Man Ems 010

Prime Tanker Management Inc.
Prime Gas Management Inc.
Manual Code: EMS (009)
ENVIRONMENTAL MANUAL
Authorized by DPA
Approved by
CHIEF OPERATING OFFICER (COO)
DOCUMENT CONTROL
No part of this document may be reproduced, utilised, stored in any retrieval system or transmitted in any
form or by any means, electronic or mechanical, including photocopying, recording or by any information,
storage or retrieval system without the permission of Prime Tanker Management Inc and Prime Gas
Management Inc.
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GENERAL
Environmental Prime Gas Management Inc.
Manual (009) Revision: 09
GENERAL
Eff. Date: 29/02/2020
RECORD OF AMENDMENTS
Amendment Date Position /
Section / Page No. Date Issued Initials
Number Amended Rank
All Sections
00 Newly issued 01/03/2016 N/A CAC S&Q Mgr
Manual
Sections Amended
01 01/03/2016 30/09/2016 CAC S&Q Mgr
01-06-07-09
Sections Amended
02 01/03/2016 28/02/2017 CAC S&Q Mgr
05
Section Amended
03 01/03/2016 31/03/2017 CAC S&Q Mgr
04
Additional
Versions added
automatically be
DANAOS during
the integration
( due to
unsuccessful
uploading )
01-02-02-03-03
04-04-05-06-07-
08-08-09-10-10
All Sections
04 01/03/2016 30/11/2017 CAC S&Q Mgr
01 to10
Sections Amended
05 01/03/2016 30/06/2018 CAC S&Q Mgr
02-03-05-06
Sections Amended
06 01/03/2016 31/03/2019 CAC S&Q Mgr
03-07
Sections Amended
07 01-02-03-04- 01/03/2019 31/05/2019 CAC S&Q Mgr
05-06-07
-08-09-10
Sections Amended
01/03/2019
03-05-06
08 30/09/2019 CAC S&Q Mgr
New Section
30/09/2019
05A
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GENERAL
GENERAL
Eff. Date: 29/02/2020
Amendment Date Position /

Section / Page No. Date Issued Initials
Number Amended Rank
05A
Rev. created by
Danaos
Sections Amended
( All)
09 01-02-03-04 01/03/2019 29/02/2020 CAC S&Q Mgr
05-05A-06-07
08-09-10
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GENERAL
GENERAL
Eff. Date: 29/02/2020
CONTENTS
SECTION No Title Issue Issue

Status Date
Manual Control Page
GENERAL : 09 29/02/2020
Record of Amendments and Contents
SECTION 01 Introduction 05 29/02/2020
SECTION 02 Law and Regulations 06 29/02/2020
SECTION 03 Compliance with Marpol Annex I 08 29/02/2020
SECTION 04 Compliance with Marpol Annex IV 06 29/02/2020
SECTION 05 Compliance with Marpol V 07 29/02/2020
SECTION 05A Garbage Management 02 29/02/2020
( Transferred from SOM (007) Manual
SECTION 06 Compliance with Marpol VI 07 29/02/2020
SECTION 07 Compliance with Ballast Water Management 06 29/02/2020
Requirements
SECTION 08 Miscellaneous Pollution Sources 05 29/02/2020
SECTION 09 Office Environmental Requirements 05 29/02/2020
SECTION 10 Ship Recycling 05 29/02/2020
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Prime Tanker Management Inc. SECTION 01
Environmental
Manual Prime Gas Management Inc.
(009) Revision: 05
INTRODUCTION Eff. Date: 29/02/2020
Contents
1. PURPOSE.....................................................................................................................................2
2. PROCEDURE...............................................................................................................................2
2.1 Protection of The Environment................................................................................................. 2
2.2 General Requirements............................................................................................................... 3
2.2.1 Portable Emergency Transfer Pumps.....................................................................................3
2.2.2 Sorbent Material and Tools....................................................................................................3
2.2.3 Scuppers and actions on deck in the event of rain................................................................. 3
2.2.4 Oil Record Book Weekly Reporting and Review.................................................................. 4
2.2.5 Environmental Critical Equipment........................................................................................ 4
3. RECORD...................................................................................................................................... 4
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1. PURPOSE
The aim of the following procedures is to provide a proactive approach to environmental
management that includes identification of sources of marine and atmospheric pollution and
measures for the reduction of potential impacts both onboard and ashore.
The Company is voluntary committed in continually improving its environmental performance by
adopting an Environmental Management System (EMS, which is part of the IMS), by which all
aspects of its activities with significant environmental impact are identified, addressed, monitored
and controlled.
2. PROCEDURE
2.1 PROTECTION OF THE ENVIRONMENT

The DPA is responsible to coordinate the Management and Environmental Review Committee
meetings and record their results. The DPA / EMR / EnMR are also responsible to record and
monitor the implementation of the Company¶s Environmental (including Energy Efficiency)
programs.
The Management and Environmental Review Committee members are responsible to identify the
environmental impacts of the Company¶s activities and to propose solutions and action plans so as to
minimise these impacts. Reference is made to the relevant procedures of the IMS Procedures Manual.
All shore staff, Superintendent Engineers, Port Captains, Technicians, etc., having routine
involvement in any aspect of the Vessels¶ operations, maintenance and repairs shall report to the
DPA any information related to the Vessels¶ or crew's inability to comply with the IMS and any other
marine environmental protection requirement.
The Master is responsible for the proper implementation of this procedure onboard, in cooperation
with the Chief Engineer. This procedure also involves all Officers and ratings.
The purpose is to ensure that:
x Interaction of the shipboard activities with the environment is in accordance with the applicable
rules and regulations.
x Shipboard emissions to the sea, air and land are controlled and monitored in accordance with the
Company¶s policies and objectives.
x Environmental aspects of the Company¶s activities which have significant impacts to the
environment are identified, controlled and continuously monitored.
The Company has established, implements and maintains the following procedures to systematically
identify and assess all environmental aspects of its ships and shore-based operations, taking into
account planned or new developments or new or modified services:
x Minimising adverse environmental impacts and waste generation, and ensuring the safe and
responsible disposal of residual wastes.
x Reporting arrangements for all pollution incidents or near-misses which could have resulted in
pollution.
x Establishing reduction targets to minimise discharge of pollutants.
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2.2 GENERAL REQUIREMENTS

All Company¶s ships comply with MARPOL and other applicable regulations. Additional
requirements may be imposed by the National Authority with which the ship is registered and/or by
the Administration within whose territorial jurisdiction is intended to operate.
This section provides details of the Company's minimum requirements which must be complied with
at all times.
More specific requirements and information will be found in instructions, EMS Circulars,
Newsletters, Bulletins circulated to the Fleet and regulatory publications which are referred to in this
Section.
2.2.1 PORTABLE EMERGENCY TRANSFER PUMPS

During all ballast and bunker handling operations, and at all other times when in port, the portable
emergency transfer pumps must be deployed at the aft end of the main deck on each side of the ship
and rigged ready for immediate use to transfer any liquid to a slop tank or other suitable tank.
Pump discharge hoses are to be of non-collapsing reinforced rubber construction.
The transfer pumps to be connected to the Vessel¶s structure by earthing wires, which must be
connected to a suitable earthing point whenever transferring through these pumps is deployed.
2.2.2 SORBENT MATERIAL AND TOOLS

During all bunker handling operations the ³oil spill response´ kit, containing sorbent materials, must
be deployed on each side of the ship. Many countries do not allow chemicals to be used in port areas.
Clarification must be sought from the port authorities before utilising these products.
On LPG Vessels, scuppers might left open while at port, except during Bunkering Operations.
2.2.3 SCUPPERS AND ACTIONS ON DECK IN THE EVENT OF RAIN

Scuppers must be effectively plugged during all bunker handling operations, and at all other times
when in port, to prevent any spilled oil escaping into the water around the Vessel and terminal.
Where the ship is fitted with a scupper drain system this must be checked prior to arrival in port to
ensure that the lines are clear and the valves operate correctly.
Scupper drain system valves must be clearly identified.
In the event of rain, there will inevitably be a build-up of water on deck, which will nearly always
have sheen of oil on it as the result of grease run off from exposed wires, winch gears, etc.
Rain water accumulated at the deck stringers on both sides of the Vessel and particularly when
Vessel is trimmed for operational purposes, may create very severe problem if there is a spillage,
because it displaces the oily mixture over the stringer and into the sea.
Rain water must never left to build up to a level where it might flow over the ship side plate.
If needed, the portable emergency transfer pump or the scupper drain system must be used to transfer
the water to a suitable tank.
The officers and deck crew on watch must be permanently vigilant on this matter, and when they
have to drain the water, extreme care must be taken when replacing the scuppers before oily mixtures
run off following the water.
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2.2.4 OIL RECORD BOOK WEEKLY REPORTING AND REVIEW

Following a number of MARPOL violation incidents reported by various International
Organizations, the Company has increased its requirements in the reporting and review of Oil Record
Books as per relevant Company¶s Circular.
According to this, weekly copies of Oil Record Book must be sent every Sunday afternoon at office
for review and are also accompanied by form ³Oil Record Book Supplement´ that includes three (3)
parts:
x Bilge / Sludge Tanks Sounding / Capacity Register.
x OWS Oil Content Meter Memory Card Entries Log.
x Bilge Suction / Discharge Valves & Flanges Seals Register.
2.2.5 ENVIRONMENTAL CRITICAL EQUIPMENT

Company has developed a Risk Assessment (RA) and accordingly derived list of Critical Equipment.
The following critical equipment, considering their environmental impact have been also categorized
as Environmentally Critical:
x Oil / water separator including Content Meter.
x Incinerator.
x Sewage System.
x ODME - Oil Discharge Monitoring Equipment for cargo (applicable in oil tankers).
x Ballast Water Treatment System.
x Exhaust Gas Cleaning System ± Scrubber.
Spares from list of environmental critical equipment are kept separately in boxes painted orange with
Stencil name of System in order to avoid incorrect or unauthorized use.
In case that any of the above critical equipment is malfunctioning, the malfunction must be
immediately reported to the Company and any Discharge / Disposal as above must concurrently stop.
All effluents (either bilges, slops, sewage or sludges) must be retained on board and the Company
will arrange disposal at shore facilities at the next port of call.
Company does not care for the cost necessary for disposal, whatever high might be.
Therefore does not accept this kind of saving to be attempted by any crew member.
This must be clear and well understood. Disciplinary actions, including immediate dismissal, will be
implemented against whoever violates the Environmental Policy.
The condition of the equipment is checked on a weekly basis and the reports are sent to the office
together with the required documents.
All PMS Jobs related to Environmentally Critical Equipment have to be accompanied by clear
photos. Reference is also made in PROC 28-Annex B G-02-Critical Equipment Risk Assessment.
3. RECORD
Oil Record Book Supplement EMS/SECTION 3/SF/TEC/135
Risk Assessments to be referred to:
De-activation of Oily Water Separator A-11
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LAW AND REGULATIONS Eff. Date: 29/02/2020
Contents
1. PURPOSE.....................................................................................................................................2
2. PROCEDURE...............................................................................................................................2
2.1 MARPOL 73/78 - Annex I........................................................................................................ 2
2.2 MARPOL 73/78 - Annex II.......................................................................................................2
2.3 MARPOL - Annex IV............................................................................................................... 3
2.4 MARPOL - Annex V................................................................................................................ 3
2.5 MARPOL - Annex VI............................................................................................................... 4
2.6 MEPC........................................................................................................................................ 5
2.7 Kyoto Protocol.......................................................................................................................... 5
2.8 SOLAS...................................................................................................................................... 6
2.9 BHC Code................................................................................................................................. 6
2.10 IBC Code................................................................................................................................6
2.11 IMDG Code............................................................................................................................6
2.12 International Convention on the Control of Harmful Antifouling System on Ships............. 6
2.13 Directive 75/442/EC.............................................................................................................. 7
2.14 International Convention for the Control and Management of Ships¶ Ballast Water and
Sediments............................................................................................................................................7
2.14.1 International Convention for the Control and Management of Ships¶ Ballast as per US Ballast Water
Requirements...................................................................................................................................................................7
2.15 Maritime Labour Convention and STCW Code.................................................................... 8
2.16 USA Requirements and Regulations......................................................................................8
2.17 VRP / NTVRP........................................................................................................................8
2.18 US Government CWA (Clean Water Act).............................................................................9
2.19 TMSA 3 Requirements.......................................................................................................... 9
2.19.1 Particulate Matter...............................................................................................................9
2.19.1.1 Data Sources......................................................................................................................... 9
2.19.1.2 PM Calculation..................................................................................................................... 9
2.20 Directive 2015/757/EC....................................................................................................... 11
3. RECORD.................................................................................................................................... 11
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1. PURPOSE
This procedure describes the applicable Law and Regulations relevant to the Environmental matters.
2. PROCEDURE
2.1 MARPOL 73/78 - ANNEX I

