FIGHTING POLLUTION

PREVENTING POLLUTION AT SEA

EDITION 4
 FIGHTING POLLUTION
PREVENTING POLLUTION AT SEA
EDITION 4

A VIDEOTEL PRODUCTION

The Producers would like to thank the following for their help with this programme:

The European Union (EU)

Faire Marine Services
International Chamber of Shipping (ICS)
International Maritime Organization (IMO)
V Ships

WARNING:
Any unauthorised copying, hiring, lending, exhibition diffusion, sale, public performance or other exploitation
of this video and accompanying workbook training package is strictly prohibited and may result in prosecution.

COPYRIGHT © VIDEOTEL 2010

CONSULTANT: JON WONHAM
This video and accompanying workbook training package is intended to reflect the best available
VIDEO PRODUCER: ROBIN JACKSON
techniques and practices at the time of production, it is intended purely as comment. No responsibility is
accepted by Videotel, or by any firm, corporation or organisation who or which has been in any way VIDEO WRITER/DIRECTOR: ZIGGY USZKURAT
concerned with the production or authorised translation, supply or sale of this video and accompanying
workbook training package for accuracy of any information given hereon or for any omission herefrom.
4 5
CONTENTS 1 : INTRODUCTION

1 : INTRODUCTION 5 1.1 / AIMS AND OBJECTIVES

1.1 / AIMS AND OBJECTIVES 5 This training package deals with the ways in which professional sea farers can limit
1.2 / AN ENVIRONMENTAL POLICY 6 the pollution of the seas. It is designed for ships’ officers who should be well aware
2 : EXISTING REGULATIONS 8 of the problems of ensuring compliance with the regulations, with company policy
2.1 / MARPOL 73/78 AND ITS ANNEXES 8 and with industry best practice guidelines.
2.2 / OIL, SEWAGE AND GARBAGE DISCHARGE FOR ALL SHIPS 9 The intention here is to provide a focus for the officers themselves and so help to
2.3 / OIL DISCHARGES 10 achieve good training and motivation for other crew members. The strategy is to
2.4 / DISPOSAL OF SEWAGE 15
view compliance with the regulations as an essential minimum and to encourage all
2.5 / DISPOSAL OF GARBAGE 17
those involved to do everything possible to minimise the impact of their operations
2.6 / AIR POLLUTION 22
on the marine environment.
2.7 / ANTI-FOULING PAINT CONTROL 25
2.8 / BALLAST WATER 25 The video consists of four sections for convenience in presentation and ease of
2.9 / SHIP RECYCLING 26 assimilation. The first section presents the significance of ship-source pollution and
the need for the individual crew member to take it seriously and act accordingly.
3 : TRAINING TO PREVENT POLLUTION 27
The second deals with bunker loading and cargo handling. The third covers
3.1 / OIL-WATER AND OIL DISCHARGES 27
oil-water separation and monitoring, and the fourth, garbage handling and final
3.2 / GENERAL REQUIREMENTS 28
disposal.
3.3 / COMPLIANCE WITH MARPOL REGULATIONS 29
3.4 / AVOIDING ACCIDENTAL OIL SPILLS 31 This workbook should be used together with the video. It is also divided into four
3.5 / RESPONSE TO ACCIDENTAL OIL SPILLS 32 sections, the first of which is this introduction. The second section deals with
3.6 / SOME ADDITIONAL POINTS 33 existing regulations of MARPOL; the third covers methods of training to prevent any
3.7 / PROCEDURE FORMS AND OPERATIONAL CHECKLISTS 34 pollution from operational discharges or from accidental events; the fourth provides
4 : APPENDICES 36 a number of references, for example, a bunkering procedures checklist, which help
4.1 / BUNKERING OPERATIONS CHECKLISTS 36
the development of good practice on board.
4.2 / BALLAST WATER REPORTING FORM 38 In Section 3 on training, prevention of oil release from safe containment is treated
4.3 / GARBAGE RECORD BOOK 39 separately from procedures for dealing with operationally produced oily water
4.4 / MARPOL ANNEX I AMENDMENTS 39 mixtures. Here are listed causes of oil release, ways of avoidance, and means of
4.5 / INVENTORY OF HAZARDOUS MATERIALS 42 response should release occur.
4.6 / FURTHER RESOURCES 45
These, together with the items in Section 4, can be brought into a training session
5 : ASSESSMENT QUESTIONS 47
by photocopying the relevant pages. Crew members could then read through the
6 : ASSESSMENT ANSWERS 50 suggested points, discuss if and how they apply to their particular ship and decide

CONTENTS 1 : INTRODUCTION
6 7
how best to implement any measures not already part of regular practice. number of technologies have now been approved that should enable the standards
to be met.
There are many basic precautions against pollution which every ship and every
crew member can take. Company environmental policy should also take account of the fact that regulation
tends to become stricter where it already applies, and to extend its cover to
areas not yet regulated. To get ahead of the game and reach a more comfortable
1.2 / AN ENVIRONMENTAL POLICY state of self regulation, company environmental policy should seek to promote a
Every shipping company and every ship must have an environmental policy in place. proper understanding of the need for regulation, and the objectives of the various
This training package has been designed to assist in training those on board ship to Conventions, codes of practice and guidelines. This will encourage not only
be more aware of this policy. Any such policy must take account of the International compliance, but also the search for means to improve performance beyond current
Convention for the Prevention of Pollution from Ships, MARPOL 73/78, and its best practice.
Annexes, and of industry standards and port authority regulations. All shipping
Section 3 on training suggests what could be included in such a programme.
companies must ensure that their ships carry a Shipboard Oil Pollution Emergency
Many companies now appoint one of the officers on board to assume the duties of
Plan. Chemical tankers must, in addition, carry a Shipboard Marine Pollution
Environmental Officer (EO). The EO could set aside times for small groups of crew
Emergency Plan to cover potential environmental contamination from noxious liquid
members to meet and view the video and then discuss the various ways of reducing
substances.
pollution on board ship. There is no need to make such sessions overly formal - the
The six MARPOL Annexes have had a marked effect in reducing the amount of emphasis should be on practical ways of making sure that pollution incidents do not
pollution at sea. Pollution through oil and chemical discharges, the handling of happen.
packaged goods, and disposal of garbage and sewage are all covered by these
Wherever practical, it is preferable to avoid even discharges that are legal. The
regulations. Air pollution is covered by Annex VI and the amended regulations
identification of such opportunities could be made the basis of feedback from ships
entered into force on July 1st 2010. In some cases, individual nations may have
to company head offices for policy changes, if appropriate.
regulations that are more demanding than MARPOL, and local port requirements
should be checked. The United States, for example, has recently introduced the
Vessel General Permit (VGP), an environmental regulatory system that governs the
treatment or disposal of the many different effluent streams that may be found on
vessels operating in US coastal waters.

In addition, the IMO’s International Safety Management Code (ISM Code) is

progressively formalising and tightening up on safety management at sea. The
influence of the ISM Code will have affected the environmental policies of all
shipping companies.

In 2004, the IMO adopted the International Convention for the Control and
Management of Ships’ Ballast Water and Sediments, (BWM Convention). This
aims to limit the transfer of harmful organisms and pathogens in ballast water
discharges. Ships constructed from 2010 onwards must be equipped to meet
the standards for ballast water management established by the regulations and a

