the tanks will be filled.
• The anticipated pumping rate and duration of the operation.
• Who will be responsible for each aspect of the bunkering.
• All involved should review the appropriate requirements of the vessel SMS
and SOPEP or SMPEP.

Marine Cargo Operation (F0LM 34) Outcome 4 – Marine Pollution 30


13. MONITORING AND WATCH-KEEPING

As with all shipboard operations, monitoring of the operation and watch-


keeping is to be carried out in accordance with the Safety Management
System, Ship Security Plan and good seamanship taking into account the
prevailing conditions on board and in the vicinity of the ship. There should
be a minimum of one deck watch and one engine-room watch on duty at all
times overseeing the:
• Safe access between shore or ship to ship
• Bunker transfer connection
• Bunker transfer progress (transfer rate, in order to avoid overfills, bunkers
received versus capacity and agreed quantity to be received on board,
estimated time of completion, etc.)
• Sampling

14. RECORD KEEPING

All events and operations are to be carefully entered in both the Deck and
Engine log books respectively and checks made that the appropriate entries
in the Engine Room Oil Record Book are also made.

Marine Cargo Operation (F0LM 34) Outcome 4 – Marine Pollution 31


WEEK 12 SESSION 2 (3 hours)

15. BALLAST WATER MANAGEMENT

Legislation and Regulations


As shipping is probably the most
international industry, the only effective
way to address shipping related issues is
through a standardised international
system. This has been one of the hallmarks
of the success of IMO in its more than 50
year history. The avoidance of unilateral
responses by individual states is critical to
the success of any regulatory regime that
applies to shipping.

As described under the section on The


International Response, IMO member
States adopted the new ballast water
Convention in February 2004. As an IMO
activity, GloBallast is promoting the
adoption of the standardised IMO legal
regime throughout all of its activities. One
of these activities has been a Legislative
Review

Despite the significant efforts being expended by IMO member States to


develop an international legal instrument, many countries and even sub-
national jurisdictions have unilaterally developed or are developing
national or local legislation. These include Australia, Canada, Chile, Israel,
New Zealand, the USA, various individual States within the USA and various
individual ports around the world, such as Buenos Aires in Argentina, Scapa
Flow in Scotland and Vancouver in Canada.

Many of these unilateral responses remain generally consistent with


current IMO Guidelines, while others impose new and different requirements
on shipping. Such developments are of major concern to the shipping

Marine Cargo Operation (F0LM 34) Outcome 4 – Marine Pollution 32


industry, which must operate across many jurisdictions and which may be
impacted severely when the rules change from port to port. In order to keep
its members and others informed of legislative developments, the
International Association of Independent Tanker Owners (INTERTANKO)
has developed national legislation profiles, posted on its web site.

Treatment Technology
Reballasting at sea, as recommended by the IMO guidelines, currently
provides the best-available measure to reduce the risk of transfer of harmful
aquatic organisms, but is subject to serious ship-safety limits. Even when it
can be fully implemented, this technique is less than 100% effective in
removing organisms from ballast water. Some parties even suggest that
reballasting at sea may itself contribute to the wider dispersal of harmful
species, and that island states located ‘down-stream’ of mid-ocean
reballastring areas may be at particular risk from this practice.

It is therefore extremely important that alternative, effective ballast water


management and/or treatment methods are developed as soon as possible,
to replace reballasting at sea. Significant research and development (R&D)
efforts are underway by a number of scientific and engineering research
establishments around the world, aimed at developing a more complete
solution to this problem.

Options being considered include:


• Mechanical treatment methods such as filtration and separation.
• Physical treatment methods such as sterilisation by ozone, ultra-violet
light, electric currents and heat treatment.
• Chemical treatment methods such adding biocides to ballast water to
kill organisms.

Marine Cargo Operation (F0LM 34) Outcome 4 – Marine Pollution 33


• Various combinations of the above.
All of these possibilities currently require significant further research effort.
Major barriers still exist in scaling these various technologies up to deal
effectively with the huge quantities of ballast water carried by large ships
(e.g. about 60,000 tonnes of ballast water on a 200,000 DWT bulk carrier).
Treatment options must not interfere unduly with the safe and economical
operation of the ship and must consider ship design limitations. Any control
measure that is developed must meet a number of criteria, including:
• It must be safe.
• It must be environmentally acceptable.
• It must be cost-effective.
• It must work.
For a list of available technologies, please consult the IMO website