Oil tankers of 150 GT or more and other ships of 400 GT or more shall be surveyed for compliance
with MARPOL / Annex I, by reviewing the ship's International Oil Pollution Prevention (IOPP)
Certificate or equivalency, Oil Record Book(s), oil discharge monitor records, and subdivision and
stability documents and calculations.
The first step, in checking a ship engaged in oceangoing trade for Annex I compliance, is to review
the ship's IOPP certification.
The IOPP Certificate provides information to easily determine if a ship has all required equipment
and systems on board.
The IOPP Certificate is composed of two (2) parts:
x The one page Certificate shows the expiration date and the dates, places, and persons
completing required surveys.
x The second part is either Form A Supplement, Record of Construction and Equipment for
Ships Other than Oil Tankers, or Form B Supplement, Record of Construction and Equipment
for Oil Tankers.
The Form A and B Supplements provide specific information on the ship and its pollution prevention
equipment.
MARPOL 73/78 requires Shipboard Oil Pollution Emergency Plans (SOPEP) to be available
onboard. This Shipboard Oil Pollution Emergency Plan shall be written in accordance with the
requirements of MARPOL 73/78 Annex I, as amended.
Shipboard Marine Pollution Emergency Plans (SMPEP) have to be onboard for noxious and liquid
substances referring to chemical tankers holding NLS Class Certificate.
The purpose of the Plan is to provide guidance to the Master and officers on board the ship with
respect to the steps to be taken when a pollution incident has occurred or is likely to occur.
MARPOL 73 / 78, as amended, aims at ensuring that discharges from ships are minimized in order to
prevent damage to the environment.
A number of resolutions have been adopted by IMO (MEPC) that define or recommend suitable
equipment, performance standards and/ or procedures.
This publication provides an up ± to ± date reference to all applicable IMO ± resolutions on shipboard
pollution prevention equipment required under MARPOL 73/78.
2.2 MARPOL 73/78 - ANNEX II

Carriage of chemicals in bulk is covered by regulations in SOLAS Chapter VII - Carriage of
dangerous goods and MARPOL Annex II - Regulations for the Control of Pollution by Noxious
Liquid Substances in Bulk.
Both Conventions require chemical tankers built after 1 July 1986 to comply with the International
Bulk Chemical Code (IBC Code), which gives international standards for the safe transport by sea in
bulk of liquid dangerous chemicals, by prescribing the design and construction standards of ships
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involved in such transport and the equipment they must carry so as to minimize the risks to the ship,
its crew and to the environment, having regard to the nature of the products carried.
The IBC Code lists chemicals and their hazards and gives both the ship type required to carry that
product as well as the environmental hazard rating.
Each of the products may have one or more hazard properties which include flammability, toxicity,
corrosiveness and reactivity.
Annex II of MARPOL 73/78 prohibits the discharge into the sea of Noxious Liquid Substances
(NLS) of Categories X, Y or Z or of ballast water, tank washings or other residues or mixtures
containing such substances, except in compliance with specified conditions including procedures and
arrangements based upon standards developed by the International Maritime Organization (IMO) to
ensure that the criteria specified for each Category will be met.
The requirements of Annex II apply to all ships carrying Noxious Liquid Substances in bulk.
Substances posing a threat of harm to the marine environment are divided into three (3) categories:
x X
x Y
x Z
Category X substances are those posing the greatest threat to the marine environment, whilst
Category Z substances are those posing the smallest threat.
2.3 MARPOL - ANNEX IV

Annex IV applies only to ships that engage in international voyages.
These include ships of 400 gross tonnage and above or less than 400 gross tonnage if they are
certified to carry more than 15 persons.
Ships are required to be equipped with either a sewage treatment plant in compliance with IMO
standards, a sewage comminuting and disinfecting system or a holding tank for the retention of
sewage (Regulation 9).
Regulation 10 outlines the standard discharge connections required to enable pipes of reception
facilities to be connected to the ship¶s discharge pipeline.
Survey and certification of ships will be required under Regulation 4.
Ships will be subject to an initial survey before the ship is put into service, when an International
Sewage Pollution Prevention Certificate is issued for the first time and/or during renewal surveys at
intervals not exceeding five years.
The issue, form, duration and validity of the International Sewage Pollution Prevention Certificate
are outlined in Regulations 5, 6, 7 and 8.
2.4 MARPOL - ANNEX V

MARPOL Annex V, as amended by MEPC Circulars requires that:
x every ship of 100 gross tonnage and above, and every ship certified to carry 15 or more persons,
and fixed or floating platforms shall carry a garbage management plan;
x every ship of 400 gross tonnage and above, and every ship certified to carry 15 or more persons
engaged in voyages to ports or offshore terminals of another Party, and every fixed or floating
platform shall be provided with a Garbage Record Book; and
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x every ship of 12 meters or more in length overall, and fixed or floating platforms shall display
placards which notify the crew and passengers of the ship's disposal requirements of Regulations
3, 4, 5 and 6 of the Annex as applicable.
Compliance with the provisions of Annex V requires careful planning by the Ship Management
Company and proper execution by shipboard personnel.
When developing the most appropriate procedures for handling and storing garbage, the Vessel¶s
type and size, the area of operation (e.g. distance from nearest land), shipboard garbage processing
equipment and storage space, crew size, duration of the voyage and regulations and reception
facilities at ports of call were taken into account.
Reference is made to the ship-specific Garbage Management Plan (Form SF/MRS/213).
2.5 MARPOL - ANNEX VI

MARPOL Annex VI sets limits on sulphur oxide and nitrogen oxide emissions from ship exhausts
and prohibits deliberate emissions of ozone depleting substances.
The Annex includes a global cap on the sulphur content of fuel oil and calls on IMO to monitor the
worldwide average sulphur content of fuel.
Annex VI contains provisions allowing for special SOx Emission Control Areas (ECA) to be
established with more stringent controls on sulphur emissions.
In these areas, the sulphur content of fuel oil used onboard ships must not exceed a specific
percentage.
Alternatively, ships must fit an exhaust gas cleaning system or use any other technological method to
limit SOx emissions.
Annex VI prohibits deliberate emissions of ozone depleting substances, which include halons and
chlorofluorocarbons (CFCs).
New installations containing ozone-depleting substances are prohibited on all ships. But new
installations containing hydro-chlorofluorocarbons (HCFCs) are permitted until -DQXDU\ 2020.
Annex VI also sets limits on emissions of nitrogen oxides (NOx) from diesel engines.
Also, NOx Emission Control Areas have been designated under regulation 13 of MARPOL Annex VI
(NOx emission control) for specific certification type diesel engines and amendments adopted by
Resolution MEPC.286 (71).
A mandatory NOx Technical Code, which defines how this shall be done, was adopted by the
Conference under the cover of Resolution 2.
The Annex also prohibits the incineration onboard ship of certain products, such as contaminated
packaging materials and polychlorinated biphenyls (PCBs).
Regulation 15 of Annex VI of MARPOL 73/78, as revised by IMO Resolution MEPC.176 (58),
regulates the Volatile Organic Compounds (VOC) emissions from a tanker in designated port(s) or
terminal(s) of a Party regulating such emissions.
Volatile organic compounds (VOCs) may be toxic, and when they evaporate into the air where they
can react with Nitrogen Oxides (NOx) in sunlight and split apart oxygen molecules in air and thereby
form ground-level ozone, commonly referred to as smog.
The layer of brown haze it produces is not just an eyesore, but also is a source of serious illnesses.
The aim of the VOC Plan, which is required by this Annex, is to identify the arrangements and
equipment required to enable compliance with Regulation 15.6 of the revised Annex VI and to
identify for the ship¶s officers all operational procedures for VOC emission control.
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ANNEX VI requires all Convention ships of parties to MARPOL 73/78 to be issued with an
International Air Pollution Prevention Certificate. The certificate¶s continuing validity will require
annual, intermediate and renewal surveys to be satisfactorily carried out and, being a statutory
certificate, it will come under the scrutiny of port state control inspectors wherever the ship is
trading.
Reference is made to bunkering procedure of the Shipboard Operations Manual, the stand-alone ship-
specific VOC Manual and the section of this manual for controlling ozone depleting substances.
2.6 MEPC
MEPC: Marine Environment Protection Committee. IMO ± committee working on issues connected
to the prevention of pollution. The committee¶s main task is related to the MARPOL 73/ 78
Convention and its continuous development. MEPC produces guidelines and other documents related
to the prevention of pollution from ships.
2.7 KYOTO PROTOCOL

The Kyoto Protocol is the basis for the first measures to halt climate change worldwide.
The Kyoto Protocol, responsible of the greenhouse effect, requires the control of carbon dioxide
(CO2), nitrous oxide (N2O), methane (CH4), hydro fluorocarbons (HFCs), perfluorocarbons (PCFs),
and sulphur hexafluoride (SF6).
The overall reduction must have been at least 5 % within 2008-2012, with respect to 1990 levels of
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The International Maritime Organization (IMO) through its Marine Environment Protection
Committee (MEPC) has developed regulation to improve energy efficiency on board ships.
The first formal CO2 control regulations were adopted at the MEPC 62 in July 2011 and were further
amended at the MEPC 63 in March 2012.
These regulations comprise of the Energy Efficiency Design Index (EEDI) and Ship Energy
Efficiency Management Plan (SEEMP), both of which were entered into force on 1 January 2013 and
are necessary for the issuance of an International Energy Efficiency Certificate (IEEC) for
Newbuildings.
Recognizing the need to develop management tools to assist in managing the ongoing environmental
performance of ships, Ship Energy Efficiency Management Plan, as recommended by the IMO
±MEPC. 213 (63), must be developed.
The 2012 Guidelines for the Development of a SEEMP have been revised accordingly and new 2016
Guidelines were adopted at MEPC (Resolution MEPC.282 (70)).
This plan provides an approach for monitoring ship and fleet efficiency performance over time and
some options to be considered when seeking to optimize the performance of the ship, recognizing
that no two shipping companies are the same, and that ships operate under a wide range of different
conditions.
Further to the below, the International Maritime Organization (IMO) adopted a mandatory Fuel Oil
Data Collection System (DCS) for international shipping, requiring ships of 5,000 gross tonnage or
above to start collecting and reporting data to an IMO database from 2019.
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It was adopted by the IMO¶s Marine Environment Protection Committee (MEPC70) on 28th October
2016 as amendments to Chapter 4 of Annex VI of MARPOL, adding a new Regulation 22A on
Collection and reporting of ship fuel oil consumption data and new appendices covering Information
to be submitted to the IMO Ship Fuel Oil Consumption Database. These amendments came into force
on 1 March 2018.
Reference is made to the stand-alone ship-specific Ship Energy Efficiency Management Plan.
2.8 SOLAS
A number of relevant Codes regarding the prevention of pollution have been made mandatory under
SOLAS Convention (the International Safety Management Code ± the ISM Code and others).
2.9 BHC CODE

Code for the Construction and Equipment of Ships carrying Dangerous Chemicals in Bulk
The BHC Code implements both technical and operational requirements and includes a listing of
chemicals for which the code is applicable to (a supplement to the code).
These requirements apply to Chemical Tankers, built before 1st July, 1986.
2.10 IBC CODE

International Code for the Construction and Equipment of Ships Carrying Dangerous Chemicals in
Bulk
The IBC Code covers requirements of both technical and operational nature and includes a listing of
those chemicals is applicable to.
These requirements apply to Chemical Tankers built on or after 1st of July, 1986.
2.11 IMDG CODE

International Maritime Dangerous Goods Code
International Maritime dangerous goods code is an international guide setting standards to the
transport of dangerous goods by sea. It is intended for use by the mariner as well as by all those
involved in industries and services connected with shipping. It is divided into two volumes and a
supplement.
2.12 INTERNATIONAL CONVENTION ON THE CONTROL OF HARMFUL ANTIFOULING SYSTEM ON

SHIPS
The International Convention on the Control of Harmful Anti-fouling Systems on Ships, which was
adopted on 5 October 2001, prohibits the use of harmful organotins in anti-fouling paints used on
ships and establishes a mechanism to prevent the potential future use of other harmful substances in
anti-fouling systems.
Under the terms of the Convention, Parties to the Convention are required to prohibit and/or restrict
the use of harmful anti-fouling systems on ships flying their flag, as well as ships not entitled to fly
their flag but which operate under their authority and all ships that enter a port, shipyard or offshore
terminal of a Party.
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Under the terms of the convention, ships either:

x shall not bear such compounds on their hulls or external parts or surfaces; or
x shall bear a coating that forms a barrier to such compounds leaching from the underlying non-
compliant anti-fouling systems.
This applies to all ships (excluding fixed and floating platforms, floating storage units (FSUs), and
Floating Production, Storage and Offloading units (FPSOs).
Ships of above 400 gross tonnage and above engaged in international voyages (excluding fixed or
floating platforms, FSUs and FPSOs) will be required to undergo an initial survey before the ship is
put into service or before the International Anti-fouling System Certificate is issued for the first time;
and a survey when the anti-fouling systems are changed or replaced.
Anti-fouling systems to be prohibited or controlled will be listed in an annex (Annex 1) to the
Convention, which will be updated as and when necessary.
Reference is made to the stand-alone ship-specific Bio-fouling Management Plan.
2.13 DIRECTIVE 75/442/EC