1 : INTRODUCTION 1 : INTRODUCTION
8 9
2 : EXISTING REGULATIONS
2.1 / MARPOL 73/78 AND ITS ANNEXES
The MARPOL Convention has now been in operation for a good many years
and you should be familiar with its main requirements. Its six Annexes deal with
discharges from ships of oil; noxious liquids carried in bulk; harmful substances in
packaged form; sewage; garbage; and air pollution. These Annexes contain many
regulations and are often amended and updated. There should be a current copy
aboard your ship.
Annex I deals with oil discharges from all ships and with the special requirements of
oil tankers. Annex II deals with the special requirements of bulk chemical tankers.
Annexes I and II have been made more user-friendly and harmonised as far as
possible as between oil and chemical tankers through revisions adopted by IMO
in October 2004. The revised texts entered into force on 1 January 2007 and have
been used as the basis for this text. Further amendments to Annex I are due to
enter into force on 1 January 2011. These will mean changes to the “Record of
Construction and Equipment” and the “Oil Record Book”. Shipboard personnel, in
particular, should be aware of changes to the Oil Record Book, and the background
to this. Details of these amendments can be found in Appendix 4.4.
Annex III deals with the carriage of packaged goods. Hazard evaluations continue
to be made as new substances enter the market and are regulated through the
addition of “marine pollutants” to the International Maritime Dangerous Goods Code
(IMDG Code).
Annex IV covers sewage and entered into force on 27 September 2003. It has also
been revised by IMO and references in this booklet are to the revised text, which
entered into effect on 1 August 2005.
Annex V is concerned with garbage and is supplemented with general IMO
guidance on garbage disposal. Floating garbage is seen as a particular problem
and the whole question of port reception facility arrangements continues to be
under review. As of 2010, work is continuing at IMO on a general revision of Annex
V and this may be completed in 2 to 3 years time.
2 : EXISTING REGULATIONS
Annex VI on Air Pollution entered into force on 19 May 2005. However, the date at
which diesel engines in new builds had to comply with NOx emission limits was 1
January 2000. The 2008 revision of Annex VI entered into force on 1 July 2010.
This booklet is concerned with the Annexes which relate to all ships, i.e. Annexes
I, IV, V and VI. The video deals principally with Annexes I and V. In addition, both
booklet and video include the specialised oil tanker-related aspects of Annex I in
respect of tank cleaning and ballast water related discharges.
2.2 / OIL, SEWAGE AND GARBAGE DISCHARGE FOR ALL SHIPS
Ideally, there should be no discharge but this is thought to be impractical. So
permitted limits for discharges are set with regard to what is ‘reasonable and
practical’ as judged by international consensus through IMO, in respect of whether
they are to occur inside or outside Special Areas and depending on the distance
from land at which they are to occur.
This in turn is based on the judgement that some sea areas are more sensitive to
pollutants than others and that any impact on shores and inshore waters has to be
specially avoided. These two judgements taken together mean that shores and
inshore waters are themselves ‘Special Areas’, whatever the designation of the sea
area itself may be.
In the case of oil, we also have to accept that oil-contaminated water discharged
from tankers within accepted limits may nevertheless form slicks which will affect
birds at sea. The slicks may wash up on beaches if they do not disperse into the
water column as small droplets before reaching shore. For these reasons, the
total amount of permitted discharge, the oil concentration in any discharges, and
the distance from shore, are set in such a way as to permit reasonable time for
dispersion.
Consideration of the regulations shows that oil as such should not be allowed
to enter the sea. Only oily water mixtures from clearly designated sources are
permitted and these may have to be processed in order to reduce the oil content to
acceptable levels. This may be achieved either by separation of oil from water by
gravity in tanks or by passage through oil-water separators, coalescers and filters.
If the regulation limits cannot be met, the oily waters must be retained onboard and
2 : EXISTING REGULATIONS
10
discharged to shore reception facilities. This also applies to cooking oil from the
galley; it should be stored onboard and discharged to shore reception facilities.
With garbage however, although discharge may be banned entirely in some cases
(i.e. plastics of any kind), distance from shore is generally the main consideration,
even though floating, non-degradable garbage may ultimately come ashore,
whatever the distance.
Processing is only called for by grinding and comminution in the case of food
wastes and that only in certain circumstances; and while discharge of plastics
and incinerator ash containing toxins and heavy metal residues is banned, all other
identified items and classes of garbage may be discharged without quantity limits,
provided stipulated distances from shore are met. However, local quarantine
regulations (e.g. in Australia and the USA) may dictate whether food wastes can be
discharged.
In the case of sewage, discharge is banned and it must be transferred to a holding
tank pending discharge to a shore reception facility or at stipulated distance from
shore. Ships may, however, be fitted with a system to comminute and disinfect
the sewage, or with a sewage treatment plant, in which case discharge from such
systems and plant is permitted, again with regard to stipulated, though shorter,
distances from shore.
All discharges of oil must be entered in the Oil Record Book and ballast water on
the Ballast Water Reporting Form. It is a legal requirement to keep these up-to-
date. Likewise all ships should be operating a Garbage Management Plan and
record discharges in a Garbage Record Book. Port State Inspectors often check
these records and inaccurate statements can lead to prosecution.
2.3 / OIL DISCHARGES
Annex I Special Areas
Special Areas for minimisation of oil pollution have been designated under Annex I
of MARPOL. These are the Mediterranean Sea area, the Baltic Sea area, the Black
Sea area, the Red Sea area, the ‘Gulfs’ area, the Gulf of Aden area, the Antarctic
area, North West European waters, the Oman area of the Arabian Sea and the
southern South African waters. The last named is the most recent Special Area
2 : EXISTING REGULATIONS
11
to be adopted and it entered into effect on August 1st 2008. The term, Special
Area means a sea area where, for recognised technical reasons in relation to its
oceanographic and ecological condition and to the particular character of its traffic,
the adoption of special mandatory methods for the prevention of sea pollution by
oil is required. In the case of the Red Sea, Gulf of Aden area and Oman area of
the Arabian Sea, the Special Area discharge requirements will become applicable
when the IMO determines an appropriate date, dependent on adequate reception
facilities being available. However, oil tankers entering these Special Areas for the
purpose of loading must make every effort to enter the area with only clean ballast
aboard.
In addition, Particularly Sensitive Sea Areas (PSSAs), currently exemplified by the
Great Barrier Reef, are likely to be identified in increasing numbers.
A new Chapter 9 has recently been added to Annex I so that, as from February
1st 2011, special requirements for the use or carriage of oils in the Antarctic Area
come into force. These basically prohibit the carriage in bulk or the use as fuel of:
1 Crude oils having a density at 15ºC higher than 900 kg/m3
2 Oils, other than crude oils having a density at 15ºC higher than 900 kg/m3 or a
kinematic viscosity at 50ºC higher than 180mm2/s, or
3 Bitumen, tar and their emulsions
Nearest Land
This is defined under Regulation 1 of Annex I and indeed is repeated in all the
Annexes.
The term ‘distance from nearest land’ means from the baseline from which the
territorial sea of the territory in question is established in international law, except
that for the purposes of the MARPOL Convention, ‘from nearest land’ on the north-
eastern coast of Australia (the Great Barrier Reef) shall mean from a line drawn
between a series of points, the positions of which, are set out in paragraph 10 of
Regulation 1.
Oil discharges In Special Areas (Regulation 15B)
Any discharge into the sea of oil or oily mixture from any oil tanker or any ship of
400 tonnes gross tonnage (GT) and above, other than an oil tanker, is prohibited.
2 : EXISTING REGULATIONS
12
In respect of the Antarctic area, any discharge into the sea of oil or oily mixture from
any ship is prohibited.
Any discharge into the sea of oil or oily mixture from a ship of less than 400 GT,
other than an oil tanker, is prohibited while in a Special Area, except when the oil
content of the effluent, without dilution, does not exceed 15 parts per million (ppm).
However, the above provisions do not apply to the discharge of clean or segregated
ballast (see later). Nor do they apply to the discharge of processed bilge water from
machinery spaces, provided that all the following conditions are satisfied:
a The bilge water does not originate from cargo pumproom bilges
b The bilge water is not mixed with oil cargo residues
c The ship is proceeding en route
d The oil content of the effluent without dilution does not exceed 15ppm
e The ship has in operation oil filtering equipment complying with the Convention
(Regulation 14.6) provided with an alarm arrangement to indicate when this
level cannot be maintained; and
f The filtering system is equipped with a stopping device which will ensure that
the discharge is automatically stopped when the oil content of the effluent
exceeds 15ppm (Regulation 14.7)
Saturated filters and sludge from fuel oil purification equipment must be incinerated
on board or delivered to reception facilities ashore.
Oil discharges outside Special Areas (Regulation 15A)
Any discharge of oil or oily mixtures from ships is prohibited except when all of the
following conditions are satisfied.
a For an oil tanker except as provided for in sub-paragraph (b) of this paragraph:
(i) the tanker is not within a Special Area
(ii) the tanker is more than 50 nautical miles from the nearest land
(iii) the tanker is proceeding en route
(iv) the instantaneous rate of discharge of oil content does not exceed 30 litres
per nautical mile
(v) the total quantity of oil discharged does not exceed, for existing tankers,
1/15,000 of the total quantity of the particular cargo of which the residue
formed a part and for new tankers, 1/30,000 of the total quantity of the
2 : EXISTING REGULATIONS
13
particular cargo of which the residue formed a part; and
(vi) the tanker has in operation an oil discharge monitoring and control system
and a slop tank arrangement as required by Regulations 29 and 31 of
Annex I
b From a ship of 400 GT and above, other than an oil tanker, and from machinery
space bilges excluding cargo pumproom bilges of an oil tanker, unless mixed
with oil cargo residue:
(i) the ship is not within a Special Area
(ii) the ship is proceeding en route
(iii) the oil content of the effluent without dilution does not exceed 15ppm
(iv) the ship has in operation equipment as required by Regulation 14 of this Annex
In the case of a ship of less than 400 GT, other than an oil tanker, whilst outside
Special Areas, the administration shall ensure that it is equipped as far as is
practicable and reasonable with installations to ensure the storage of oil residues
onboard and their discharge to reception facilities or into the sea in compliance with
the requirements of sub-paragraph (b) of this regulation.
The above provisions shall not apply to the discharge of clean or segregated
ballast or unprocessed oily mixtures which, without dilution, have an oil content not
exceeding 15ppm and which do not originate from cargo pumproom bilges and are
not mixed with cargo oil residues.
Segregated ballast, clean ballast and the Load-on-Top system
Segregated ballast means the ballast water introduced into a tank which
is completely separated from the cargo oil and oil fuel system and which is
permanently allocated to the carriage of ballast or cargoes other than oil or noxious
liquid substances as defined by MARPOL.
Since 6 July 1992, newer tankers have been built with double hulls, or prior to that,
protectively located Segregated Ballast Tanks (SBT) which have their own piping
and pumping systems. Such tanks never carry oil or have any contact with oil.
Older product tankers may continue to use the Clean Ballast Tank (CBT) system
in which tanks formerly used for cargo are now designated as ballast tanks for
the carriage of clean ballast, though they still share the cargo piping and pumping
system. Such tanks should only be used for ballast.
2 : EXISTING REGULATIONS
14
The discharge operations which are the subject of sub-paragraph (a) earlier, relate
to cargo tank cleaning for the purpose of preparing clean ballast tank capacity
during the ballast voyage. Such ships retain oil residues removed from tanks during
the cleaning process and operate the ‘Load-on-Top’ system (LoT), i.e. the next
cargo is loaded on top of the retained residues held in the tank designed as the
slop tank for the cleaning process.
‘Clean Ballast’ as defined in Regulation 1 means the ballast in a tank which since
oil was last carried therein has been so cleaned, that effluent therefrom, if it were
discharged from a ship which is stationary, into clean calm water on a clear day,
would not produce visible traces of oil on the surface of the water or on adjacent
shorelines or cause a sludge or emulsion to be deposited beneath the surface
of the water or upon adjoining shorelines. If the ballast is discharged through an
oil discharge and monitoring and control system approved by the administration,
evidence based on such a system to the effect that the oil content of the effluent
did not exceed 15ppm, shall be determinative that the ballast was clean,
notwithstanding the presence of visible traces.
Any tanker is allowed under MARPOL to discharge clean ballast anywhere, ports
and Special Areas included, under the following conditions:
a Before discharging from SBTs, the surface of the ballast water should be
inspected for possible signs of oil
b While discharging other clean ballast the oil discharge monitoring or control
system should be used to make sure that the oil content is not greater than
15ppm. Monitoring is compulsory in ships using CBT and LoT; and
c While discharging clean ballast, the sea surface should be inspected for
possible signs of oil
Single hull tanker phase out
The rules that apply to the discharge of clean ballast exist principally to meet the
pollution prevention requirements of single hull tankers. However these rules are
becoming less significant as the IMO has adopted a global timetable to phase out
tankers of this design.
The reason is summarised below:
In April 2001, an amendment to Annex I divided tankers into three categories
2 : EXISTING REGULATIONS
15
(Categories 1, 2 and 3) for purposes of establishing phase-out dates of single hull
tankers depending on their delivery date. The phase-out timetable sets 2015 as the
principal cut-off date for all single hull tankers. A Condition Assessment Scheme
(CAS) was applied to all Category 1 vessels continuing to trade after 2005 and all
Category 2 vessels after 2010. The CAS stipulates more stringent verification of the
reported structural condition of the ship.
However, in December 2003, new amendments to Annex I were adopted that
brought forward the phase-out schedule for existing single hull tankers. Accordingly,
all Category 1 single hull tankers were prohibited from trading after 2005. Category
2 oil tankers, which have some level of protection from protectively located
Segregated Ballast Tank requirements, were given the year 2010 as cut-off date.
The year 2010 is also the final cut-off date for Category 3 oil tankers (which are
generally smaller tankers in the range 5,000 - 20,000 dwt).
An exemption, however, is allowed:
The 2003 revision allows an Administration (i.e. the flag State) to permit continued
operation of Category 2 or 3 tankers beyond their phase-out date (subject to
satisfactory CAS), but the continued operation must not go beyond the anniversary
date of the ship in 2015 or the date on which the ship reaches 25 years of age,
whichever is earlier.
Clean Ballast Tank operation, a feature in non-SBT ships, has become unnecessary
in newer vessels. In future, the situation of extremely heavy weather, where water
ballast is taken into oil-contaminated cargo tanks, will probably be the most likely
occasion when onboard processing of oily ballast water becomes necessary, or a
reception facility is needed for disposal ashore.
2.4 / DISPOSAL OF SEWAGE
Annex IV of MARPOL deals with sewage but a number of countries, e.g. the USA,
have more stringent regulations governing the discharge of sewage into their
territorial waters.
Sewage means:
* Drainage and other wastes from any form of toilets and urinals
* Drainage from medical premises (dispensary, sick bays, etc.) via wash basins,
2 : EXISTING REGULATIONS
16
wash tubs and scuppers located in such premises
* Drainage from spaces containing living animals, or
* Other waste waters when mixed with the drainage defined above
Every ship required to comply must be subject to surveys, as specified below, to
ensure:
a When the ship is fitted with a sewage treatment plant, it shall meet operational
requirements based on standards and test methods developed by the
Organisation
b When the ship is fitted with a system to comminute and disinfect the sewage,
it shall be of a type approved by the Administration. Such system shall be fitted
with facilities, to the satisfaction of the Administration, for the temporary storage
of sewage when the ship is less than 3 nautical miles from the nearest land
c When the ship is equipped with a holding tank, it shall have a capacity to the
satisfaction of the Administration for retention of all sewage having regard to
the operation of the ship, the number of persons onboard, and other relevant
factors. The holding tank shall have a means to indicate visually the amount of
its contents; and
d That the ship is equipped with a pipeline leading to the exterior for the discharge
of sewage to a reception facility and that such a pipeline is fitted with a standard
shore connection in compliance with Regulation 10 of this Annex
The discharge of sewage is prohibited, except when
a The ship is discharging comminuted and disinfected sewage using a system in
accordance with the above at a distance of more than 4 nautical miles from the
nearest land, or sewage which is not comminuted or disinfected at a distance
of more than 12 nautical miles from nearest land, provided that in any case the
sewage which has been stored 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 Organisation; or
b The ship has in operation an approved sewage treatment plant to meet the
requirements referred to above, and
(i) The test results are laid down in the ship’s International Sewage Pollution
Prevention Certificate (1973);
2 : EXISTING REGULATIONS
17
(ii) Additionally, the effluent shall not produce visible floating solids in, nor
cause discoloration of, the surrounding water; or
c The ship is situated in the waters under the jurisdiction of a State and is
discharging sewage in accordance with such less stringent requirements as
may be imposed by such State
When the sewage is mixed with water or with waste water having different
discharge requirements, the more stringent requirements shall apply.
Reception Facilities
Where ships are prohibited from discharging into a State’s waters, then the
Government of the State concerned should ensure the provision of adequate
facilities at ports and terminals for the reception of sewage or waste without
causing any delay (Regulation 12). In some areas, however, provision remains poor.
IMO continues to press for improvement in provision and operation of such facilities
but it will be some while before all ports achieve the same standards. With regard
to Special Areas, adequate provision is integral with Special Area Status.
To further assist with the provision by others of adequate facilities, IMO published
the comprehensive Manual on Port Reception Facilities (1999 Edition) which
covers, amongst other things, the legal background; waste management; strategy
development; national implementation; the planning of facilities; choice of location;
types and quantities of ship generated wastes; recycling; options for final disposal;
financing and cost recovery, coordination of port and ship requirements; and
options for enforcement and control.
Ship’s captains should be aware that they can report any inadequacies they find in
shore reception facilities.
2.5 / DISPOSAL OF GARBAGE
Annex V of MARPOL requires ships over 400 GT, or certified to carry 15 or more
persons, to operate a Garbage Management Plan (that outlines how the ship
will collect and separate the waste), and have a designated garbage officer who
implements the plan and keeps and maintains a Garbage Record Book (which
details the discharge or incineration of waste at sea and in port). An example of
2 : EXISTING REGULATIONS
18
such a record can be seen in Appendix 4.3. The records in the book should be kept
for a minimum of two years from the date of the last entry.
The Garbage Record Book details how six different categories are discharged at
sea or ashore. The categories are:
Category 1: Plastics
Category 2: Floating dunnage, lining or packing material
Category 3: Ground-down paper products, rags, glass, metal, bottles, crockery, etc.
Category 4: Cargo residues, paper products, rags, glass, metal, bottles, crockery, etc.
Category 5: Food wastes
Category 6: Incinerator ash except from plastic products which may contain toxic or
heavy metal residues.
Residual water from cargo holds may be discharged during a voyage if it goes
through a fixed line and the quantities are recorded in the Garbage Record Book.
Examining Port State Inspectors often check the record books and inaccurate
statements can lead to prosecution. Passenger ships should consider carrying
placards on board informing passengers and crew that throwing garbage into the
sea is prohibited.
Note that keeping garbage on-board may create a fire risk. The storage area should
be equipped to the appropriate fire protection standards of SOLAS Chapter II-2.
Generally, garbage should be separated when it is collected according to how it is
to be disposed of. Many ships have different types of containers.
* One for food wastes
* One for other biodegradable garbage such as paper and wood
* One for plastics and mixed plastic and non-plastic non-biodegradable or
recyclable wastes
* Bins for recyclable wastes such as glass, steel cans, aluminium cans etc.
Most ships colour code these bins to make them easier to find and recognise.
Special equipment is used to reduce the volume of garbage, either for easier
storage or for disposal. The main types of processing are:
a Comminution: a comminutor pulps or grinds food and other wastes for disposal
or incineration. Pre-treatment using a comminutor is recommended for any food
2 : EXISTING REGULATIONS
19
waste to be disposed of at sea, and is essential for any food wastes which are
intended to be disposed of between 3 and 12 nautical miles from land.
b Compaction: a compactor (or baler) compresses waste into blocks which take
up less space. They are particularly good for reprocessing ‘recyclables’ ready
for disposal at on-shore reception facilities.
c Incineration: an incinerator reduces waste to ash, which is not only easier to
handle and store but is more hygienic. Incineration is the commonest method of
processing waste on board; however ash from the incinerator is not necessarily
safe to dump at sea. Ash from plastics contains toxins and it must be stored
for disposal at an on-shore reception facility. Some countries restrict the use of
incinerators in port because of the risk of atmospheric pollution.
Disposal of garbage within Special Areas: Regulation 5
The Special Areas designated under Annex V of MARPOL are the Mediterranean
Sea area, the Baltic Sea area, the Black Sea area, the Red Sea area, the Gulfs
area, the North Sea area, the Antarctic area, and the Wider Caribbean Region (for
the last named region, the regulations come into force on 1 May 2011). These are
defined under Regulation 5 of Annex V. As for Annex I, Regulation 1 of Annex V
defines ‘nearest land’ in general and includes the specification relating to the Great
Barrier Reef region of north-eastern Australia.
a Disposal into the sea of the following is prohibited:
(i) all plastics including, but not limited to, synthetic ropes, synthetic fishing
nets, plastic garbage bags and incinerator ashes from plastic products
which may contain toxic or heavy metal residues
(ii) all other garbage including paper products, rags, glass, metal, bottles,
crockery, dunnage, lining or packing materials
b Disposal into the sea of food wastes shall be made, as far as is practicable from
land, but in any case not less than 12 nautical miles from the nearest land
c Disposal into the Wider Caribbean Region of food wastes which have passed
through a comminuter or grinder shall be made as far as is practicable from
land but in any case, not less than 3 nautical miles from nearest land. Such
contaminated or ground food wastes shall be capable of passing through a
screen with openings no greater than 25mm
2 : EXISTING REGULATIONS
20 21
Disposal of garbage outside Special Areas: Regulation 3 such platforms.

