E

MARINE ENVIRONMENT PROTECTION MEPC 69/14/xx

COMMITTEE 11 February 2016
69th session Original: ENGLISH
Agenda item 14

PROMOTION OF IMPLEMENTATION AND ENFORCEMENT OF MARPOL AND

RELATED INSTRUMENTS

IACS Unified Interpretation MPC127

Submitted by the International Association of Classification Societies (IACS)

SUMMARY

Executive summary: This document provides IACS Unified Interpretation (UI) MPC127,
which has been developed by IACS members to facilitate the
uniform implementation of the revised Guidelines on
implementation of accuracy checks for 15 ppm bilge alarm, as
detailed in resolution MEPC.107(49).

Strategic direction: 1.1

High-level action: 1.1.2

Planned output: 1.1.2.3

Action to be taken: Paragraph 10

Related documents: None

Background

1 The Committee, at its forty-ninth session, adopted resolution MEPC.107(49) on the

revised Guidelines and specifications for pollution prevention equipment for machinery space
bilges of ships, which contains specifications related to 15 ppm Bilge Alarms.

2 Paragraph 4.2.11 of the Annex to this resolution states:

“4.2.11 The accuracy of the 15 ppm Bilge Alarms should be checked at IOPP
Certificate renewal surveys according to the manufacturer’s instructions.
Alternatively the unit may be replaced by a calibrated 15 ppm Bilge Alarm. The
calibration certificate for the 15 ppm Bilge Alarm, certifying date of last calibration
check, should be retained onboard for inspection purposes. The accuracy checks
can only be done by the manufacturer or persons authorized by the manufacturer.”

3 In accordance with this resolution, it is understood that the accuracy checks of the
15 ppm Bilge Alarms by the manufacturer, or persons authorized by the manufacturer, is
definitely required at IOPP renewal surveys. However, IACS considers that it is not pragmatic
to apply the accuracy checks at IOPP renewal surveys for ships having different intervals
MEPC 69/14/xx
Page 2

between IOPP renewal surveys and calibration intervals, which are generally set at five years
unless otherwise instructed by manufacturer.

4 IACS considers that this resolution intends that the accuracy of 15 ppm Bilge Alarms
be checked by calibration and testing of the equipment conducted by a manufacturer, or
persons authorized by the manufacturer, at intervals not exceeding a maximum of five years.
Consequently, IACS is of the view that the accuracy checks of the 15 ppm Bilge Alarms are
not necessarily required at IOPP renewal surveys; but rather within the period as instructed
by the manufacturer, and not more than five years from the installation, replacement, or
previous calibration of the 15 ppm Bilge Alarms.

5 Further, it is noted that paragraphs (OA) 1.2.1.17, (OIn) 1.3.1.1 and (OR) 1.4.1.2 in
Annex 3 of resolution A.1104(29) (the 2015 HSSC Guidelines) state:

“(OA) 1.2.1.17 verifying, if applicable, that the 15ppm bilge alarm has been
calibrated by the manufacturer or a person authorized by the manufacturer and that
a valid calibration certificate is available on board”;

“(OIn) 1.3.1.1 the provisions of (OA) 1.2.1”; and

“(OR) 1.4.1.2 verifying that, if applicable, the 15ppm bilge alarm has been calibrated
by the manufacturer or a person authorized by the manufacturer and that a valid
calibration certificate is available on board.”

6 Considering that the descriptions provided for (OA) 1.2.1.17 and (OR) 1.4.1.2 are
the same, it should be clear that the 15 ppm Bilge Alarms need not be calibrated at IOPP
renewal surveys. Further, the verification for a valid calibration certificate should be
periodically carried out, as stated in the relevant paragraphs in Annex 3 of resolution
A.1104(29), so that the accuracy checks for alarms with recommended calibration intervals
different from the IOPP renewal survey intervals can be implemented without omissions.

IACS Unified Interpretation

7 On the basis of the analysis as presented above, IACS has developed Unified
Interpretation (UI) MPC127, a copy of which is set out in the annex to this document, to
facilitate uniform implementation for the phrase “the accuracy of the 15 ppm Bilge Alarms
should be checked at IOPP Certificate renewal surveys according to the manufacturer’s
instructions”; as specified in paragraph 4.2.11 of the Annex to resolution MEPC.107(49).