This directive requires that all those storing waste, must only hand over their waste to a company
duly authorized for waste treatment.
2.14 INTERNATIONAL CONVENTION FOR THE CONTROL AND MANAGEMENT OF SHIPS ¶ BALLAST
WATER AND SEDIMENTS
Ballast water is essential to control trim, list, draught, stability, or stresses of the ship. However,
ballast water may contain aquatic organisms or pathogens which, if introduced into the sea including
estuaries, or into fresh water courses, may create hazards to the environment, human health, property
or resources, impair biological diversity or interfere with other legitimate uses of such areas.
The selection of appropriate methods of ballast water management must take into account the need
ensure that Ballast Water Management practices used to comply with this Convention do not cause
greater harm than they prevent, to the environment, human health, property or resources of any States
and the safety of ships.
The Ballast Water Management Plan shall be written in accordance with the requirements of
Regulation B-1 of the International Convention for the Control and Management of Ships' Ballast
Water and Sediments, 2004 (the Convention) associated Guidelines and national requirements.
Reference is made to the stand-alone ship-specific Ballast Water Management Plan.
2.14.1 International Convention for the Control and Management of Ships¶ Ballast as per US
Ballast Water Requirements
Ballast water management in the United States is administered by both the US Coast Guard (USCG)
and the US Environmental Protection Agency (EPA).
The USCG final rule became effective on 21 June 2012 and applies to all Vessels, US flag, and non-
US flag, equipped with ballast tanks operating in US navigable waters (defined in 33 CRF 2.38)
unless specifically exempt (crude oil tankers engaged in coastwise service and Vessels that operate
exclusively within one Captain of the Port (COTP) zone).
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US navigable waters include the territorial sea as extended to 12 nautical miles from the US baseline.
While some specific types of Vessels are exempt from certain BWM requirements, all Vessels with
ballast tanks must meet the reporting and recordkeeping requirements.
Per these regulations, the owner/operator of a Vessel equipped with ballast tanks operating in US
waters must employ one of the following management methods:
Install and operate a ballast water management system (BWMS) that has been approved by the
USCG under 46 CFR 162.060
Use only water from a US public water system
Perform complete ballast water exchange in an area 200 nautical miles from any shore prior to
discharging ballast water, unless the Vessel is required to employ an approved BWMS per the
implementation schedule
No ballast water is discharged
Discharge to a facility onshore or to another Vessel for the purpose of treatment
In the case of an emergency or malfunction of the treatment system, the USCG may allow the use of
ballast water exchange as a contingency.
Treatment must be done using either a USCG type-approved system or a system type approved by
another Administration which the USCG has accepted.
The USCG treatment discharge standard is the same as the IMO Ballast Water Management
Convention D-2 Standard.
Reference is made to the stand-alone ship-specific Ballast Water Management Plan and Vessel
General Permit.
2.15 MARITIME LABOUR CONVENTION AND STCW CODE

MLC 2006 sets out seafarers¶ rights to minimum decent conditions of work and living and helps to
create conditions of fair competition for Shipowners.
The MLC 2006 contains new subjects, particularly in the area of occupational safety and health, to
meet current health concerns, such as fatigue, the effects of noise and vibration on workers and other
workplace risks.
STCW is regulating Seafarers¶ Competence Certificates, Qualifications, and Training.
2.16 USA REQUIREMENTS AND REGULATIONS

OPA ± 90, Oil Pollution Act of 1990: OPA ± 90 sets requirements to liability of freight of oil in US
waters. OPA ± 90 is a US public law.
Some definitions of this law will have general interest whilst for tanker owners operating in US
waters, the OPA ± 90 will be governing.
2.17 VRP / NTVRP

Is the United States Coast Guards regulation to improve pollution, response preparedness for Vessel
carrying or handling oil upon the navigable waters of the United States.
This role is applicable upon all navigable waters of the US, including the exclusive economic zone
and adjoining shorelines.
Reference is made to the stand-alone ship-specific Vessel Response Plan.
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2.18 US GOVERNMENT CWA (CLEAN WATER ACT)

CWA prohibits the discharge of oil into any surface waters of the U.S., if the discharge violates
applicable State water quality standards or effluent standards or causes a sheen on, or film upon, or
discoloration of the surface of the water or adjoining shorelines, or causes a sludge or emulsion to be
deposited beneath the surface of the water, or upon the shoreline.
On 18 December 2008 the U.S. Environmental Protection Agency (EPA) initially issued the final
Vessel General Permit (VGP) under the authority of the Clean Water Act (CWA) requirements for
the National Pollutant Discharge Elimination System (NPDES) programme.
The requirements applied to different discharges incidental to the normal operation of all commercial
Vessels 79 feet or greater in length when operating within the 3 mile territorial sea of the United
States.
The Vessel General Permit (VGP) lays out the requirements for general housekeeping on board, and
to monitor discharges from specific sources on board ships.
The EPA reissued the 2013 VGP on April 12, 2013 with an effective period of December 19, 2013 to
December 18, 2018 (i.e., five years). The VGP provided NPDES permit coverage nationwide for
discharges incidental to the normal operation of commercial Vessels greater than 79 feet in length.
However, the Vessel Incidental Discharge Act (³VIDA´) legislation, implemented on December 4,
2018, established a new framework for the regulation of Vessel incidental discharges under Clean
Water Act (CWA) Section 312(p).
VIDA requires EPA to develop performance standards for those discharges within two years of
enactment and requires the U.S. Coast Guard to develop implementation, compliance, and
enforcement regulations within two years of EPA¶s promulgation of standards.
In conclusion, VIDA legislation extends the 2013 VGP¶s provisions, leaving them in effect until new
regulations are final and enforceable.
Reference is made to the stand-alone Ship-Specific Vessel General Permit.
2.19 TMSA 3 REQUIREMENTS
2.19.1 PARTICULATE MATTER

Particulate matter (PM), also known as particle pollution, is a complex mixture of extremely small
particles and liquid droplets that get into the air, produced by the combustion of fuel in ship's diesel
engines. Once inhaled, these particles can affect the heart and lungs and cause serious health issues.
2.19.1.1 DATA SOURCES

The amount of particulate matter emitted to the atmosphere depends on the amount of sulphur in the
fuel (% m/m) burnt in the Vessel's engines. Therefore, primary data sources for the assessment of
ship's PM emissions must be the ship¶s bunkering- related records (i.e. Bunkering operations log,
bunker delivery notes, etc.) which provide a clear view of the fuel type1, quality (in terms of sulphur
content) and quantity received by the ship over a given period (e.g. quarterly, biannually).
2.19.1.2 PM CALCULATION
Taking into account the interrelation of PM emissions and the % sulphur content of the fuel burnt in
order to assess the ship's PM emissions performance and based on data from LR Marine Exhaust
Emissions Research Program, it is important to calculate the weighted average of the % of sulphur
content (% m/m) of each type of fuel (e.g. HFO, MDO, LFO) received by the Vessel over a given
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period. This assessment is based on the simplification that the fuel received (type, quantity, quality)
during the reported period is the same in terms of type, quantity and quality with the fuel burnt for
propulsion and auxiliary services (auxiliary generators, boilers).
Despite the fact that this process imposes a certain degree of uncertainty to the calculations, the errors
over a continuous reporting period are smoothed out and become negligible.
The weighted average of the sulphur content of each type of fuel used is calculated by the following
equation:
Sx=i=1n(Ax,jൈBx,j)i=1n(Ax,j) (1)Sx=i=1n(Ax,jൈBx,j)i=1n(Ax,j)
(1)
Where:
xx = Fuel type (e.g. HFO, LFO, MDO etc.) received by the Vessel
nn = Number of bunkering operations within the reporting period
SxSx = Weighted average of % sulphur content of fuel type
xx
Ax,jAx,j = Quantity of fuel of type
xx received during bunkering operation
jj (in MT)
Bx,j Bx,j = Sulphur content (% m/m) of fuel type
xx received during bunkering operation
jj
(As per the Bunker Delivery Note received by the Vessel).
The ship¶s
PMPM emission for
nn bunkering operations is given by the formula below:
PM=i=1n(FOCiൈPMef)1000 (2)PM=i=1n(FOCiൈPMef)1000
(2)
Where:
PMPM = The quantity of ship¶s PM emission over n bunkering operations in MT.
FOCiFOCi= The quantity of fuel bunkered in MT.
PMefPMef =
PMPM emission factor depending on fuel sulphur content as per graph on next page
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2.20 DIRECTIVE 2015/757/EC

In June 2013, the European Commission proposed a strategy for progressively integrating maritime
emissions into the EU's policy for reducing its domestic greenhouse gas (GHG) emissions.
After a two-year legislative process involving all EU institutions, this strategy was adopted by the
European Parliament in April 2015. The Regulation 2015/757 ('Shipping MRV Regulation') came
into force on 1st July 2015.
The strategy consists of three consecutive steps:
x Monitoring, reporting and verification of carbon emissions from ships.
x GHG reduction targets for the maritime transport sector.
x Further measures, including Market-Based Measures (MBM).
x
The first step of the strategy is the design of a robust Monitoring, Reporting and Verification (MRV)
system of carbon emissions for ships exceeding 5,000 gross tonnage (GT) on all voyages to, from
and between EU ports applicable from 2018.
The second step is to set Greenhouse gas reduction targets for the maritime transport sector.
The third step is further measures, including Market-Based Measures (MBM).
The EU Shipping MRV system is designed to contribute to building an international system. First
steps in this direction have already been taken at the IMO, with active support from the EU and
partner countries. On 4 February 2019 the European Commission (EC) tabled a proposal
concerning the amendment of Regulation (EU) 2015/757 on the monitoring, reporting and
verification of carbon dioxide emissions from maritime transport (the ³EU MRV Regulation´). The
main objective of the proposal is to amend the EU MRV Regulation in order to take account of the
new Global Data Collection System (³IMO DCS´) for fuel oil consumption of ships that was
introduced by the International Maritime Organisation (IMO) in March 2018.
By yielding further insights into the sector's potential to reduce emissions, the EU Shipping MRV
system will also provide new opportunities to agree on efficiency standards for existing ships.
Reference is made to the stand-alone ship-specific EU MRV Monitoring Plan.
3. RECORD
EMS Environmental Workbook PRO/PRO 25 / SF/TEC/139
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COMPLIANCE WITH MARPOL ANNEX I Eff. Date: 29/02/2020
Contents
1. PURPOSE.....................................................................................................................................2
2. PROCEDURE...............................................................................................................................2
2.1 Bunkering Tanks Cleaning........................................................................................................ 2
2.2 Handling of Oily Bilge Water and Sludge in the Engine Room............................................... 2
2.2.1 Oily Water Separator (OWS).......................................................................................................................... 3
2.2.2 Bilge main cross-connections..........................................................................................................................5
2.2.3 Overboard valves.............................................................................................................................................5
2.2.4 Oil to Sea Interface Management....................................................................................................................5
2.2.5 Handling of oil sludges................................................................................................................................... 6
2.2.6 Separation and discharging of E/R Oily Bilge Water using the OWS............................................................7
2.2.7 Discharge of E/R oil and oily water to shore facilities................................................................................. 11
2.3 Handling of Slops.................................................................................................................... 11
2.4 Bilge, Sludge and Slop Management Record Keeping........................................................... 13
2.4.1 Oil Record Book Part I and Part II................................................................................................................ 14
2.4.2 Bilge and Sludge receipts.............................................................................................................................. 15
2.4.3 Oil Content Meter (OCM) Calibration Log.................................................................................................. 15
2.4.4 Engine logbook............................................................................................................................................. 15
3. RECORD.................................................................................................................................... 16
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1. PURPOSE
This Section includes Instructions concerning:
x The Arrangements and Operation Procedures for handling Oily Mixtures in the Engine Room
and in the Cargo Space area, in accordance with the requirements of Annex I of MARPOL.
x The Arrangements and Procedures for handling Oil Sludges and Bilges.
x The requirements for discharge within and outside of special areas, as per Annex I of MARPOL.
x The completion of the Oil Record Book (ORB).
The Company¶s ships must always handle the oil residues and bilge waters according to these
procedures.
Bilge water volume may be reduced by the use of the Oily Water Separator (OWS), discharging
water with less than 15ppm into the sea, wherever this is permitted by International and National
Regulations.
In areas where discharge of bilge water is prohibited, the latter as well as any oil residues
accumulated onboard will be delivered to Port reception facilities.
Records of all operations must be made in Oil Record Book Part I & ³Oil Record Book Supplement´
Form.
Receipts from the shore receiving Companies, shall be kept together with the ORB, Part I.
2. PROCEDURE
2.1 BUNKERING TANKS CLEANING