a Disposal into the sea of all plastics, including but not limited to synthetic ropes,
synthetic fishing nets, plastic garbage bags and incinerator ashes from plastic
products which may contain toxic or heavy metal residues, is prohibited
b Disposal into the sea of the following garbage shall be made as far as
practicable from the nearest land, but in any case is prohibited if the distance
from land is less than:
(i) 25 nautical miles for dunnage, lining or packing materials which float
(ii) 12 nautical miles for food wastes and all other garbage including paper
products, rags, glass metal, bottles, crockery, and similar refuse
c Disposal into the sea of garbage specified in b (ii) above may be permitted when
it has passed through a comminuter or grinder and made as far as practical
from nearest land, but in any case is prohibited, if the distance from the nearest
land is less than 3 nautical miles. Such comminuted or ground waste shall be
capable of passing through a screen with openings no greater than 25mm
When garbage is mixed with other discharges having different disposal or
discharge requirements, the more stringent requirements shall apply.
TIME TAKEN FOR OBJECTS TO DISSOLVE AT SEA
Paper bus ticket 2-4 weeks
Cotton cloth 1-5 months
Rope 3-14 months
Woollen cloth 1 year
Painted wood 13 years
Tin can 100 years
Aluminium can 200-500 years
Plastic bottle 450 years
Source: Hellenic Marine Environment Protection Association (HELMEPA)
Special requirements: Regulation 4
a Disposal of any materials regulated by Annex V is prohibited for fixed or floating
platforms engaged in exploration and associated offshore processing of seabed
mineral resources and from all other ships when alongside or within 500m of
b Disposal into the sea of food wastes may be permitted when they have been
passed through a comminuter or grinder from such fixed or floating platforms
located more than 12 nautical miles from land and all other ships when
alongside or within 500m of such platforms. Such comminuted or ground food
wastes shall be capable of passing through a screen with openings no greater
than 25mm.
Guidelines for implementation of Annex V
In addition to the seven regulations of Annex V, IMO has published guidelines
for the implementation of the Annex (2006 Edition). The main objectives of these
guidelines are to:
1 Assist governments in developing and enacting domestic laws which give force
to and implement Annex V
2 Assist vessel operators in complying with the requirements set forth in Annex V
and domestic laws; and
3 Assist port and terminal operators in assessing the need for, and providing
adequate reception facilities for, garbage generated on different types of ships
Part IV (Garbage) of the Organization’s guidelines on the Provision of Adequate Reception
Facilities in Ports, June 1978 has been modified and incorporated in the published
guidelines referred to here, in order to consolidate all Annex V related guidelines.
In addition, a form for reporting alleged inadequacy of port reception facilities for
garbage is provided as an appendix to the guidelines.
Again, in 1992, IMO published as Appendix 2, a standard specification for
shipboard incinerators including materials of manufacture, operating controls,
documentation, tests certification, marking and quality assurance, and including
annexes on emission standards, fire protection, head recovery, flue gas
temperatures and a form of IMO type approval certificate for incinerator with
capacities up to 1160 kW.
Onboard incineration is an efficient means of disposing of solid waste and sludge
oil. In 1997 IMO adopted MARPOL Annex VI on the prevention of air pollution from
ships. This Annex became the focal point for regulation of atmospheric emissions
from shipboard incinerators. Accordingly, shipboard incinerators installed on or after

