Page 6 NEWSLINE—March 2016

Used Cooking Oil – Proper Handling on Board Your Vessel

Throughout the course of conducting numerous VGP Annual Inspections and Port State Control inspections on vessels over
the years, ECM has noted a number of different ways that vessels have dealt with their used cooking oil. Most vessels
transfer the cooking oil to the engine room to be placed in waste oil tanks and then it is recorded in the engine room Oil
Record Book. However, various Flag and Classification Societies along with the IMO have published articles and
circulars on how to deal with these wastes.

It’s important to understand that cooking wastes which are not food wastes (Regulation 1.8, Annex V as amended) are
considered domestic waste and should be recorded within Category C of the Garbage Record Book. Additionally,
Regulation 1.3 of the revised MARPOL Annex V adopted by resolution MEPC.201(62), which entered into force on
January 1, 2013 states that “cooking oil” is to be considered a garbage and liable to be disposed of as such. The re-
lated “Guidelines for the Implementation of MARPOL Annex V” adopted by resolution MEPC.219(63) state in Section
2.4.3 that “cooking oil” is a “recyclable material” and therefore is should be separated on board and discharged on-
shore to a reception facility.

In this case, MARPOL Annex V does not explicitly indicate any different option and any transfer of the cooking oil to the
ship’s oil residue (sludge) tank is not considered an option. The mixing of the Annex V cooking oil and Annex I oil wastes
should be avoided and they should be kept separate. Putting used cooking oil in the bilge system also means putting it
through the OWS. Most OWS units and 15 ppm oil content meters are not approved to treat used cooking oil which
could cause a malfunction or reading error in the system since engine room waste oils are defined as a “petroleum” oil
and cooking oil is a “vegetable” oil. This is not to say that the OWS cannot handle the cooking oil, only that most
systems are only tested to the “petroleum” standard. Additionally, disposal under MARPOL Annex I requirements do not
refer to cooking oil and therefore disposal with machinery space petroleum oils under the “ORB Part I – Machinery
space” is not an appropriate entry.

The cooking oil can also be incinerated on board if your vessel is so equipped, provided it can be done without mixing
with other machinery oil wastes (sludge). This can be done if your vessel is equipped with an incinerator day tank which
doesn’t allow drainage back into the bilge system. Annex VI Regulation 16.2 lists the types of materials that cannot be
incinerated. It is important to check with the incinerator’s manufacturer to ensure that the incinerator can handle cooking
oil as well.

Regardless of how your vessel disposes of the cooking oil (via landing ashore to a reception facility or burning in the
incinerator), the Garbage Management Plan should show the proper handling of the wastes. This should also only be
recorded in the Garbage Record Book only as discussed above and if landed ashore, proper receipts should be
obtained and kept on board as proof of proper disposal.

Reference: IMO Sub-Committee on Pollution Prevention and Response (PPR 2/15/1) 14NOV2014, related to the disposal
of cooking oils