The cleaning of Bunker Tanks must not be carried out within Port limits, unless permission has been
obtained from Port authorities.
Tank Cleaning must be carried out in such a manner so as to prevent emissions of hydrocarbon
vapours to the atmosphere. If tank vapours have to be vented, then prior to doing so, permission must
be obtained from Port authorities.
An entry is to be recorded in the Bridge logbook of such permission being granted, along with the
actual times of venting.
2.2 HANDLING OF OILY BILGE WATER AND SLUDGE IN THE ENGINE ROOM
The purpose is to describe the way to handle oily bilge water and sludges in the E/R, so that the
requirements of Annex I, MARPOL and National legislation are complied with.
Master The Master is jointly responsible with the C/E to apply these instructions and
avoid any illegal overboard discharges.
Chief Engineer The Chief Engineer is responsible to adhere to the efficient application of
these instructions and to inform the personnel working in the E/R accordingly.
He is responsible for all bilge pumping operations, which must never be carried
out without his personal approval. Written instructions relating to bilge
operations must be posted in the E/R adjacent to the OWS and in the Engine
Control Room (ECR) and signed by all Engineering Officers. He is also
responsible for properly maintaining the ORB.
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The following Terminology is used in order to describe this procedure:
Oily Bilge Water It means 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.
Oil Residue It means the residual waste oil products generated during the normal operation
(Sludge) of a ship such as those resulting from the purification of fuel or lubricating oil
for main or auxiliary machinery, separated waste oil from oil filtering
equipment, waste oil collected in drip trays, and waste hydraulic and lubricating
oils.
Oil Residue It means a tank which holds oil residue (sludge) from which sludge may be
(Sludge) Tank disposed directly through the standard discharge connection or any other
approved means of disposal. As oil residue / sludge tanks are considered those
listed in Section 3.1 of the Supplement of the Vessel¶s IOPP Certificate.
Oil Residue (Sludge) tank must be provided with a designated pump for
disposal that is capable of taking suction from it and must not have discharge
connections connected directly to the bilge piping system, oily bilge water
holding tanks, tank top or oily water separators.
Oily bilge Water It means a tank collecting oily bilge water prior to its discharge, transfer or
Holding Tank disposal. As oily bilge water holding tanks are considered those listed in
Section 3.3 of the Supplement of the Vessel¶s IOPP Certificate.
Oily bilge water can be handled in two ways:

x Collection in the holding tank and subsequent discharge to the shore reception facilities through
the standard connection. Collection and discharge is carried out by a designated bilge pump or by
an independent pump used exclusively for that purpose.
x Separation of oily bilge water using the OWS. The supply of equipment is carried out using its
integral pump. The suction of this pump is connected directly to the bilge lines or the holding
tank.
Any discharge of Oily Bilge Waters into the sea without the use of the OWS constitutes an
infringement of the requirements of MARPOL.
2.2.1 Oily Water Separator (OWS)

The OWS is of vital importance for the oil pollution prevention, and ensures that the oily bilge water
is separated effectively and any discharge is within the limits set by MARPOL Annex I.
The OWS is characterised as Environmental Critical Equipment.
The OWS is included in the PMS of each Vessel, ensuring that it is maintained and operated
according to the Maker¶s instructions and MARPOL Regulations and must remain fully operational
at all times.
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It must be also ensured that there is no method of by-passing OWS, as this is a breach of
Regulations. There must be no signs of such connection. Additionally, any other temporary
arrangements, such as hoses or anything else that may create the impression that illegal by-pass is
being used, are not allowed.
All the testing and operation details of the OWS must be recorded correctly in the ORB. For the test
of the OWS, the Officer of the Engine Watch (OOEW) must follow the ³OWS Testing / Operation
Standing Orders´ as follows.
1. The OWS is to be tested on a WEEKLY BASIS

2. If the test is to take place inside ports or special areas, the overboard valve will be kept closed
and the OWS will deliver inside the engine room only.

3. An entry must be made in the Oil Record Book Part I with the following data:
Date of test.
Position of Vessel.
Results of test.

4. Time and duration of test must be recorded in ³Oil Record Book Supplement´ Form.
5. At least the Chief Engineer and the OOEW must be present during the test. The Chief
Engineer will ensure that all Engineer Officers will participate on rotation.

6. Any malfunction is to be reported in the ORB, Part I (section F) and in the Engine Log Book
DQGUHSRUWHGWRWKH2IILFH
7. The weekly test must include at least the following:

a. Flush cell with oil free water.
b. Check zero-setting.
c. Clean the Oil Content Meter measuring cell.
d. Check the functioning of 15ppm alarm.
e. Perform / verify Oil Content Meter calibration.
8. Confirm alarms, 3-way valve and overall operation in good order. In order to ensure that
2:6LVXVHGRXWVLGHSURKLELWHGDUHDVUHTXHVWSHUPLVVLRQIURPWKH22%:EHIRUHXVH
The above standing Orders must be posted near the OWS.

The monthly OWS tests must be performed as per PMS instructions.
Before De-activating the Oily Water Separator, the relevant Risk Assessment A-11- must be referred
to and all the Hazards and Safety Control Measures must be taken into consideration.
A Critical Equipment De-activation / Re-activation Report (MTN/SECTION 1/SF/TEC134) has to be

prepared and submitted to office for approval prior to every De-activation of the OWS.
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2.2.2 Bilge main cross-connections

The use of cross connections between the bilge suction piping from E/R bilge wells/bilge tanks and
the suction of E/R pumps, other than the dedicated bilge pump, is strictly prohibited.
Connection of the Bilge Suction Piping to the Fire, General Service, Sea Water Cooling and Ballast
Pumps via existing Permanent Piping and Valves or via Temporary Hose Connections, intended to
facilitate the overboard discharge of Bilge Oily Water through Sea Water Overboard Valves,
is an illegal practice, equivalent to by-passing the OWS, it is contravening to the MARPOL
Regulations and it is strictly prohibited.
Dedicated emergency bilge suction valves shall be painted brightly.

A brightly colored sign with three inch letters shall be also permanently fixed nearby.
The sign text shall read: ³Emergency Bilge Suction ± Emergency Use Only´.
2.2.3 Overboard valves

All bilge pump overboard sealing valves must be kept closed and sealed with a numbered seal which
will break when the valve is operated.
This seal must be clearly marked with a "DO NOT OPERATE" tag.
All such valves must be clearly marked with the instruction ³This valve can only be opened when
duly authorised by the Chief Engineer and the Master.
All overboard discharge valves outside Engine Room are under the monitoring of Chief Officer and
must be clearly marked with the instruction ³This valve can only be opened when duly authorised by
the Chief Officer and the Master´.
In addition, a placard "Discharge of Oil Prohibited" must be located at the overboard valve.
At the time of sealing, the seal number and date must be logged in the form ³Oil Record Book
Supplement´ and also recorded in the ORB.
The above sealing/unsealing procedure is applicable to the Bilge Discharging Valves only, and
not to the Emergency Suction Valve.
All Sealed bilge valves must be operated open/close at least once every three months as per PMS.
The main emergency bilge suction valve must be opened up for inspection and overhauled, as
necessary, during major repairs period as per PMS.
Any pipelines leading overboard, which are inconsistent with requirements of safety or common
usage, must be blanked off and the valves locked closed.
The Office must be informed accordingly.
2.2.4 Oil to Sea Interface Management

Shipboard systems in which lube oil or hydraulic oil is isolated from sea water by a single
diaphragm, tubing or rubber seals are generally included in the oil to sea interface category.
In such machinery, there is always a certain risk of lube oil or hydraulic oil leakage to the Engine
Room sea water system or directly to sea, in case of damage to the isolating arrangement.
Such systems include oil lubricated stern tubes, bow or stern thrusters, stabilizers, hydraulically
operated controllable pitch propellers, lube oil or hydraulic oil coolers and similar equipment
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whereby the leakage of a sealing component may cause a loss of operating medium into the
surrounding waters of the Vessel.
Any replenishment of oil into the head tanks, operating systems reservoirs or other receivers
associated with this equipment shall be recorded in the Engine or Deck Log Book, as appropriate,
regardless of quantity.
Ingress of water or drainage of water into or from these systems must also be recorded.
When known, signed explanation of the loss shall be provided, along with dates and time.
Routine stern tube lube oil loss must be recorded in the Engine Log Book and reported to the
Company.
The Company recognizes that in certain cases, such as for leakage from stern tube aft seals, it is
difficult or even impossible to permanently rectify the leakage without taking the ship to a Dry-dock.
In such cases and depending on the time interval up to the scheduled dry-docking, leakage
minimization measures shall be planned. In extreme cases where the leakage cannot be fixed, causes
serious and continuous breach of MARPOL regulations or jeopardizes the ship¶s safety, the
Company¶s Management shall take necessary corrective actions including the ship stoppage and
arrangements for afloat or Dry-docking repairs.
Vessels that call US waters are subject to VGP requirements.

In accordance with VGP the oil used in oil to sea interface areas has to be Environmental friendly
(EAL type lubricant).
Furthermore, in Mooring Wires and Steering Gear Rudder Carrier Bearing, grease used must be of
Environmentally-friendly type.
The Company¶s Vessels shall not discharge Oily Bilge Waters with the use of the OWS, within the
VGP-covered waters.
2.2.5 Handling of oil sludges

The only way to dispose-off oil sludge is:
x By discharging to reception facilities through the standard discharge connections.
x By steaming
x By burning in the incinerator.
The Chief Engineer is responsible for the handling of sludge, including collection in the sludge
tank(s) and discharging to reception facilities.
Oily residuals handled as sludge include:
x Separated sludge, i.e. sludge resulting from purification of fuel and lubrication oil.
x Drain and leakage oil, i.e. oil resulting from drainage and leakages in machinery spaces.
x Exhausted oils i.e. exhausted lubricating oil, hydraulic oil or other hydrocarbon-based liquid
which is not suitable for further use in machinery due to deterioration/contamination.
Oil residues / sludge can never be mixed with the oily bilge water in the respective holding tank, with
the intention to be discharged overboard after separation and motoring via the OWS system.
Oily bilge water can, in principle, be mixed with oil residues in the sludge tank, but the whole
mixture shall be thereafter handled as oil residues / sludge and further discharging overboard via the
OWS is prohibited.
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According to Annex I of MARPOL it is forbidden for any piping to and from sludge tanks
to have direct connection overboard.
Therefore, there must be no interconnection between the sludge tank and any bilge pump with a
direct overboard connection.
The sludge pump must be independent, suitable for liquids with high viscosity and with no
interconnection with any other pump or tank.
Except from the sludge¶s discharge to the reception facilities, it is allowed to be burnt in an approved
type incinerator or a suitable combustion boiler.
All details of sludge control must be recorded in the ORB Part I.
2.2.6 Separation and discharging of E/R Oily Bilge Water using the OWS
The Chief Engineer is to be personally responsible for the operation of the pumping out of the oily
water from the Engine Room bilges through the OWS, when permitted.
Delegation of this task can be assigned to another Engineer Officer, only when the following
conditions are met:
x The Engineer Officer is thoroughly conversant with the operation of the equipment, including the
alarms, indications, system line up, layout and functioning of the system.
x The Engineer Officer has understood the relevant requirements of MARPOL and the IMS.
x The Chief Engineer and the Engineer Officer have conducted one to one training.
x The Engineer Officer has understood and signed the C/E's standing orders relating to the handling
of bilges.
Bilge water from the E/R bilge spaces is transferred to the waste holding tanks or bilge tanks. The
bilges may be discharged at sea only if separated / filtered through the OWS, ensuring an oil content
of 15 ppm or less.
The maximum capacity, associated sounding and ullage of each tank used for bilge waste or sludge
must be clearly posted in the E/R or the ECR. If any of these tanks are fitted with a high level alarm
or indicator, then the sounding and capacity at which this alarm or indicator is activated must be
clearly identified.
Daily sounding of above tanks must be taken and recorded in ³Oil Record Book Supplement´ Form.
The Company¶s policy is that every discharge operation is carried out during DAYLIGHT HOURS
only and after the Master¶s permission.
Furthermore, Form SF/TEC/143-³OWS Operation Authorization Request´ must be prepared and
submitted to the Office for approval, prior to every discharge.
Prior to commencing the discharging operation:

x An OWS alarm test must be performed and recorded in ORB Part I and ³Oil Record Book
Supplement´ Form.
x The Officer of the Bridge Watch (OOBW) must be advised and the position of the ship relative to
land must be ascertained.
Operation to be confirmed by Master and Master or Chief Officer to be present at the
commencement and at completion of the discharge.
x The Chief Engineer must record the ship's position in the ORB.
x The OOBW to record the position in the Bridge logbook.
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x Interface of oil/water in the bilge tank is to be taken and recorded in the E/R logbook.
x Seals to be temporarily removed and process to be properly recorded in ³Oil Record Book
Supplement´ Form.
x Interlock system (which does not permit starting of the OWS unless the OOEW puts the switch to
the ON position), if fitted, must be used.
During the operation of pumping out bilges through the 15 ppm monitor, the following checks are to
be carried out:
x Check for the correct operation of the equipment. If in doubt, stop and investigate.
x Every half hour, effluent sample through the monitor to be visually checked for clarity.
x Relevant entries in the ORB must include the time and date and be initialled by the C/E or, if
authorized so by the Chief Engineer, by the Officer in charge of the bilge operations.
x At least every half hour, the OOBW to check aft for any signs of pollution (oil/soot).
x Interface of oil/water is to be monitored and discharge to be stopped with sufficient safety
margin.
On completion of the operation:
x Stop the pump and secure all valves.
x Seals to be re-fitted and process to be properly recorded in ³Oil Record Book Supplement´ Form.
x Overboard valve to be locked with chain and padlock and key to be kept in C/E¶s custody and a
notice to be placed stating that it must not be opened without C/E¶s permission. Relevant seal
must be placed and relevant entry must be made in ORB Part I and ³Oil Record Book
Supplement´ Form
x Inform the OOBW and take the ship's position.
x Interface of oil/water in the bilge tank is to be taken and recorded in the E/R logbook.
x The Chief Engineer must record the ship's position in the ORB.
x The OOBW to record the ship's position in the Bridge logbook.
At the change of watch in the E/R, all operations are to be stopped. When re-starting, all procedures
must be followed as detailed in this section.
The usually small quantities of final residues which remain, must be manually transferred to the
incinerator, discharged directly to a shore reception facility, or retained in the holding tank for
eventual disposal ashore. In the latter case, prior to transfer starting, the OOEW must verify that there
is sufficient ullage in the holding tank.
Waste oil disposal shall be carefully documented and the Chief Engineer is responsible to record any
shore disposal process in the ORB.
Additionally, the signed receipt for waste oil disposal is to be attached to the relevant page of the
ORB.
All details of oil mixture control must be recorded. Entries shall include the quantity and type of any
oily mixture disposed and/or burnt into the incinerator.
It is noted that local regulations may apply in the process of oil mixture disposal. It is the Master¶s
and Chief Engineer¶s responsibility to be prepared and comply with them accordingly.
On UMS ships, where the bilge pump is operating in automatic mode, the level in the tanks must be
checked during the final inspection of the E/R each day. There must be sufficient space for any
volume likely to be pumped during the night.
Prior to arrival in port, the level in bilge holding tanks must be lowered in accordance with the
instructions in this section.
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This is to make space for bilges that may be generated during port stay.
Any pump which can be connected to the bilge piping system and used for the emergency discharge
of the E/R bilges must be clearly identified.
Its starter box must be marked with the instruction:
³This pump can only be connected to the Bilge System,

when duly authorised by the Chief Engineer´.
ȃote 1: In an emergency situation, shipboard personnel must be able to pump from the bilges
directly overboard, as provided for by SOLAS and MARPOL.
Such overboard valves must be sealed but not locked.
ȃote 2: Any malfunction and/or operating problem encountered in the oily bilge water treatment
system must be immediately reported to the Company and recorded in the ORB.
ȃote 3: The oily bilge water to be discharged via the OWS must not originate from cargo pump-
room bilges.
ȃote 4: The oily bilge water to be discharged via the OWS must not be mixed with oil cargo
residues.
ȃote 5: The OWS must never be left operating, when the Vessel is transmitting from manned
E/R mode to UMS mode.
Furthermore the sample line from the OWS discharge connection to the sample/flush line control
valve must be painted a bright color to distinguish it from other tubing and piping in the area.
The line must be routed so it is clearly visible to the extent possible for its entire length.
No additional connections or tees of any kind may be added to the line.
All pipe flanges in the bilge / sludge piping system must be painted by orange color and be sealed.
Seals must be included in Form SF/TEC /135C- ³Bilge Suction/Discharge Valves Flanges Seals
Identification Register.
On all managed ships, the OCM requires a sample flow for a normal operation and control. Any Oil
Content Monitor (OCM) that allows the OWS to function normally without sample flow is
prohibited.
On all managed Vessels, the OWS is configured to be capable of being fully operationally tested in
port with the skin valve closed.
Together with the tests of the OWS (as per the OWS Testing / Operation Standing Orders), monthly
operational tests of the OWS and the OCM must be carried out as per PMS.
The Chief Engineer must witness and certify the test by signature in the E/R logbook and in the ORB.
The test must document the performance of the OWS and OCM without dilution at the OWS inlet,
storage tank or tricking of the OCM.
The cleaning of the OWS source tank and removing of any accumulated oil must be carried out.
These activities will be also logged in the Engine Log logbook and in the ORB.
Any uncontrolled discharge of oil into the sea is definitely prohibited, without exemptions.
Discharge of oily bilge water into the sea while the ship is within special areas
Special Areas are geographical areas, particularly sensitive from environmental aspect, as defined in
MARPOL Annex I.
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Any discharge into the sea of oily water from a ship while in a special area is prohibited, except
when all the following conditions are satisfied:
x The ship is proceeding enroute;
x Discharge is taking place during daylight hours and under the supervision of the C/E or an E/R
Officer;
x The oil content of the undiluted effluent does not exceed 15 ppm;
x The oily bilge water is processed through an oil filtering equipment ensuring that any oily bilge
water discharged into the sea has an oil content not exceeding 15 ppm and provided with alarm
arrangements to indicate when the level of 15 ppm cannot be maintained; also the filtering system
is equipped with a stopping device which ensures that the discharge is automatically stopped
when the oil content of the effluent exceeds 15ppm.
x The Oily mixture does not originate from Cargo Pump-room Bilges on Oil Tankers.
x The Oily mixture, in case of Oil Tankers, is not mixed with oil Cargo residue.
Discharge must be duly recorded in the ORB.
Especially in the Antarctic area any discharge into the sea of oily water from any ship is prohibited.
Discharge of oily bilge water into the sea outside special areas
Criteria for Discharge
Any discharge into the sea of oily water from a ship outside special areas is prohibited, except when
all the following conditions are satisfied:
x The ship is proceeding enroute;
x Discharge is taking place during daylight hours and under the supervision of the C/E or an
E/R Officer;
x The oil content of the undiluted effluent does not exceed 15 ppm;
x The ship has in operation the oil filtering equipment ensuring that any oily bilge water
discharged into the sea after passing through the system has an oil content not exceeding 15
ppm; especially any ship of 10,000 tons gross tonnage and above shall be provided with oil
filtering equipment, and with arrangements for an alarm and for automatically stopping any
discharge of oily bilge water when the oil content in the effluent exceeds 15ppm.
x The Oily mixture does not originate from Cargo Pump-room Bilges on Oil Tankers.
x The Oily mixture, in case of Oil Tankers, is not mixed with oil Cargo residue.
All discharges through the OWS must be duly recorded in the ORB Part I.
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2.2.7 Discharge of E/R oil and oily water to shore facilities

For the disposal of oil and oily water to shore facilities, the following guidance is applied:
x The Chief Engineer will decide for the disposal of oil, oily water and sludges generated in the
E/R, taking into account the capacity of relevant tanks and the daily generation of oil water-
sludges.
x The disposal of oily waste is carried out from the relevant tanks (holding tank and sludge tank)
and never directly from the bilge well. Only in cases that the ship is under repair, the disposal
directly from the bilge well may be permitted.
x The disposal of oily waste shall take place only to authorised reception facilities. The disposal is
to be carefully documented with signed receipts obtained from the person responsible of the
reception facilities. The signed receipt is to be attached to the relevant page in the ORB.
x The disposal shall take place only through the international standard connections.
x The use of hoses with a direct suction from the relevant tanks is not permitted.
All hoses in use in Engine Room must be recorded in the monthly Form ³Hose Inspection List´,
where their tags and use have to be recorded.
The purpose of this form is to control the use of hoses in engine room and preclude the possibility of
any illegal activity.
If during a Superintendent¶s attendance an undeclared hose is found, it becomes automatically
suspicious.
The same applies if hoses with oil traces are found although not declared for this use. Again
disciplinary actions will be implemented.
2.3 HANDLING OF SLOPS

Slops which result from any cargo or ballast operation, tank cleaning, line washing or flushing,
machinery operation, repair preparation, etc. must never be directly discharged to sea and must be
retained in the slop tanks.
Decanting the contents of slop tanks is only permitted in accordance with this section.
The Chief Officer is responsible for the conduct of all Slop Tank decanting operations.
The decanting of slop tanks is prohibited in special areas, as defined in MARPOL Annex I.
Slop oil and water must be consolidated in slop tanks. Any water underneath the slops must be
carefully and slowly decanted via the Oil Discharge Monitor (ODME).
This decanting must also be monitored by the slop tank oil/water interface detector.
The separation of oil and water may be enhanced by controlled heating of the slop tank contents.
Decanting of slops to sea must only be carried out when:
x ODME and control system is operational and in use and slop tank arrangement is available, as
required by MARPOL Annex I.
x Vessel is NOT in a special area, as defined by MARPOL Annex I.
x Vessel is more than 50 nautical mile from the nearest land / baseline, as defined by MARPOL.
x Vessel is proceeding enroute; this broadly means the Vessel to proceed to its intended destination
(next port), self-propelled and at a minimum speed capable in producing wake.
x The instantaneous rate of discharge of oil content does NOT exceed 30 litres per nautical mile.
x Total quantity of oil discharge into the sea must NOT exceed 1/30000 of the total quantity of the
particular cargo of which the residue formed a part.
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Slops decanting to sea must be carried out only during DAYLIGHT HOURS
and only after Master¶s permission.
If for any reason the operation cannot be performed during daylight, permission must be obtained
from the Company.
An ODME Operation Authorization Request Permit (SF/TEC/144) has to be prepared and submitted
to office for approval prior to every discharge.
When a Vessel is loaded, the Decanting Operation is permitted

only following approval by the Operations Department.
Prior to commencing operations, the interface between oil and water must be established by using the
oil water interface detectors.
International Chamber of Shipping along with OCIMF have published ³Clean seas Guide for Oil
Tankers´ in order to increase awareness of Seafarer in the handling of Oily-water mixtures.
Decanting of the slop tank contents is a critical operation.
Hence the timing of the various steps in the operation is important. Even a short delay in stopping a
pump or closing a valve can allow a significant quantity of oil to escape into the sea. As with dirty
ballast, the time required for oil and water to separate in the slop tank depends upon the motion of the
ship as well as on the type of previous cargo.
Below is a recommendation for settling time of oily ± water mixtures in Slops prior decanting.
Under favorable conditions a few hours may be enough, but longer periods are desirable. It is
recommended in most circumstances, 36 hours or more must be allowed.
Before starting discharge an accurate interface and ullage reading must be taken to determine the
depth of the oil layer.
The interface profile may vary over several inches in depth. Hence, discharge from the tank must
cease well before the measured interface is reached to avoid discharge of any oil-in-water emulsion
overboard.
Although every effort must be made to remove as much water as possible from the slop tank, the
prime objective is to prevent oily water reaching the sea.
Extreme care is therefore necessary, and the overboard discharge must be closely checked.
If the Thirty Six (36) hours settling period cannot be kept, Vessels¶ Masters must ensure that
following have to be carried out prior commencement of discharge:
x oil water interface to be checked (sufficient water sounding to be ensured)
x Sample to be drawn near tank¶s bottom and sample cleanliness to be confirmed
x Ensure that RA C-19 is carried out
In case of ODME malfunction and decanting is necessary, company shall ensure the following:
x Flag Administrator has been informed, dispensation letter has been issued and a copy is
maintained onboard the ship for the duration of its validity, and all instructions provided
within message and notification are understood and adhered to by the Master and crew.
x Procedures as described in Marine Notices¶ provisions issued by the Flag Administrator for
ODMCS failure and while performing manual decanting are strictly followed.
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x The ODME failure is noted in the Vessel's log books and Oil Record Book.
x Decanting in manual mode takes place only during day light without exemptions, with
constant monitoring of water quality which is discharged overboard, with low discharge rate
and with all necessary calculations basing on pump specifications, Vessel¶s speed, sounding
by UTI, etc., as required by Regulations.
Furthermore:
x oil water interface to be checked (sufficient water sounding to be ensured)
x Sample to be drawn near tank¶s bottom and sample cleanliness to be confirmed.
x Ensure that RA A-11 & C-19 are carried out.
The tank ullage/sounding must be closely monitored throughout the operations and pumping must be
slowed to avoid vortex effect, as this interface is approached.
The final contents of a slop tank must always be retained onboard. In the case of product ships, the
slops will usually be discharged to a shore facility.
In the case of crude oil ships, the slops will usually be incorporated into the ³load on top´ operation,
although sometimes they may have to be kept segregated, pending Company¶s instructions?
In case of ship proceeding to shipyard, the final de-slopping operation will be arranged by the
Company and Master will be advised accordingly.
Ships operations must be planned with a view to minimising slops.
However, this requirement must never be accomplished at the cost of increased risk of pollution.
Any malfunction and/or operating problem encountered with the oil discharge monitoring and control
system must be immediately reported to the Company and recorded in the ORB Part II.
The ODME is characterised as Environmental Critical Equipment.
Before the de-activation of the ODME, the relevant Risk Assessment A-11 must be referred to
and all the Hazards and Control Measures, must be taken into consideration.