2 : EXISTING REGULATIONS 2 : EXISTING REGULATIONS

22 23
1 January 2000 must have an IMO type approval certificate showing compliance (iii) 0.50% m/m on and after 1 January 2020
with MEPC Resolution 76(40). To obtain this certificate the incinerator must be
IMO is called upon to monitor the worldwide average sulphur content of residual
designed and built to an approved standard. Each model must be subject to a
fuel oil with a view to possible future revisions of these figures.
specified type approval test operation at the factory or an approved test facility. The
make up of solid waste to be used in the approval test is clearly specified. While ships are operating within an Emission Control Area, the sulphur content of
Details of the Annex VI regulations covering operational aspects of shipboard fuel shall not exceed the following limits:
incineration may be found in the booklet that accompanies Videotel’s production (i) 1.50% m/m prior to 1 July 2010
“MARPOL Annex VI - Prevention of Air Pollution from Ships” Edition 2. Information (ii) 1.00% m/m on and after 1 July 2010
on some other aspects of MARPOL Annex VI may be found in Section 2.6. (iii) 0.10% m/m on and after 1 January 2015.

Spoilt cargo There is a requirement under MARPOL Annex VI for a sample to be taken during
bunkering for verification that sulphur content is within allowable limits. The aim of
While MARPOL covers waste derived from stowage and handling of cargo, and sampling is to obtain four representative samples which are a record of the quality
cargo residues resulting from loading and unloading (e.g. spillage), it does not of fuel delivered to the ship. The four samples are for:
cover “spoilt cargo”. However, the London Convention and Protocol (LC - LP) on
the prevention of pollution by dumping of waste at sea does regulate this, assuming * The ship’s own reference
that dumping the spoilt cargo overboard might be considered. A joint London * The supplier
Convention/IMO MEPC working group drafted a document entitled “Guidance on * Laboratory analysis
Managing Spoilt Cargo”, which was formally adopted by IMO’s Marine Environment * MARPOL compliance
Protection Committee (MEPC) in July 2009. This document is an important source
To be ‘representative’, the samples should be taken throughout the delivery, not at
of information in dealing with spoilt cargo. It also suggests that the shipowner or
the beginning or end. The MARPOL sample, which has a special label, must be at
operator considers developing contingency plans for managing spoilt cargo to help
least 400ml.
timely decision making by regulatory authorities in the port State or flag State, so
minimising possible delays to a ship. The Bunker Delivery Note (BDN)

The BDN is a record of the fuel delivered and copies are kept by the supplier and
2.6 / AIR POLLUTION receiving ship. Appendix V to Regulation 18 of MARPOL requires that the BDN
includes the following information:
Annex VI on Regulations for the Prevention of Air Pollution from Ships entered
into force on 18 May 2005. It sets limits on sulphur oxide and nitrogen oxide * Name and IMO Number of receiving ship
emissions from ship exhausts and prohibits deliberate emissions of ozone depleting * Port
substances. In October 2008 a revised Annex VI was adopted by IMO with entry * Date of commencement of delivery
into force set for 1 July 2010. * Name, address and telephone number of marine fuel oil supplier
The Annex sets out progressive limits on the sulphur content of fuel oil as follows: * Product name(s)
* Quantity in metric tons
(i) 4.5% m/m prior to 1 January 2012
(ii) 3.50% m/m on and after 1 January 2012 * Density at 15°C, kg/m3

2 : EXISTING REGULATIONS 2 : EXISTING REGULATIONS

24 25
* Sulphur content (% m/m) contaminated packaging materials and polychlorinated biphenyls (PCBs), and
restricts incineration of polyvinyl chlorides (PVCs) to shipboard incinerators for
There must also be a declaration signed and certified by the fuel oil supplier’s
which IMO Type Approval certificates have been issued.
representative that the fuel oil supplied is in conformity with MARPOL Annex VI
Regulation 14(1) or (4)(a) and Regulation 18(1). The Annex also has provisions for controlling the emissions of volatile organic
compounds (VOCs) from tankers in ports or terminals under the jurisdiction of a
The figures should be agreed by the barge Master and the Chief Engineer, signed
Party to Annex VI.
and countersigned on the BDN. The BDN must be signed regardless of whether
the receiving ship is satisfied that the quantity of fuel oil received is the same as had
been ordered. The letter of protest is the means of recording dissatisfaction with a
2.7 / ANTI-FOULING PAINT CONTROL
short delivery.
Anti-fouling reduces the drag of a vessel through the water and, consequently,
The BDN should be kept in an available place for three years, and shown to Port
helps reduce fuel consumption. Without some form of protection, algae and
State Control officers who request it.
crustaceans would grow on the hull, affecting efficiency. speed and manoeuvrability.
In the past, tributyltin (TBT) was a base component in commonly used, self-
Ozone depleting substances
polishing copolymer (SPC) paint systems. Unfortunately TBT is an extremely
The Annex prohibits the deliberate emissions of ozone depleting substances, poisonous toxin that remains in the sea for some time, causing harm to other
(ODS), which include halons and chlorofluorocarbons (CFCs). New installations organisms.
containing ozone-depleting substances are prohibited on all ships but new
In 2001, IMO adopted the International Convention on the Control of Harmful
installations containing hydro-chlorofluorocarbons (HCFCs) are permitted until 1
Anti-fouling Systems (the AFS Convention 2001), phasing out anti-fouling systems
January 2020.
using organotin compounds, like TBT. This Convention entered into force on 17
Ships that have rechargeable systems that contain ODS must maintain an ODS September 2008.
Record Book which may form part of an existing log book or electronic recording
system approved by the Administration. Entries in terms of mass (kg) must be
completed in respect of: 2.8 / BALLAST WATER