8 The Committee is invited to note that this IACS UI is in line with resolution
A.1104(29) with regard to the periodicity of verification for a valid calibration certificate and
that resolution MEPC.107(49) might be harmonized with this periodicity.

9 The Committee is invited to note that IACS UI MPC127 will be applied by IACS
Societies from 1 January 2017, unless they are provided with written instruction to apply a
different interpretation by the Administration on whose behalf they are authorized to act as a
recognized organization

Action requested of the Committee

10 The Committee is invited to consider the foregoing, the new IACS UI MPC127 as
provided at the annex and its application provisions (as discussed in paragraph 9 above);
and decide as appropriate.
--- 0 ---
 ANNEX MPC127

MP
MPC Annex I of MARPOL 73/78
C
127 Regulation 14.7
127
(cont)
(Feb Regulation 14 Oil filtering equipment
2016)
Regulation 14.7 reads:

7 Oil filtering equipment referred to in paragraph 2 of this regulation shall comply with
paragraph 6 of this regulation. In addition, it shall be provided with alarm arrangement to
indicate when this level cannot be maintained. The system shall also be provided with
arrangements to ensure that any discharge of oily mixtures is automatically stopped when the
oil content of the effluent exceeds 15 parts per million. In considering the design of such
equipment and approvals, the Administration shall have regard to the specification
recommended by the Organization.*

The footnote to regulation 14.7 reads:

* Refer to the Recommendation on International Performance and Test Specification for Oily-
Water Separating Equipment and Oil Content Meters, adopted by the Organization by
Assembly resolution A.393(X), or the Guidelines and specifications for Pollution Prevention
equipment for Machinery space Bilges of Ships, adopted by the Marine Environment
Protection Committee by resolution MEPC.60(33), or the 2011 Guidelines and specifications
for add-on equipment for upgrading resolution MEPC.60(33) - compliant oil filtering
equipment, adopted by resolution MEPC.205(62), or the revised guidelines and specification
for pollution prevention equipment for machinery space bilges of ships, adopted by the
Marine Environment Protection Committee by resolution MEPC.107(49).

Operative paragraph 4.2.11 in the Annex of resolution MEPC.107(49) reads:

4.2.11 The accuracy of the 15 ppm Bilge Alarms should be checked at IOPP Certificate
renewal surveys according to the manufacturer’s instructions. Alternatively the unit may be
replaced by a calibrated 15 ppm Bilge Alarm. The calibration certificate for the 15 ppm Bilge
Alarm, certifying date of last calibration check, should be retained onboard for inspection
purposes. The accuracy checks can only be done by the manufacturer or persons authorized
by the manufacturer.

Operative paragraphs (OA) 1.2.1.18, (OIn) 1.3.1.1 and (OR) 1.4.1.2 in the Annex 3 of
resolution A.1104(29) read:

(OA) 1.2.1.18 verifying, if applicable, that the 15 ppm bilge alarm has been calibrated by the
manufacturer or a person authorized by the manufacturer and that a valid calibration
certificate is available on board.

Note:

1. This UI is to be uniformly implemented by IACS Members from 1 January 2017.

Page 1 of 2 IACS Int. 2016

 ANNEX MPC127

(OIn) 1.3.1.1 the provisions of (OA) 1.2.1.

MPC
(OR) 1.4.1.2 verifying that, if applicable, the 15 ppm bilge alarm has been calibrated by the
127 manufacturer or a person authorized by the manufacturer and that a valid calibration
(cont) certificate is available on board.

Interpretation

For application of resolution MEPC.107(49), the phrase “The accuracy of the 15 ppm Bilge
Alarms should be checked at IOPP Certificate renewal surveys according to the
manufacturer’s instructions” in 4.2.11 shall be interpreted as follows considering resolution
A.1104(29):

a) The validity of calibration certificate should be checked at IOPP

annual/intermediate/renewal surveys.

b) The accuracy of 15 ppm bilge alarms is to be checked by calibration and testing of the
equipment conducted by a manufacturer or persons authorized by the manufacturer
and should be done at intervals not exceeding five years or within the term specified in
the manufacturer’s instructions, whichever is shorter.

End of
Docume

Page 2 of 2 IACS Int. 2016