prepared and submitted to office for approval prior to every De-activation of ODME.
2.4 BILGE, SLUDGE AND SLOP MANAGEMENT RECORD KEEPING

The system of records regarding details of all cargo, ballast, bunker, tank cleaning, slop handling,
E/R bilge and sludge management and the persons responsible for record keeping are described in
this paragraph.
The purpose of these records is to facilitate monitoring of the bilge and sludge quantities generated,
transferred and processed onboard as well as the quantities transferred ashore.
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2.4.1 Oil Record Book Part I and Part II

Details of all cargo, ballast, STS operations, tank cleaning, slop handling and engine room bilge
transfer to slop/cargo tank operations must be recorded in the Cargo Oil Record Book (Part II) in
accordance with the instructions contained in the front cover of that book.
Details of all bunker loading, bulk lube oil loading and engine room bilge handling operations must
be recorded in the Oil Record Book (Part I) in accordance with the instructions contained in the front
cover of that book.
In addition, any OWS or monitoring and control equipment system tests, including the proper
functioning of the 3-way or re-circulating valves, monitoring and/or recording devices and alarms
and/or automatic shutdown features must be recorded in the ORB Part I, in ³Oil Record Book
Supplement´ Form and the PMS, as appropriate.
Also malfunctioning of OWS or ODME must be recorded in the ORB, as appropriate.
Attention must be paid to ensuring that at all times, ullages/soundings, quantities of water/oil, tank
contents after completion of bilge transfer operations, and the Vessel¶s positions are accurately
entered, where required.
The Chief Officer is responsible for maintaining the deck ORB (Part II) and the Chief Engineer is
responsible for maintaining the Engine Room ORB (Part I). Each page of the ORB, Part I shall be
signed by the Chief Engineer and the Master.
Each page of the ORB, Part II shall be signed the Master.
Entries shall be made in accordance with the MARPOL requirements and the instructions provided
inside these books.
All entries shall be made in indelible ink.
Corrections shall be carried out by striking through.
They must also get signed and dated. The strike through shall not degrade the readability of the
wrong entry.
No corrector fluids are allowed.
Attention must be paid to ensuring that at all times quantities and positions are accurately entered,
where these are required.
The ORBs constitutes for the Company very significant evidence in order to ensure that the ship
complies with the present instructions and the operational requirements of MARPOL.
The ORBs must be retained onboard for THREE (3) YEARS from the date of the last entry.
In order to ensure compliance with the Regulations the Company requires:

a. Copy of Oil Record Book (ORB) to be submitted to the office on weekly basis for review and
comments. A continuous dialogue between the Vessels¶ Masters, Officers and Office is thus
established, contributing to the effort to avoid mistakes and improve compliance level. The
submission of ORB is supplemented by the submission of three Company¶s forms namely -
FORM SF/TEC/135 A-B-C.
b. The purpose of submitting Form 135A with bilge / sludge Tanks soundings is to cross check tank
contents with ORB and the accuracy of recordings / calculations.
It is to be made clear that 135A must be the single electronic sounding log that exists
onboard. No other electronic log is allowed.
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In case draft hand written tank measurement records / logs are kept on board (in addition to form
TEC 135A), the draft records / logs have to be scanned on a daily basis and sent to office by e-
mail. The tanks concerned are the ones mentioned on IOPP Form B paragraphs (3.1 and 3.3).
In the body of the weekly message of ORB reporting it must be declared whether the Vessel¶s
Officers keeps draft measurements of IOPP tanks content.
c. The submission of Form 135B allows office to have access to the memory of OWS and cross
check the actual disposal times with the recordings made on ORB.
It has to be mentioned that all events recorded in OWS memory have to be recorded in the
Form, including bilge transfer to Holding Tank, recirculation, transfer between Tanks etc.
A relevant note explaining the activity involved has to be inserted in 135B under the column
³Status´.
d. Form SF/TEC/135C provides information on the seals that are placed on the bilge / sludge
pipeline. A plasticised drawing indicating each seal number together with form 135C must be
placed nearby OWS.
Anytime that a seal has to be removed for maintenance purposes, the office has to be informed
beforehand, appropriate entries have to be made on ORB and TEC135C has to be updated
accordingly.
2.4.2 Bilge and Sludge receipts

Whenever bilge and sludge quantities are delivered to shore reception facilities, a receipt must be
requested by the Master, stating the date / time of the transfer and the quantities delivered ashore.
2.4.3 Oil Content Meter (OCM) Calibration Log

The OCM must be calibrated periodically in accordance to the makers¶ instructions and flag specific
requirements.
A file must be maintained onboard and ashore, in which the documentation from the calibrations and
the calibration certificates, issued in case the calibration is carried out by the maker or an external
contractor, will be kept.
This OCM Calibration must be arranged in shore facilities.
2.4.4 Engine logbook

The following additional entries shall be made to the Engine Room Logbook:
A. Extraordinary operations related to the Bunker and E/R F.O and L.O tanks
Reports of abnormally frequent draining of FO service and settling tanks and engine LO sump
tanks of excessive water or other problems i.e. waxing, stratification, incompatibility, etc.
Each entry shall contain records of the problem commencement and resolving dates, the treatment
followed to correct it and the procedures followed to handle the unburned bilge and sludge
residues, oils, oily wastes, etc. produced during the treatment.
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B. Unintended/accidental release of water, F.O and L.O from any E/R machinery:
Anytime any line or component on a fuel, luboil, or waste oil system fails, including high pressure
lines on diesel engines or due to an operational error, a record shall be made as to the quantity
released and an explanation given as to how the unintended released fluid was handled.
Any unintended releases of quantities of water, salt, fresh, condensate or cooling shall also be
recorded.
3. RECORD
Critical Equipment De-activation // Re-activation Report MTN/SECTION 1/SF/TEC134
/ Re-activation Report
x Oil Record Book Supplement EMS/SECTION 3/SF/TEC/135
x OWS Operation Authorization Request Permit EMS /SECTION 3/SF/TEC/143
x ODME Operation Authorization Request Permit EMS/SECTION 3/SF/TEC144

x De-activation of Oily Water Separator A-11
x De-activation of ODME A-11
x Discharge of oily water through ODME C-1
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COMPLIANCE WITH MARPOL IV Eff. Date: 29/02/2020
Contents
1. PURPOSE.....................................................................................................................................2
2. PROCEDURE...............................................................................................................................2
2.1 Requirements for Sewage Discharge........................................................................................ 2
2.2 Sewage Treatment Plant Operation and Maintenance.............................................................. 4
2.3 Sewage Holding Tank............................................................................................................... 5
2.4 Procedure for Sewage Holding Tank........................................................................................ 5
2.5 Prevention Measures................................................................................................................. 6
2.6 Grey Water................................................................................................................................ 7
3. RECORD...................................................................................................................................... 8
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1. PURPOSE
Sewage from ships shall be treated and disposed in accordance with the provisions of MARPOL,
Annex IV.
The Company¶s Vessels Sewage Discharge Equipment and procedures are in full compliance with
Annex IV, IMO Resolution MEPC 157(55), IMO Resolution, MEPC 159(55) and any applicable
National requirements.
The purpose of this section is to describe the procedures for sewage treatment that must be followed.
2. PROCEDURE
Master The Master is responsible to ensure that the sewage treatment is performed in
accordance with these instructions. He is also responsible to comply with the
criteria defined in Annex IV referring to the discharge of sewage into the sea.
Chief Engineer The Chief Engineer is responsible for the efficient operation of the Sewage
Treatment Plant (STP).
³Sewage´ refers to:

x Drainage and other wastes from any form of toilets and urinals;
x Drainage from medical premises (dispensary, sick bay, etc.) via wash basins, wash tubs and
scuppers located in such premises;
x Drainage from spaces containing living animals; or
x Other waste waters when mixed with the drainages defined above.
2.1 REQUIREMENTS FOR SEWAGE DISCHARGE

The following table summarises the MARPOL requirements concerning discharge of sewage:
DISTANCE SHIP¶S
SEWAGE STATUS DISCHARGE POSSIBILITY OR CAPACITY
FROM LAND SPEED
Sewage stored in holding tanks shall not

Sewage not comminuted or
12 miles >4knots be discharged instantaneously but at a
disinfected from a holding tank
moderate rate when ship is en route
Sewage stored in holding tanks shall not

Sewage comminuted and
3 miles >4knots be discharged instantaneously but at a
disinfected from a holding tank
moderate rate when ship is en route
From holding tank and a sewage The effluent shall not produce visible
No No
approved Sewage Treatment floating solids nor cause discoloration of
restrictions restrictions
Plant (STP) the surrounding water
Especially in California, Vessels of over 300 GRT cannot discharge any treated or untreated sewage
contained in a holding tank and generated prior to entry of California waters, inside 3 NM of the
State of California.
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In the above context, sewage can only be unrestrictedly discharged into the sea if STP is in use.
If this is not applicable, sewage must be retained onboard and collected in a holding tank, and only
discharged subject to the above restrictions.
If no Holding Tank is available and the Vessel calls to ports where untreated sewage/grey-water
discharge overboard is prohibited, the Company has to be advised and Flag Administration to be
contacted in order to grant approval for temporary use of a tank designated to store sewage/grey
water onboard during the specific port call.
According to Resolution MEPC.157 (55), the maximum permissible discharge rate for sewage is
1/200,000 (or one 200,000th part) of swept volume, calculated as per the following formula:
DRmax = 0.00926 VDB, where:

DRmax is maximum permissible discharge rate (m3/h)
V is ship¶s average speed (knots) over the period
D is Draft (m)
B is Breadth (m)
The maximum permissible discharge rate specified above, refers to the average rate as calculated
over any 24 hour period, or the period of discharge if that is less, and may be exceeded by no more
than 20% when measured on an hourly basis.
The Administration may approve the above rate of discharge specified in MARPOL based upon the
ship¶s maximum summer draft and maximum service speed. Where sewage is to be discharged at a
different combination of draft and speed, one or more secondary discharge rates may also be
approved as per the above formula, formatting a combination matrix as per the below table compiled
for an example Breadth of 20m:
DISCHARGE RATE (m3/h)
SPEED (kt) 4 6 8 10 12
DRAFT (m)
5 4.63 6.94 9.26 11.57 13.89
6 5.56 8.33 11.11 13.89 16.67
7 6.48 9.72 12.96 16.20 19.45
8 7.41 11.11 14.82 18.52 22.22
9 8.33 12.50 16.67 20.83 25.00
When the ship is situated in waters under the jurisdiction of a State and is going to discharge sewage
in accordance with less stringent requirements than those imposed by such State, then the discharge
into the sea shall be prohibited.
When the sewage is mixed with wastes or waste water having different discharge requirements, the
more stringent requirement shall apply.
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According to some National requirements, the discharge of sewage is not allowed when the ship is in
their port or within their territorial waters. In this case, National and Local regulations shall be
followed.
Environmental Protection Agency (EPA) and the Clean Water Act (CWA), the centerpiece of federal
legislation addressing pollution, are followed in U.S. waters. Under section 312 of the CWA, Vessel
sewage may be controlled through the establishment of areas in which discharges of sewage from
Vessels are not allowed. These areas are also known as "no-discharge zones" (NDZs).
A no-discharge zone is an area in which both treated and untreated sewage discharges from Vessels
are prohibited. Within NDZ boundaries, Vessel operators are required to retain their sewage
discharges onboard for discharge at sea (beyond three miles from shore) or onshore at a pump-out
facility.
However, the EPA made allowances in some regions:
For Vessels without blackwater storage tanks discharge using an approved sewage treatment plant
may be continued.
x For Vessels with blackwater storage tanks, but with small capacity or for a port call where the
storage capacity is exceeded, the ship can resume discharging through the sewage treatment
plant.
The condition is that the blackwater storage tanks must be empty before entering the no-discharge
zones and must be filled to extent possible before switching back to the Sewage Treatment Plant.
2.2 SEWAGE TREATMENT PLANT OPERATION AND MAINTENANCE