(i) recharge, full or partial, of equipment containing ODS The problems encountered by several nations following the accidental introduction
(ii) repair or maintenance of such equipment of ‘foreign’ species of marine plants, animals and pathogens through discharged
(iii) discharge of ODS to the atmosphere, both deliberate and non-deliberate ballast water, has led the IMO to adopt the International Convention for the Control
(iv) discharge of ODS to land based reception facilities and Management of Ships’ Ballast Water and Sediments (BWM Convention). At
(v) supply of ODS to the ship the time of writing, this has not yet received enough ratifications from governments,
but a concentrated effort on widening support for the Convention and developing
Annex VI also sets limits on emissions of nitrogen oxides (NOx) from diesel engines the necessary technology should shortly bring it into force. Current procedures
and a mandatory Technical Code has been developed which defines how this shall agreed for ballast water to be exchanged at sea or discharged to a port reception
be done. facility remain valid and each ship should have a Ballast Water Management Plan; a
Annex VI contains detailed provisions on shipboard incineration (Regulation person responsible for developing and operating it and records which demonstrate,
16). The Annex prohibits the incineration onboard of certain products such as if required, that the plan has been implemented. However, ships constructed from

2 : EXISTING REGULATIONS 2 : EXISTING REGULATIONS

26
2010 onwards must be equipped with technologies that will enable them to meet
the standards for ballast water management established by the Convention. These
systems aim to treat ballast water to render it harmless so that it can safely be
discharged in coastal waters.
Although the Convention defines acceptable limits, you should be aware that
various regional authorities such as certain US states are demanding far more
rigorous standards for vessels entering their waters.
2.9 / SHIP RECYCLING
Following widespread concern about the environmental and safety aspects of ship
scrapping in some parts of the world, a new International Convention for the Safe
and Environmentally Sound Recycling of Ships was adopted by the IMO in Hong
Kong in May 2009. This defines “new” and “existing” ships for the purposes of
implementing the Convention. One consequence of this Convention is that ship
owners and operators are required to document the life cycle and history of the
vessel with particular reference to the materials used in its structure and equipment,
and to prepare an Inventory of Hazardous Materials (IHM) that may also include
cargo residues and any other substances on board at the time the ship is sent for
recycling. The items to be listed in the IHM are shown in Appendix 4.5.
2 : EXISTING REGULATIONS
27
3 : TRAINING TO PREVENT POLLUTION
3.1 / OIL-WATER AND OIL DISCHARGES
The MARPOL Annex I Regulations are designed to minimise the discharge of oil
from clearly identified sources, i.e. from tank cleaning operations and from
deballasting; or from the discharge of bilge water. These are situations where it is
normal practice to mix oil and water, as in tank washing, or to find oil mixed with
water as in machinery space bilges. The quantity of unwanted oil should be
predictable and manageable by agreed procedures and the installed equipment.
The procedures and appropriate equipment have been developed to ensure that the
discharge limits set for all these processes can be met so that the oil content in the
discharge water is minimised at all times.
Of course oil can escape from its normal containment by accident or through low
grade leakage of the type thought acceptable for operating machinery, rather than
by being intentionally mixed with water. Such accidental releases of oil are
comparatively unpredictable and difficult to handle. Every effort must be made to
ensure that such releases are as small and as infrequent as possible.
Potential discharges of oil above regulation limits can occur due to inadequate
separation of oil and water, as may happen in tank cleaning and bilge emptying
operations. However, it is when loading or unloading cargo and during bunker
loading that the most dramatic consequences of oil spills can occur. Such spills
could vary in size and occur in a wide range of locations with considerable
environmental impact.
So training must have two objectives. First, we need to ensure that the procedures
and the equipment required for compliance with MARPOL regulations are fully
understood and efficiently operated.
Second, we need to ensure that:
* All sources and locations for possible accidents, sudden malfunctions, and the
scope for human error are identified
3 : TRAINING TO PREVENT POLLUTION
28 29
* The scale and frequency of any release of oil from safe containment is quantified • the relevant discharge requirements
as far as possible • the ancillary equipment associated with compliance
* Methods of avoidance and response are developed • operations which can cause oil discharges
• the means of response to oil discharges both onboard the ship and external
All of these factors must be built into the training scheme. The contents of such a
to the ship
scheme are now dealt with under the following headings:
1 General requirements Provision of:

2 Compliance with MARPOL Regulations • instruction on the above

• demonstration of all aspects under operational conditions
3 Avoiding accidental oil spills
• supervision and monitoring of all aspects of crew performance
4 Response to accidental oil spills:
• onboard ship Relevant training materials include:
• external to ship • the accompanying video
• this workbook
IMO recognises that many ships operate with comprehensive and effective
• special briefing documentation
emergency plans such as the Shipboard Oil Pollution Emergency Plan (SOPEP).
• operation manuals
Nonetheless, in 1996, IMO produced Guidelines for a Structure of an Integrated
• permanently posted instructions
System of Contingency Planning for Shipboard Emergencies for the attention of
• checklists for all equipment operations and for all procedures
maritime administrators and relevant industry organisations. Reference should be
made to such documentation in preparing operational and training materials for
shipboard use.
3.3 / COMPLIANCE WITH MARPOL REGULATIONS

The evidence suggests that operational oil pollution from ships has been reduced
3.2 / GENERAL REQUIREMENTS through compliance with MARPOL Annex I Regulations covering tank cleaning and
ballasting operations including LOT and Crude Oil Washing (COW), SBT and CBT;
Every ship has her own individual characteristics, nature of trade, range of
the use of oil water separation for oily bilge water; and oil content monitoring and
equipment and degree of crew experience. A realistic training programme will cover
control systems in general. More recently the IMO requirement for double hulls in
all aspects of the ship and her operations in regard to oil and garbage, and have
new tanker builds has meant that segregated ballast is held in the double hull spaces.
regard to the trainees’ personal duties and responsibilities.
Annex V Regulations are expected to have similar and increasing beneficial effects,
General training requirements should include:
though much of the Annex V related text is contained in guidelines rather than in the
Awareness of: regulations as such. The guidelines for implementation of the Annex state:
• the importance of pollution prevention
• the ways in which pollution can arise Although Annex V permits the discharge of a range of garbage into the
• the means of pollution avoidance sea, it is recommended that wherever practicable, ships use as a primary
means, port reception facilities.
Familiarisation with:
• operations likely to cause pollution So the preferred position is one of zero discharge to the sea.