Ballast Water Exchange


Three methods of ballast water exchange have been evaluated and
determined to be acceptable to IMO; viz. the sequential method, the flow-
through method and the dilution method. A description of these methods is
as follows:
i) Sequential method – A process by which a ballast tank intended for the
carriage of water ballast is first emptied and then refilled with replacement
ballast water to achieve at least a 95% volumetric exchange.
ii) Flow-through method – A process by which replacement ballast water is
pumped into a ballast tank intended for the carriage of water ballast,
allowing water to flow through overflow or other arrangements. At least
three times the tank volume is to be pumped through the tank.
iii) Dilution method – A process by which replacement ballast water is filled
through the top of the ballast tank intended for the carriage of water ballast
with simultaneous discharge from the bottom at the same flow rate and
maintaining a constant level in the tank throughout the ballast exchange
operation. At least three times the tank volume is to be pumped through the
tank.

Marine Cargo Operation (F0LM 34) Outcome 4 – Marine Pollution 34


Ballast Water Treatment

Compliance requirements

IMO Current

Ballast capacity Existing ships Existing Ships Existing Ships


Constructed Constructed in Constructed
before 2009 or after 2009 in or after
but before 2012 2012
Less than 1,500m Entry into force Compliance by first IOPP renewal
(EIF)* before survey after EIF
2016:
compliance by
first IOPP**
renewal survey
after the
anniversary
date of the

Marine Cargo Operation (F0LM 34) Outcome 4 – Marine Pollution 35


delivery of the
ship in 2016
EIF after 2016:
compliance by
first IOPP
renewal survey
Between 1,500m3 Compliance by first IOPP renewal survey after EIF
and 5,000m3
Greater than EIF before 2016: compliance by Compliance by
5,000m3 first IOPP** renewal survey after first IOPP
the anniversary date of the delivery renewal
of the ship in 2016 survey after
EIF after 2016: compliance by first EIF
IOPP renewal survey

USCG Current (01/01/2014)

Ballast Date constructed Compliance date


water
capacity
New vessels All On or after 1 December, On delivery
2013
Existing Less than Before 1 December, 2013 First scheduled
vessels 1,500m3 drydocking after 1
January, 2016
1,500 – Before 1 December, 2013 First scheduled
5,000m3 drydocking after 1
January, 2014
Greater Before 1 December, 2013 First scheduled
than drydocking after 1
5,000m3 January, 2016

Regulation D-2 of the BWM Convention sets the standard that ballast water
treatment systems must meet (Table 3). Ballast water treatment systems
must have a type approval certificate in compliance with the IMO Guidelines

Marine Cargo Operation (F0LM 34) Outcome 4 – Marine Pollution 36


for the Approval of Ballast Water Management Systems (Resolution MEPC.
174(58)), which updated Resolution MEPC.125(53)).
It should be noted that the USCG treatment discharge standard is the same
as the IMO BWM Convention D-2 Standard.

Organism category Regulation


Plankton, >50 μm in minimum <10 cells/m3
dimensions <10 cells/ml
Plankton, 10-50 μm <1 colony forming unit
Toxicogenic Vibrio cholera (O1 and (cfu)/100ml or less than 1cfu/g
O139) (wet weight)
Escherichia coli <250 cfu/100ml
Intestinal Enterococci <100cfu/100ml

All ships of 400 gt and above will be required to have on board an approved
Ballast Water Management Plan and a Ballast Water Record Book to comply
with the BWM Convention. The Ballast Water Management Plan is required
to:
• assist the ship in complying with international regulations to minimise
the risk of the transfer of harmful aquatic organisms and pathogens in
ships’ ballast water and associated sediments
• identify the ship’s Ballast Water Management Officer
• consider ship safety elements, provide information to PSC officers on the
ship’s ballast handling system and confirm that ballast water
management can be effectively planned
• include training on BWM operational practices
• be written in the working language of the ship. If this language is not
English, French or Spanish a translation into one of these languages
must be included.

http://www.lr.org/Images/Understanding%20Ballast%20Water%20Mana
gement_0214_tcm155-248816.pdf

Marine Cargo Operation (F0LM 34) Outcome 4 – Marine Pollution 37


Regulatory update 15/01/2016 there are now 43 countries and 34.56% of
world tonnage signed up to the convention –and it requires 35% for
ratification.

NOTE:
The notes of the unit “Cargo Operations”, LO1, LO2, LO3 and LO4, have
been arranged and updated by capt.(ret) Stelian Cojocaru.
Romanian Nautical College, Constanta, 2017

AUTHOR: Capt. Paul ENGLISH <paul.english@stc.ac.uk>

Marine Cargo Operation (F0LM 34) Outcome 4 – Marine Pollution 38

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