The STP must be operated and maintained according to the manufacturer¶s instructions. Records of
maintenance and/or repair are to be maintained.
The manufacturer¶s restriction on materials which may be disposed of through the sewage treatment
system are to be clearly displayed at each input point.
The disinfectant dosing points must be readily accessible.
The Sewage Treatment Plant is characterised as Environmental Critical Equipment.
Before De-activating the Sewage Treatment Plant, the relevant Risk Assessment A-11- must be
referred to and all the Hazards and Safety Control Measures must be taken into consideration.

prepared and submitted to office for approval prior to every De-activation of STP.
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2.3 SEWAGE HOLDING TANK

In case the Vessel is equipped with a sewage holding tank in lieu of the STP, the former must be of
sufficient capacity to hold the generated black and/or grey water for the maximum time the Vessel is
normally expected to sail within the limits where discharge is prohibited.
The holding tank is to be constructed to the satisfaction of the Administration and have means to
indicate visually the amount of its contents.
Its capacity is to comply with the following formula:
Cr A Np Da, where
Cr: capacity of the holding tank (m3)
A: 0.06 (m3/person/day); the value of A may be reduced according to flushing system etc.
Np: the total number of persons on board
Da: the maximum number of days operating in areas where the discharge of sewage which is
not comminuted or disinfected into the sea is prohibited (minimum 1 day).
The Vessels¶ Flag Administrations may have their own capacity requirements.
The holding tank must be equipped with a high level alarm and flushing line or other equipment
according to the requirements of the Vessels¶ Flag State.
The tank must also be connected with a pump capable of delivering the tank contents to a shore
connection and subsequently to shore reception facilities.
To enable pipes of port reception facilities to be connected with the ship¶s discharge pipeline, both
shall be fitted with a standard discharge connection in accordance with specifications defined in
MARPOL Annex IV.
The Chief Engineer must keep records of discharge at sea operations and the receipts of discharging
to shore facilities.
2.4 PROCEDURE FOR SEWAGE HOLDING TANK

The following procedure is to be implemented when the Vessel is fitted with Holding Tank:
x Prior entering 12 nautical miles from the nearest land, discharge pump of the sewage plant shall
be stopped and secured for non-operation;
x The sewage overboard discharge valve shall be securely locked in closed position;
x The Holding Tank shall be emptied at least six hours prior to entering the 12 nautical miles as per
Vessel¶s position given from the bridge;
x All sewage generated during Vessel¶s staying within 12 nautical miles from the nearest land, shall
be collected in the Holding Tank;
x The level of the sewage in the Holding Tank shall be monitored by a designated Engineering
Officer, however the Holding Tank has sufficient capacity for normal use over a number of days;
x Overboard discharging of sewage shall be only commenced out of 12 nautical miles from nearest
land with confirmation from the bridge for Vessel¶s position and when the Vessel shall reach the
speed of more than 6 knots;
x Discharge shall be made at a moderate rate;
x Holding Tank is to be flushed with water periodically;
x Preventive maintenance of all equipment shall be carried out as per company¶s PMS and
manufacturer¶s instructions.
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General Clean-up procedures:

x Indoor clean up procedures involve cleaning the area thoroughly and the application of a
chemical disinfectant over the affected area.
x Fans and natural ventilation must be used to assist in drying the area to prevent mould growth.
x All items unable to be hygienically cleaned by a professional must be disposed of appropriately.
x Please note that some ships may become uninhabitable for the duration of the clean-up procedure.
x Thoroughly wash down affected areas on decks with clean water and apply an appropriate
chemical disinfectant over these areas.
x General procedures for absorbent material:
Absorbent material such as carpets, rugs, upholstered furniture that has come into contact with
sewage must be removed and replaced to prevent the growth of microorganisms.
x General procedures for hard surfaces:
All hard surfaces must be thoroughly cleaned with clean hot water and detergent, and then
appropriately disinfected. All items must then be thoroughly dried.
x Preventing mould growth:
Mould growth after a sewage overflow may occur as a result of excess moisture in materials.
Mould is likely to grow if materials stay wet. In order to prevent mould from growing it is
important to ensure all materials exposed to sewage are thoroughly cleaned, disinfected and
allowed to dry, or disposed in accordance with port requirements.
It is extremely important to keep the area well ventilated following the event to assist in drying.
Windows, doors and hatches must be kept open. Fans must be used to assist in the drying process.
2.5 PREVENTION MEASURES

Simple measures to prevent accidental spills from sewage overflows include:
x Maintaining the sewage treatment system and the macerator at regular intervals in accordance
with the treatment system service manual and the manufacturer¶s instructions.
x Ensure that the sewage system is tested at regular intervals, as per Manufacturer¶s
recommendations and that the system¶s service records are kept on board at all times.
x Ensure sewage is regularly discharged, taking always in consideration the restrictions.
x For ships fitted with sewage holding tanks, the tank discharge valves and the overboard valves
must be sealed and a log to be maintained when sewage is discharged (recording Vessel¶s
position, speed etc. as required by Marpol). Entries to be made in the Engine log book. The 3-
way valve leading sewage directly overboard (or if there are two separate valves, one leading
sewage overboard and the other leading sewage to the holding tank) must also be sealed.
Precautions to reduce the risk of exposure to sewage with sewage overflow clean-up procedures:
x Where sewage overflows or spills occur, the contaminated area must be isolated and access must
be restricted.
x Unprotected persons must leave the affected area until the area has been thoroughly cleaned and
disinfected.
x Persons involved in the clean- up procedure must wear personal protective clothing such as
overalls, rubber boots, disposable gloves or washable rubber gloves and facial protection (if there
is a risk of splashing). Ensure cuts are covered with a water resistant dressing.
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x Clean the hose and the affected area using water and detergent, followed by disinfectant.
Chemical disinfectants are used to destroy or prevent the growth of disease-causing micro-
organisms.
x Other precautions may include:

o Assume anything touched by sewage is contaminated.
o Wash your hands and affected areas of the body thoroughly with clean warm water and soap,
especially before eating or smoking. An adequate number of hand washing amenities must be
provided in a suitable location. These must be maintained in a hygienic condition and include
running water, liquid soap and disposable paper towels (not communal cloth towels).
o Immediately wash and disinfect any wounds that come into contact with sewage. This may
reduce the likelihood of skin infections.
o Change out of dirty clothes and wash clothes separately as soon as possible.
o Clean and dry dirty footwear.
o Request medical attention if any illness is experienced.
2.6 GREY WATER
Grey water is defined as the drainage from dishwater, shower, laundry, bath & washbasin drains.
It does NOT include drainage from toilets, urinals, hospitals & animal spaces as defined in
regulation 1(3) of Annex IV, as well as drainage from cargo spaces.
Grey water discharges can also contain bacteria, pathogens, oil & grease, detergent & soap
residues, metals (e.g. cadmium, chromium, lead copper, zinc, silver, nickel & mercury), solids &
nutrients (USEPA, 2008B; USEPA 2010).
Thus, their discharge in near-shore marine environments could cause negative environmental
impacts.
The company follows all the International & Local Regulations regarding Grey water discharges.
Especially, for Vessels operating in U.S. waters, the company follows the discharge regulations
of EPA¶s Clean Water Act (CWA) Section 301 of National Pollutant Discharge Elimination
System (NPDES) Program.
On December 19, 2008, EPA issued the VGP to provide NPDES permit coverage for Vessel
discharges incidental to normal operation from commercial Vessels greater than 79 feet into
waters of the United States.
The EPA reissued the 2013 VGP on April 12, 2013 with an effective period of December 19,
2013 to December 18, 2018 (i.e., five years). The VGP provided NPDES permit coverage
nationwide for discharges incidental to the normal operation of commercial Vessels greater than
79 feet in length.
All definitions and regulations of 2013 are consistent with 2008 VGP.
However, the Vessel Incidental Discharge Act (³VIDA´) legislation, signed into law on
December 4, 2018, established a new framework for the regulation of Vessel incidental
discharges under Clean Water Act (CWA) Section 312(p). VIDA requires EPA to develop
performance standards for those discharges within two years of enactment and requires the U.S.
Coast Guard to develop implementation, compliance, and enforcement regulations within two
years of EPA¶s promulgation of standards.
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In conclusion, VIDA legislation extends the 2013 VGP¶s provisions, leaving them in effect until
new regulations are final and enforceable.
The company also tries to follow the several best management practices (BMPs) that EPA
includes in the 2008 VGP when practicable & achievable for the control of grey water impacts
(USEPA 2008a), such as the minimization of the production of grey water while in port.
Moreover, the company implements an environmental program (EP-7) regarding the sewage &
grey water discharges with emphasis to the new buildings.
Please refer to Environmental Program (EP-7) and to the stand-alone ship-specific Vessel
General Permit.
3. RECORD
x Critical Equipment De-activation MTN/SECTION 1/SF/TEC134

x De-activation of Sewage Treatment Plant A-11
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COMPLIANCE WITH MARPOL V Eff. Date: 29/02/2020
Contents
1. PURPOSE.....................................................................................................................................2
2. PROCEDURE...............................................................................................................................2
2.1 General...................................................................................................................................... 2
2.2 Garbage Disposal Regulations.................................................................................................. 3
2.3 Designated Environmental Control Officer & Nominated Crew.............................................. 4
2.4 Garbage Record Book and Entries............................................................................................ 5
2.5 Disposal of Cooking Oil............................................................................................................5
2.6 Disposal of Waste to Reception Facilities.................................................................................6
2.6.1 Responsibilities for Disposal of Waste to Reception Facilities............................................. 6
2.7 Training..................................................................................................................................... 7
2.8 PURCHASING & SUPPLYING PROCEDURES................................................................... 7
3. RECORD...................................................................................................................................... 7
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1. PURPOSE
The purpose of these instructions is to describe the procedures that must be followed for the handling
and disposal of garbage, in compliance with the requirements of Annex V of MARPOL.
Reference is made to Garbage Management Plan (Booklet) (Form SF/MRS/213) and the relevant
procedure in Section 05A±³Garbage Management´ of this Manual.
2. PROCEDURE
2.1 GENERAL
Every Company ship shall carry a Garbage Management Plan (GMP) which provides instructions
for collecting, segregating, storing, processing, disposing and minimizing garbage, including the use
of the equipment on board.
The procedures cover all garbage generated during normal ship operation, except those substances
which are defined or listed in other Annexes of MARPOL, such Annex I and II.
In this respect the procedures cover:
x Food Wastes ( comminuted or not comminuted)
x Plastics
x Domestic Wastes (paper products, rags, glass, bottles, crockery and similar, as well as
floating dunnage, lining and packing materials )
x Cooking Oil
x Incinerator ASHES
x Solid Operational Wastes
o scraped paint,
o sand,
o deck sweeping,
o rust/scale debris,
o large metal objects such as oil drums and old machinery components ,
o ropes made of wire , synthetic or natural fibre etc )
o Oils, greases and waste rags contaminated with oil.
o Paint and painting materials
x Liquid Operational Wastes
o Chemicals, Refrigerants, cleaning agents, chemicals
x Engine Room Cleaning Chemicals.
(Please also refer to Maintenance Manual / Section 02/par.2.7.10- Use of Detergents in the
Engine Room)
x Fishing Gear
x Special Wastes (Pyrotechnics, batteries)
x Medical Wastes
x Cargo residues & Cargo associated wastes.
x E-wastes
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The Company¶s Policy on this matter is fully aligned with the MARPOL, Annex V requirements, as
revised by all relevant MEPC and any other applicable National regulations.
Separate garbage categories must be stored in separate containers onboard and disposal must be
carried out as per the Annex V requirements.
2.2 GARBAGE DISPOSAL REGULATIONS

Garbage disposal is subject to restrictions imposed by MARPOL Annex V, as per the following
matrix:
Offshore platforms located
Ships within special more than 12 nm from
Type of garbage Ships outside special areas
areas land) and all ships within
500 m of such platforms
Discharge permitted
Discharge permitted
t12 nm from the
Food waste comminuted t3 nm from the nearest
nearest land, en Discharge permitted
or ground land, en route and as
route and as far as
far as practicable
practicable
Discharge permitted
Food waste not
t12 nm from the nearest
comminuted or Discharge prohibited Discharge prohibited
land, en route and as
ground
far as practicable
Cargo residues*1 not
contained in wash Discharge prohibited Discharge prohibited
water
Discharge permitted
Discharge permitted
t12 nm from the
t12 nm from the nearest
nearest land , en
Cargo residues*1 land , en route and as
route ,as far as
contained in wash far as practicable Discharge prohibited
practicable and
water
subject to two
additional
conditions*2
Discharge permitted
t12 nm from the
Cleaning agents and nearest land, en
additives *1 route, as far as
Discharge prohibited
contained in cargo practicable and
hold wash water subject to two
Discharge permitted
additional
conditions *2
Cleaning agents and
additives *1 in deck
Discharge permitted Discharge prohibited
and external surfaces
wash water
Carcasses of animals Discharge permitted
carried on board as as far from the nearest
Discharge prohibited Discharge prohibited
cargo and which died land as possible and en
during the voyage route
Table continuing on next page
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Table continuing from previous page
Offshore platforms located

more than 12 nm from
Ships within special
Type of garbage Ships outside special areas land) and all ships
areas
within 500 m of such
platforms
All other garbage
including plastics,
synthetic ropes,
fishing gear, plastic
garbage bags,
incinerator ashes,
clinkers, cooking oil,
floating dunnage,
lining and packing
Discharge prohibited Discharge prohibited Discharge prohibited
materials, paper,
rags, glass, metal,
bottles, crockery and
similar refuse,
e-Waste
and Sludges from Bunker
Tanks further to
cleaning for IMO 2020
preparations
When garbage is mixed with or contaminated by other substances prohibited from discharge
Mixed garbage
or having different discharge requirements, the more stringent requirements shall apply
1. *1 These substances must not be harmful to the marine environment.