3 : TRAINING TO PREVENT POLLUTION 3 : TRAINING TO PREVENT POLLUTION

30
Clearly the reduction of marine pollution through compliance with these Annexes,
requires the knowledge and cooperation of seafarers. This, in turn, requires ship
owners and managers to train and motivate their crews.
This training will depend on ship type and mode of operation, and may include:
Uptake of ballast water into uncleaned tanks in port:
• avoidance of backflow of oil to the sea
• drainage of pipelines to remove static head
• correct sequence for opening sea valves and pump start-up
Tank cleaning procedures:
• cleaning by use of sea water
• preliminary tank cleaning by COW. Subsequent final tank cleaning by water
washing at sea
• maintenance of inert atmospheres during COW operations
• maintenance of SBT and operations for maintenance of the CBT option
Discharge of settled/gravity separated tank cleaning water at sea:
• care to be exercised in approach of oil/water interface to the discharge
pump’s inlet in final stages of water discharge
• observation of sea surface/use of interface detectors
• transfer of separated oil and interface water to the slop tank
Discharge of “clean” ballast water:
• inspection of surface of ballast prior to discharge
• observation of sea surface
• attention to oil content and control equipment
Specialised equipment associated with the above:
• tank washing machines
• monitoring and control equipment
• pumps, pipelines, etc.
Operation of oil/water separators for bilge waters:
• care and maintenance of gravity separator
• care, maintenance and use of associated oil content monitoring equipment
• replacement schedule for coalescers and filter units
3 : TRAINING TO PREVENT POLLUTION
31
Garbage procedures and arrangements:
• consideration of purchasing options to minimise garbage arising, e.g. less
packaging
• segregation of garbage
• storage of garbage
• disposal of garbage, preferably to shore reception
• use of a garbage record book
Operation of garbage related equipment:
• maintenance of grinders, comminuters, compactors and incinerators
• avoidance of damage to comminuters, compactors and grinders by
introduction of extraneous materials with which they are not designed to deal
• ensuring incinerators are operated at their optimum temperatures
3.4 / AVOIDING ACCIDENTAL OIL SPILLS
MARPOL Annex I deals with minimising oil discharge to the sea in situations when it
becomes mixed with water during normal ship operations. Thus oil may be mixed
with ballast water through use of cargo tanks for the carriage of such ballast, or
through discharge or leakage from machinery into bilge waters. The Annex also
deals with SBT and CBT operations as an alternative means of avoiding the
deliberate contacting of oil and water in the first place; and with COW as an
intermediate stage in tank cleaning whereby most of the residue is re-dissolved in
the cargo and unloaded with it to shore. In addition, it deals with ship construction
aspects of tank size, double hulls and double bottoms to minimise oil release in
conditions of hull damage.
The Annex does not specifically deal with avoiding accidental release of oil from safe
containment, during cargo loading and unloading, or during bunker loading
operations. Here, recourse is to industry standards, port regulations, and the need
for ships to comply with these additional requirements.
Again, training and motivation are essential. Training under this heading should
include:
Compliance with all industry standards and port regulations for:
• safe mooring
3 : TRAINING TO PREVENT POLLUTION
32
• loading/unloading procedures
• tank loading sequence and delivery rates
• tank topping-off procedures
• final tank topping-off procedure
• emergency stop arrangements
Establishment of ship/shore operational agreements for all of the above.
Onboard equipment checks to ensure full operational state and availability of:
• the cargo handling system
• the bunker handling system
• loading arms
• manifold
• associated pumps, valves, pipelines, couplings, and blanks
• vents and overflow systems
Onboard procedure checks to ensure that all equipment will be properly used:
• ensuring pressure testing of delivery lines
• availability of cargo handling checklists
• availability of bunker handling checklists
• ensuring all couplings are properly made up
• ensuring blank flanges are completely secure – no missing nuts and bolts
• ensuring that ullages can, and will be, checked
3.5 / RESPONSE TO ACCIDENTAL OIL SPILLS
The previous sections dealt with minimising the oil content of water discharges
through compliance with MARPOL regulations, and avoiding oil spills through good
operational practice according to industry standards. Now let’s consider the actions
to be taken when oil does escape from safe containment. This section deals also
with action onboard and, if pollution arises external to the ship, with the necessary
reporting procedures.
Training here should include:
The need to arrange for back-up provisions in case of unwanted release of oil:
• positioning of drip trays
• checking for holes/cracks in gutter bars
3 : TRAINING TO PREVENT POLLUTION
33
• plugging of scuppers
The need to ensure that such first line defences are not overwhelmed:
• maintain an efficient deck watch during all cargo and bunker operations
• ensure that dump valves, from drip trays, into slop tanks (if fitted) can be
easily opened
The need to ensure that on-deck spillage can be cleaned up by:
• emergency pumping capacity
• adequate supplies of absorbent materials
• storage for oil soaked absorbents
If oil escapes from the ship
Provided any escape of oil can be retained and dealt with onboard by the means
discussed earlier, there will be no effect external to the ship. If, however, oil
escapes to the sea either directly from the transfer area or as overspill from the
deck, because onboard back-up is overwhelmed, or from inappropriate use of sea
valves in ballasting, the incident should be reported to the relevant authorities.
Oil releases may also occur from collision damage to tanks but that aspect is
outside the scope of this training package.
Training in the reporting of spills should emphasise the need to have the following
contact details readily available:
• terminal representative
• ship’s agent
• port authorities
• US National Response Centre (NRC) and the US Coastguard Marine Safety
Office when trading in the USA
• reporting requirements specific to other national administrations, as
appropriate
3.6 / SOME ADDITIONAL POINTS
The training topics outlined above, together with the accompanying video and the
checklists in the appendices to this workbook, provide a good basis for the creation
and delivery of an onboard training scheme for ships’ crews. Here, we will look
3 : TRAINING TO PREVENT POLLUTION
34
again at a number of the points mentioned earlier because of their importance as
sources of unwanted oil release.
Experience has shown that pollution incidents have often been caused by leaking
cargo line dresser couplings, valve flanges, faulty pressure gauge connections, and
other parts of the main cargo piping system on deck. External or internal pipe
corrosion, in particular at the bottom of the cargo pipes, often proceeds without
being detected. So regular and frequent hydrostatic pressure tests should be
carried out at maximum working pressure. The test pressure used and the results
obtained should be logged. COW lines should be tested prior to arrival in port if
COW operations are to be carried out there.
The test pressure to be used is the pressure to which the pump relief valve is set. If
there is no relief valve, then the highest pressure attainable by the pump in service
should be used. It should be applied for 15 to 30 minutes and thrust stoppers in the
way of expansion joints and dresser couplings should be checked after the test.
Another cause of pollution incidents is simply by continuing to deliver oil to a tank
after it is full. Careful topping-off procedures to avoid tank overflows are essential.
The draining of pipelines, secure blanking off at the end of oil deliveries and pump
start-up before opening a sea valve to the sea in ballasting, are all essential to avoid
unwanted release of oil to the external environment.
35
• identification of responsible and operational personnel
• topping-off details
• emergency shut-down procedures
They should also provide details of the pipeline systems to which they refer.
Checklists are a very convenient means of ensuring that all relevant points are
noted in preparing for and conducting any particular operation involving oil in bulk,
in order to avoid its escape from safe containment. The use of checklists is only
an aid to safe working, however. They do not do the job for the operator. It is all
too easy simply to check-off items on the list in a semi-conscious way. This can
result in the checklist itself becoming the cause of accidents. Operators must fully
understand the function of each item on the list and its interaction with other items;
and they must remain vigilant and active in carrying out the operation according to
the aide memoire which the list provides.
With this warning in mind, the checklist included in the Appendices is
recommended as a guide in the development of operational procedures on board
your ship. Operators should also fully appreciate and understand the design and
function of the bunker transfer pipeline system which they are operating. This is
best achieved by reference to diagrams which must of course be freely and readily
available.

Finally, it is essential to ensure a clear chain of command for all operations, clear
instruction and a fully trained crew - that is one which understands the need for, and
the function of, all steps and actions taken. While checklists are necessary, you
must avoid simply ticking-off the entries without actually carrying out each identified
action on the list. This can only be achieved through concentration and
understanding and both require leadership and motivation for success.

3.7 / PROCEDURE FORMS AND OPERATIONAL CHECKLISTS

Procedure Forms provide a convenient means of focusing in an operational manner

on the points covered earlier in this booklet. They summarise information on:
• the provision of drip trays
• spillage response techniques
• equipment for on-deck spillage response

3 : TRAINING TO PREVENT POLLUTION 3 : TRAINING TO PREVENT POLLUTION

36
4 : APPENDICES
4.1 / BUNKERING OPERATIONS CHECKLISTS
With thanks to West of England P&I
This shows the detail necessary to ensure onboard and overboard spillage is
avoided.
Initial Preparation
* Ensure all personnel are aware of intention to bunker and emergency response
procedures
* Discuss bunkering plan and tank sequence with officers involved
* Close and secure all associated overboard discharge valves
* Close and blank off all unnecessary manifold valves/connections
* Plug all deck scuppers and make oil/watertight
* Empty out and plug save-alls
* Place oil absorbent materials in key locations
* Provide means of draining off any accumulations of water on deck
* Establish common communication link between bunkering station, duty officer
and engine room
* Check all bunker tank air pipes are open and unblocked
* Ensure all sounding pipe caps are tight, except when sounding tank
* Reconfirm space remaining in all bunker tanks to be filled
* Check all bunker tank high level alarms are functioning
* Ensure all fire precautions are observed
Prior to Bunkering
* Check hose is of sufficient length
* Inspect hose and couplings for damage
* Check weight of hose does not exceed SWL (Safe Working Load) of vessel’s
lifting gear
* Place drip trays under hose couplings and flanges
4 : APPENDICES
37
* Check delivery note quantity and specification are correct
* Discuss bunkering plan with supplier
* Discuss vessel’s emergency response procedures with supplier
* Discuss supplier’s own emergency response procedures
* Establish communication link between vessel and supplier
* Agree signalling system with supplier
* Commence pumping
* Reduce pumping rate
* Cease pumping
* Emergency stop
* Agree with supplier the quantity of oil to be pumped aboard
* Agree unit of measurement (metric tonnes, cubic metres, barrels etc)
* Agree maximum pumping rate and pressure
* Carry out spot analysis with vessel’s fuel test kit (if carried)
* Conduct compatibility test, if necessary
* Sight, agree and record shore/barge meter readings
* Appoint seaman to tend mooring lines during bunkering
* Rig fire wires fore and aft (if applicable)
* Ensure designated overflow tank is prepared
* Prepare filling line and open all relevant valves
During Bunkering
* Commence bunkering at minimum pumping rate
* Monitor supply line pressure
* Examine hose connections for leakage
* Reduce pumping rate/open next tank before topping up
* Close valves as each tank is completed
* Witness, date, jointly countersign and retain sealed bunker samples
* Ensure sufficient ullage* in final tank for hose draining/line blowing
* Notify supplier when final tank is reached
* Give suppliers timely warning to stop pumping
* Drain hoses on completion of bunkering and close all filling valves
4 : APPENDICES
38 39
* ullage = the distance between the top of the oil and the top of the tank 4.3 / GARBAGE RECORD BOOK

Completion of Bunkering RECORD OF GARBAGE DISCHARGES

* Ensure all hoses are fully drained Ship’s name: ____________________ Distinctive No. or letters __________ IMO No. __________
Garbage category:
* Close and blank off manifold connection
1 Plastic
* Blank off disconnected hose couplings 2 Floating dunnage, lining or packing materials
* Reconfirm all bunker line and tank filling valves are secured 3 Ground paper products, rags, glass, metal, bottles, crockery etc
4 Paper products, rags, glass, metal, bottles, crockery etc
* Reconfirm all bunker tank soundings 5 Food waste
* Sight, agree and record shore/barge meter readings 6 Incinerator ash except from plastic products which may contain toxic or heavy metal residues
* Verify all bunker receipt details are correct NOTE:THE DISCHARGE OF ANY GARBAGE OTHER THAN FOOD WASTE IS PROHIBITED IN SPECIAL AREAS. ONLY GARBAGE
DISCHARGED INTO THE SEA MUST BE CATEGORIZED GARBAGE OTHER THAN CATEGORY 1 DISCHARGED TO RECEPTION
* Complete entry in oil record book FACILITIES NEED ONLY BE LISTED AS A TOTAL ESTIMATED AMOUNT. DISCHARGES OF CARGO RESIDUES REQUIRE START
AND STOP POSITIONS TO BE RECORDED.

DATE TIME POSITION OF THE SHIP ESTIMATED AMOUNT DISCHARGED ESTIMATED AMOUNT DISCHARGED ESTIMATED AMOUNT CERTIFICATION/
4.2 / BALLAST WATER REPORTING FORM INTO THE SEA (M3) TO RECEPTION FACILITIES OR INCINERATED (M3) SIGNATURE
TO OTHER SHIP (M3)
The version shown is recommended by IMO. Some countries, such as Australia, CAT 2 CAT 3 CAT 4 CAT 5 CAT 6 CAT 1 OTHER
have their own form and will not accept anyone else’s.

BALLAST WATER REPORTING FORM

(To be provided to the Port State Authority upon request)
1. SHIP INFORMATION 2. BALLAST WATER
Ship’s Name: Type: IMO Number: Specify Units: M3, MT, LT, ST
Owner: Gross Tonnage: Call Sign: Total Ballast Water on Board:
Flag: Arrival Date: Agent:
Last Port and Country: Arrival Port: Total Ballast Water Capacity:
Next Port and Country:

3. BALLAST WATER TANKS Ballast Water Management Plan on board? YES NO Management Plan Implemented? YES NO
Total number of ballast tanks on board: ___________ No. of tanks in ballast: ________ IF NONE IN BALLAST GO TO No. 5.
No. of tanks exchanged: No. of tanks exchanged:

4. BALLAST WATER HISTORY: RECORD ALL TANKS THAT WILL BE DEBALLASTED IN PORT STATE OF ARRIVAL; IF NONE GO TO 5.
Tanks/ BALLAST WATER EXCHANGE
Holds BALLAST WATER SOURCE
Circle one: Empty/Refill or Flow Through
BALLAST WATER DISCHARGE Master’s Signature: __________________________________________ Date: ____________
(List multiple
sources per tank Date Port or Volume Temp Date Endpoint Volume Sea Date Port or Volume Sallinity
separately) % Exch.
DDMMYY Lat/Long (units) (units) DDMMYY Lat/Long. (units) Hgt. (m) DDMMYY Lat/Long (units) (units)

P LE 4.4 / MARPOL ANNEX I AMENDMENTS

SAM
Ballast Water Tank Codes: Forepeak = FP, Aftpeak = AP; Double Bottom = DB; Wing = WT; Topside = TS; Cargo Hold = CH; Other = O
On 17 July 2009, IMO adopted amendments to MARPOL Annex I which better
IF EXCHANGES WERE NOT CONDUCTED, STATE OTHER CONTROL ACTION(S) TAKEN: ______________________________ defined “oily bilge water” and “oil residue (sludge)”. By setting out formal definitions
IF NONE STATE REASON WHY NOT: __________________________________________________________ of these substances in terms of the situations from which they derive, the
5. IMO BALLAST WATER GUIDELINES ON BOARD (RES. A.868(20))? YES NO
regulations concerning their subsequent onboard retention and, ultimately, transfer
RESPONSIBLE OFFICER’S NAME AND TITLE (PRINTED) AND SIGNATURE: ___________________________

4 : APPENDICES 4 : APPENDICES
40
or disposal have been greatly clarified.
New definitions
Oil residue (sludge) is defined as the residual oil products generated during the
normal operations of a ship, such as resulting from purification of fuel or lubricating
oil from main or auxiliary machinery, separated waste oil from oil filtering equipment,
waste oil collected from drip trays, and waste hydraulic and lubricating oils.
Oily bilge water is defined as water which may be contaminated by oil resulting
from things such as leakage or maintenance work in machinery spaces. Any liquid
entering the bilge system including bilge wells, bilge piping, tank top or bilge
holding tanks is considered oily bilge water.
Holding tanks
The amendments also define the onboard tanks required for storage of the above.
The oil residue (sludge) tank is defined as a tank which holds oil residue (sludge)
from which sludge may be disposed directly through the standard discharge
connection or any other approved method of disposal.
The oily bilge water holding tank is defined as a tank collecting oily bilge water prior
to its discharge, transfer or disposal.
Consequent changes
The regulations concerning a machinery space construction requirement for oil
residue (sludge) tanks has been extended to include the mandatory provision of a
designated pump for disposal that is capable of taking suction from such a tank.
Furthermore, these tanks must have no discharge connections to the bilge system,
oily bilge water holding tank, tank top or oily water separators. The exception to this
is the fitting of drains allowing settled water to be led to an oily bilge water holding
tank (with specified safeguards, such as self-closing valves) provided there is no
direct connection with the bilge piping system.
Other changes are:
Record of construction and equipment for ships other than oil tankers
The above described change to the machinery space construction requirements
4 : APPENDICES
41
has necessitated a number of minor amendments to Form A - Supplement to the
IOPP Certificate:
Section 3 of Form A on recording the means for retention and disposal of oil
residues (sludge) (regulation 12) and oily bilge water holding tank(s) now requires
the maximum capacity of an incinerator for oil residue (sludge) disposal to be
explicitly specified.
Note: Although the provision of bilge water holding tanks is not mandatory, Form A
sets out the recording format for ships having such tanks.
Oil Record Book: Part I - Machinery Space Operations
Minor changes have also been made to the list of items to be recorded, particularly
in the event that transfer of oil residue (sludge) between onboard tanks takes place.
There is a new heading (C) 11.4 “quantity of residue collected by manual operation
... metre cubed” with the annotation “operator initiated manual collections where oil
residue (sludge) is transferred into the oil residue (sludge) holding tanks”. Heading
(C)12 which records “method of disposal and quantity of oil residues disposed of”
has been amended so that “disposal” has been replaced by “transfer and disposal”
indicating that disposal by incineration or other methods, as well as between tanks,
also involves transfer as well as disposal.
Headings (D) and (E) on disposal of bilge water which has accumulated in
machinery spaces are similarly amended to include transfer as well as disposal.
Note: Section (J) of Oil Record Book: Part ii - Cargo/Ballast Operations - which
records “Disposal of residues and oily mixtures not otherwise dealt with” has also
been amended to reflect transfer as well as disposal, so that heading (J)57 now
reads “Method of transfer or disposal” and (J)57.3 is now as follows:
“transferred to or from (an) other tank(s) including transfer from
machinery space oil residue (sludge) and oily bilge water tanks
(identify tank(s): state quantity transferred and total quantity in tank(s),
in metres cubed)”
4 : APPENDICES
42 43
4.5 / INVENTORY OF HAZARDOUS MATERIALS TABLE C Potentially hazardous items
Inventory
APPENDIX 1 No. Properties Goods
Part I Part II Part III
ITEMS TO BE LISTED IN THE INVENTORY OF HAZARDOUS MATERIALS
C-1 Kerosene x
TABLE A Materials listed in appendix 1 of the Annex to the Convention C-2 White spirit x
Oiliness
Inventory C-3 Lubricating oil x
No. Materials Threshold
level C-4 Hydraulic oil x
Part I Part II Part III
C-5 Anti-seize compounds x
no threshold
A-1 Asbestos x C-6 Fuel additive x
level
C-7 Engine coolant additives x
no threshold
A-2 Polychlorinated biphenyls (PCBs) x C-8 Antifreeze fluids x
level
CFCs x C-9 Liquid Boiler and feed water treatment and test re-agents x
C-10 De-ioniser regenerating chemicals x
Halons x
C-11 Evaporater dosing and descaling acids x
Other fully halogenated CFCs x
C-12 Paint stabilizers/rust stabilizers x
Carbon tetrachloride x C-13 Solvents/thinners x
Ozone Depleting 1, 1, 1-Trichloroethane (Methyl chloroform) x no threshold
A-3 C-14 Paints x
Substances level
Hydrochlorofluorocarbons x C-15 Chemical refrigerants x
Hydrobromofluorocarbons x C-16 Battery electrolyte x
Methyl bromide x C-17 Alcohol, methylated spirits x
Bromochloromethane x C-18 Acetylene x
C-19 Explosives/ Propane x
Anti-fouling systems
2500 mg total C-20 inflammables Butane x
A-4 containing organotin x
compounds as biocide tn/kg C-21 Oxygen x
TABLE B Materials listed in appendix 2 of the Annex to the Convention C-22 CO2 x
Gas
C-23 Perflourocarbons (PFCs) x
Inventory C-24 Green House Methane x
No. Materials Threshold level Gases
Part I Part II Part III C-25 Hydrofluorocarbons (HFCs) x
B-1 Cadmium and cadmium compounds x 100 mg/kg C-27 Nitrous oxide (N2O) x
B-2 Hexavalent chromium and hexavalent chromium compounds x 1,000 mg/kg C-28 Sulfur hexaflouride (SF ) x
C-29 Bunkers fuel oil x
B-3 Lead and lead compounds x 1,000 mg/kg
C-30 Grease x
B-4 Mercury and mercury compounds x 1,000 mg/kg
C-31 Oiliness Waste oil (sludge) x
B-5 Polybrominated biphenyl (PBBs) x 1,000 mg/kg C-32 Bilge x
B-6 Polybrominated diphenyl ethers (PBDEs) x 1,000 mg/kg C-33 Liquid Oily liquid cargo tank residues x
B-7 Polychlorinated naphthalenes (more than 3 chlorine atoms) x no level threshold C-34 Ballast water x
B-8 Radioactive substances x no level threshold C-35 Raw sewage x
B-9 Certain shortchain chlorinated paraffins (Alkanes, C10-13, chloro) x 1% C-36 Treated sewage x
C-37 Non-oily liquid cargo residues x
* For materials in this Table with no threshold level, quantities occurring as unintentional trace contaminants should not be listed in Material
Explosibility/
C-38 Gas inflammability Fuel gas
Declarations and in the Inventory. x

4 : APPENDICES 4 : APPENDICES
44 45
TABLE C Potentially hazardous items 4.6 / FURTHER RESOURCES
Inventory
No. Properties Example Reading
Part I Part II Part III
C-39 Dry cargo residues x Ballast Water Management Convention and the Guidelines for its Implementation;
C-40 Medical waste/infectious waste x
IMO 2009
C-41 Incinerator ash2) x
C-42 Garbage2) x Clean Seas Guide for Oil Tankers; ICS/OCIMF 1994
C-43 Fuel tank residues x
C-45 Oily solid cargo tank residues x Guidelines for a Structure of an Integrated System of Contingency Planning for
C-45 Oily/contaminated rags x Shipboard Emergencies; IMO 1996
C-46 Batteries (incl. lead acid batteries) x
Guidelines for the Development of Shipboard Marine Pollution Emergency Plans,
C-47 Pesticides/insecticide sprays x
Solid Extinguishers x IMO 2010
C-48
Chemical cleaner (incl. electrical equipment Guidelines for the Implementation of Annex V of MARPOL (2006 Edition)
C-49 x
cleaner, carbon remover)
C-50 Detergent/bleacher (could be a liquid) x IMDG Code Supplement (2010 edition), IMO
C-51 Miscellaneous medicines x
C-52 Fire fighting clothing and equipment x International Safety Guide for Oil Tankers and Terminals; (5th Edition, 2006) IAPH/
C-53 Dry tank residues x ICS/OCIMF
C-54 Cargo residues x
Spare parts which contain materials listed in London Convention-London Protocol.1/Circular 30, dated 04/09/2009
C-55 x
Table A or Table B
Manual on Oil Spill Prevention, Vol I; IMO
2) Definition of garbage is identical to that in MARPOL Annex V. However, incinerator ash is classified separately MARPOL 73/78, Consolidated Edition, IMO 2006
because it may include hazardous substances or heavy metals.
Revised MARPOL – Annex VI – Regulations for the Prevention of Air Pollution from
TABLE D* Regular consumable goods potentially containing Hazardous Materials Ships 2008; (2009 Edition)
Inventory MARPOL, How To Do It; IMO 2002
No. Properties Goods
Part I Part II Part III
Port Reception Facilities, Comprehensive Manual on; IMO 1999
Computers, refrigerators, printers, scanners,
Domestic and television sets, radio sets, video cameras, video
D-1 accommodation x Prevention of Oil Spillages through Cargo Pumproom Sea Valves; ICS/OCIMF
recorders, telephones, consumer batteries,
appliances fluorescent lamps, filament bulbs, lamps

* This Table does not include ship specific equipment integral to ship operations, which has to be listed in Part 1 of the Inventory
Key to abbreviations:
IMO International Maritime Organization
ICS International Chamber of Shipping
OCIMF Oil Companies International Marine Forum
IAPH International Association of Ports and Harbours

4 : APPENDICES 4 : APPENDICES
46 47
Training Materials video/books/ CBT from Videotel
5 : ASSESSMENT QUESTIONS
Ballast Water Management (Code 698)

Dangerous Goods at Sea Series Edition 5:

Part 1 - The IMDG Code (Code 712) Which MARPOL Annex deals with Outside Special Areas, how many
Part 2 - Expecting the Unexpected (Code 713) garbage and waste disposal from nautical miles from the nearest
Environmental Officer Training Course (Code 864) ships? land can oil or oily mixtures be
a) I b) IV c) V d) VI discharged from an oil tanker?
Good Bunkering Practice Edition 2 (Code 962)
a) 15 b) 35 c) 50 d) 75
Holding Effective Drills (Code 706) Which of the following is NOT a
MARPOL Annex VI - Prevention of Air Pollution from Ships Edition 2 (Code 1119) ‘Special Area’ designated under According to HELMEPA, how
MARPOL 73/78 Annex I? many years does it take for a tin
Personal Survival at Sea (SOLAS) Series Edition 2:
a) The Mediterranean Sea Area can to disintegrate in the sea?
Part 1 - Mustering (Code 1114)
b) The Baltic Sea Area a) 1 month
Part 2 - Lifeboats (Code 1115)
Part 3 - Life Rafts (Code 1116) c) The Red Sea Area b) 1 year
Part 4 - Survival & Rescue (Code 1117) d) The Caribbean Sea Area c) 10 years

Prevention & Reaction to Marine Oil Spills Series Edition 2: e) The Black Sea Area d) 100 years
The Seafarer’s Role (Code 794)
Under OPA ’90 (Code 793) Vessels smaller than 400 GT can Which MARPOL Annex deals with
Under MARPOL (Code 792) discharge oil or oily mixture into the Regulations for the Prevention
the sea in the Antarctic area. of Pollution of oil?
Engine Room Waste Management Series:
True or False? a) Annex I
Oil Record Book (Code 964)
Oily Water & Separators (Code 963) b) Annex II
Sewage & Waste Water Treatment (Code 966) MARPOL Annex VI limits the c) Annex IV
Sludge & the Incinerator (Code 965) emissions into the atmosphere
d) Annex V
from ships of:
Ship Energy Efficiency Management Plan (Code 1121)
a) Nitrogen oxides Which MARPOL Annex deals with
Waste & Garbage Management (Code 627) b) Methyl bromide the Regulations for the Prevention
It’s Not Worth It! Maritime Pollution Offences (Code 944) c) Carbon dioxide of Pollution of oil?

d) Ozone a) Annex I
ISO 14001 Environmental Management Training Course (Code 828)
b) Annex II
c) Annex IV
d) Annex V

4 : APPENDICES 5 : ASSESSMENT QUESTIONS

48
The term “segregated ballast”
means:
a) A ballast system completely
separated from the fuel oil system
b) A ballast system completely
separated from the cargo oil
system
c) A ballast system completely
separated from the cargo and
fuel oil systems
d) None of the above
Ships may only discharge
processed bilge water from
machinery spaces into the sea if
certain very specific criteria are met.
Which of those listed are correct?
a) The ship is sailing within a
special area
b) The ship is proceeding en route
c) The oil content of the effluent
without dilution does not exceed
100 ppm
d) The ship has in operation
equipment as required by
Regulation 16(5) of Annex 1 to
MARPOL
MARPOL Annex V affects:
a) All ships (unless expressly
provided otherwise)
b) Ships of 150 GT and above
c) Ships of 500 GT and above
5 : ASSESSMENT QUESTIONS
d) Ships carrying 12 or more
passengers
The disposal of plastics at sea is:
a) Allowed anywhere outside the
designated Special Areas
b) Allowed as long as they have
passed through a comminutor
c) Allowed as long as the ship is no
less than 12 nautical miles from
the coast
d) Strictly prohibited everywhere
The Garbage Record Book must
be open for inspection at all times
and kept, after entry of the last
record, for a minimum of:
a) 6 months
b) 1 year
c) 2 years
d) 5 years
All oily water discharge must be
monitored to ensure that the oil
content is not greater than the
permitted limit. This is:
a) 10 parts per million
b) 15 parts per million
c) 25 parts per million
d) 50 parts per million
Sewage which has not been
comminuted or disinfected can
only be discharged when the ship
49
is more than: MARPOL Annex VI specifies that
a) 3 nautical miles from shore the Bunker Delivery Note (BDN)
should be kept available for
b) 12 nautical miles from shore
inspection for:
c) 4 nautical miles from shore
a) 6 months
d) 50 nautical miles from shore
b) 1 year
c) 2 years
15-18. Are the statements listed
about bunkering True or False? d) 3 years
During fuel transfer the deck
scuppers should be plugged
True or False?
Cleaning materials should be
ready to deal with any accidental
spill
True or False?
The ullage should be checked
once the transfer has been
completed
True or False?
Once transfer begins all the hoses
and connections should be checked
to ensure they are tight under pressure
True or False?
From 1 July 2010, what is the
maximum permitted sulphur
content of fuel oils in an Emission
Control Area (ECA) according to
MARPOL Annex VI?
a) 0.5%
b) 1.0%
c) 1.5%
d) 4.5%
5 : ASSESSMENT QUESTIONS
50
6 : ASSESSMENT ANSWERS

c d
d c
False b
a b
c True
d True
a False
c True
b&d b
a d

6 : ASSESSMENT ANSWERS
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