2. *2 According to regulation 6.1.2 MARPOL Annex V the discharge shall only be allowed if:
(a) both the port of departure and the next port of destination are within the special area and the
ship will not transit outside the special area between these ports;
and
(b) if no adequate reception facilities are available at these ports.
Company Vessels do NOT incinerate Plastics.
2.3 DESIGNATED ENVIRONMENTAL CONTROL OFFICER & NOMINATED CREW

A designated person on board shall be in charge of carrying the GMP procedures.
The Chief Engineer is the Environmental Control Officer.

He is the designated person, responsible for the implementation of the Garbage Management
Plan, as per MARPOL Annex V requirements.
All crew shall provide support which is necessary in the collection, separation and processing of the
garbage.
Some crew are designated specific duties, relevant to the implementation of the Garbage
Management Plan.
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These are clearly stated in Table 4-³Nominated Crew and Responsibilities for implementing the
Garbage Management Plan´ (Booklet)´ (refer to SF/MRS/213-³Garbage Management Plan´.
(Booklet)´).
Furthermore, display placards are positioned to notify the crew, visitors and supernumeraries of the
disposal requirements prescribed in Annex V for garbage disposal within and outside special areas.
2.4 GARBAGE RECORD BOOK AND ENTRIES

A Garbage Record Book (GRB) must also be maintained onboard.
Each discharge operation, including landing to shore for disposal, or completed incineration shall be
recorded in the Garbage Record Book and signed on the date of the incineration or discharge by the
Officer in charge. The Master shall sign each completed page of the GRB.
The Garbage Record Book shall be kept onboard for two (2) years after the last entry is made and
must be made readily available for inspection.
In the event of discharge, escape or accidental loss as referred to in ³Exceptions of MARPOL-

Annex V´ an entry shall be made in the Garbage Record Book of the circumstances of and the
reasons for the loss.
The Vessel¶s Garbage Management Plan must contain a list of the Vessel¶s garbage disposal
equipment, which must be attached to the Garbage Record Book.
Maintenance wastes contaminated with substances such as oil or toxic chemicals are in some cases
controlled under other MARPOL Annexes or other pollution control laws.
Company minimizes the use of chemicals, cleaners and detergents for various shipboard applications.
Also, environmentally friendly chemicals, cleaners, detergents and thinners are considered and
preferred when available.
In such cases, the more stringent disposal requirements take precedence.
The Company / Purchasing Department, in an effort to minimise the generation of waste, will review
the following provisioning practices with Vessel¶s suppliers in order to determine the optimum
packaging for the products:
x Reusable packaging and use of containers, disposable cups, utensils, dishes, towels and rags and
other convenience items must be limited and replaced by washable items when possible.
x Where practical options exist, provisions packaged in or made of materials other than disposable
plastic must be selected to replenish Vessel¶s supplies, unless a reusable plastic alternative is
available.
2.5 DISPOSAL OF COOKING OIL

As per Annex V of MARPOL, since 1st January 2013 the disposal of cooking oil is prohibited. So, as
per our Company¶s policy there are two ways to treat Cooking Oil:
1) Delivery to Shore Facilities
(an entry in the Garbage Record Book under category ³D´ must be made).
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2) Incineration
The cooking oil must be disposed to the tank leading directly to the incinerator (an entry
under code ³I´ in the ORB and also an entry in the Garbage Record Book under category ³D´
must be made).
2.6 DISPOSAL OF WASTE TO RECEPTION FACILITIES
2.6.1 RESPONSIBILITIES FOR DISPOSAL OF WASTE TO RECEPTION FACILITIES

The Master The Master is responsible for planning /
supervising the disposal of waste and
garbage to reception facilities. In case of
lack or inadequacy of reception facilities, it
is under his responsibility to inform the
Company and report to the port authority
accordingly.
The Chief The Chief Engineer is the Environmental
Engineer Control Officer.
He is responsible for the implementation of
the Garbage Management Plan, as per
revised Marpol Annex V requirements and
is also responsible for the disposal of oily
bilge water and sludge generated in the E/R.
Disposal needs must be identified, particularly when arrangements are necessary for garbage
requiring special handling.
The Master must ascertain as clearly as possible, the Final Destination and Disposal Method, of any
garbage landed.
The Garbage Record Book contains many references to the estimated amount of garbage.
It is recognised that the accuracy of estimating amounts of garbage is left to interpretation.
Volume estimates will differ before and after processing.
Some processing procedures may not allow for a usable estimate of volume, e.g. the continuous
processing of food waste.
Such factors must be taken into consideration when making and interpreting entries made.
The Master must obtain from the Port Reception facilities or from the Vessel receiving the garbage, a
receipt or certificate specifying the estimated amount of garbage transferred
If practicable, a receipt must be requested from the final destination (i.e. land fill site, incinerator, etc)
of the garbage landed, in order to provide a ³continuous tracking record´.
The amount of garbage onboard must be estimated in cubic metres (m3), if possible separately
according to category.
The Receipts or Certificates must be kept onboard with the Garbage Record Book for two (2) years.
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2.7 TRAINING
Training must be provided for all crew members involved in operating the garbage processing
equipment as well as in collecting, handling and disposing of garbage.
Material for training could include Seagull Training CDs, Posters, Brochures, and Photographs.
Newsletter Articles, Video Tapes etc.
2.8 PURCHASING & SUPPLYING PROCEDURES

The company applies waste reduction methods such as purchasing and supplying in bulk to reduce
packaging volumes. Also, it encourages recycling initiatives by promoting actions such as the
packaging material to be from environmentally friendly, recycled or re-used materials. Use of non-
disposable equipment, bio-disposable materials and returning packaging material to the deliverer at
the time of the delivery are also considered, as available.
Moreover, an Approved Supplier List is being monitored and updated with all available ISO Standard
Certifications such as ISO 14001, ISO 18011 and ISO 9001.
Reference is also made in 002-PRO-Procedures / PROC 08_PURCHASING-4.
3. RECORD
Garbage Management Plan (Booklet) SOM/SECTION 09/ SF/MRS/213
Garbage Management Plan- Placard 1 - English SOM/SECTION 09/ SF/MRS/212A
Garbage Management Plan-Placard 2 - English SOM/SECTION 09/ SF/MRS/212B
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Prime Tanker Management Inc. SECTION 05A
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GARBAGE MANAGEMENT Eff. Date: 29/02/2020
Contents
1. PURPOSE.....................................................................................................................................2
2. PROCEDURE...............................................................................................................................2
2.1 General Rules for Garbage Management onboard Company Vessels...................................... 2
2.2 Garbage Management Plan....................................................................................................... 3
2.3 Designated Persons in Charge of Carrying out the Plan........................................................... 3
2.4 Shipboard Responsibilities for implementing the Garbage Management Plan.........................3
2.5 Garbage Management Activities............................................................................................... 4
2.6 Garbage Categories (As applicable to company Vessels) & Color Code................................. 4
2.7 Garbage Collection /Segregation /Storage................................................................................ 5
2.8 Hazardous Materials and Special Wastes..................................................................................6
2.8.1 Hazardous Materials (HM) /Hazardous Waste...................................................................... 6
2.8.2 Rags, Mops and Sorbents.......................................................................................................6
2.8.3 Solvents.................................................................................................................................. 6
2.8.4 Batteries................................................................................................................................. 6
2.9 Medical Waste........................................................................................................................... 7
2.10 Placards, Garbage Management Plans (Marpol Annex V - Regulation 10).......................... 7
2.10 Garbage Record Book (Marpol Annex V- Regulation 10).................................................... 8
2.11 Receipts for Disposing Garbage to Shore Facilities.............................................................. 8
2.12 Training of Shipboard Personnel in Garbage Management...................................................9
3. RECORD...................................................................................................................................... 9
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1. PURPOSE
This section describes the procedures for the Collection, Segregation, Storage, Processing and
Disposal of garbage, in compliance with the relevant MARPOL Regulations.
This procedure includes general guidelines.
The Company¶s Garbage Management Plan (Form SF/MRS/213) includes detailed guidance and
instructions. It must be reviewed and be made Ship-Specific and be maintained updated at all times.
2. PROCEDURE
This procedure is based on the Revised MARPOL requirements listed below:
MARPOL ANNEX V-Regulations 1-10

Amendments to the Annex of the Protocol of 1978 relating to the
MEPC.201 (62)
International Conventions for the prevention of Pollution from Ships, 1973-
Revised MARPOL Annex V (entry into force in January 1, 2013)
Amendments to MARPOL Annexes I, II, IV, and V±making the use of
MEPC.265 (68)
environment-related provisions of the Polar Code mandatory´
(entry into force January 1, 2017)
MEPC.264 (68) International Code for Ships operating in Polar Water (Polar Code )
(entry into force January 1, 2017)
Amendments to MARPOL Annex V
MEPC.277 (70)
(HME substances and Form of Garbage Record Book )
(entry into force March 1, 2018)
MARPOL ANNEX VI
Regulation 16 ³Regulations for the prevention of Air Pollution from Ships concerning
Shipboard Incineration´.
2.1 GENERAL RULES FOR GARBAGE MANAGEMENT ONBOARD COMPANY VESSELS
Company Vessels may discharge at sea FOOD WASTES ONLY.
Company Vessels DO NOT INCINERATE PLASTICS.
Company Vessels DO NOT SAIL IN POLAR WATERS.
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2.2 GARBAGE MANAGEMENT PLAN

As per Marpol Annex V-Regulation 10- 10.2- Every ship of 100 gross tonnage and above which is
certified to carry 15 or more persons shall carry a Garbage Management Plan.
The Company has developed a Garbage Management Plan based on the guidelines developed by the
Organization i.e MEPC/Circ.317-Annex-³Guidelines for the development of Garbage Management
Plans´.
The Company¶s Garbage Management Plan, consists of the following forms:
SF/MRS/213- Garbage Management Plan Booklet
SF/MRS/212A- Summary of at sea Garbage Disposal Regulations
(English and Russian) ±PLACARD 1
SF/MRS/212B-Shipboard Garbage Management Plan (English and Russian) - PLACARD 2
The Garbage Management Plan Booklet (Form SF/MRS/213) must be made Ship-Specific i.e
-The Name of the Vessel must be recorded on the Cover page
-The Tables 1-6 must be filled in with Ship Specific information
o Table 1- Location and Color of the Garbage Storage Receptacles at the Main Garbage Storage
Location
o Table 2- Ship Specific Minimum Total Capacity of Storage Receptacles
o Table 3- List of Primary Garbage Collection Containers
o Table 4-Nominated Crew and Responsibilities for implementing the Garbage Management Plan
o Table 5- Garbage Processing Equipment
o Table 6- Garbage Storage Room (if available onboard )
Usually, the Garbage Management Plan of the Vessel does not require Class Approval.
However, if the Vessel has an Environmental Notation e.g ABS ENVIRO, the Ship Specific Garbage
Management Plan must be Class Approved.
2.3 DESIGNATED PERSONS IN CHARGE OF CARRYING OUT THE PLAN
The Designated person in charge of Carrying out the Garbage Management Plan is the
CHIEF ENGINEER/Environmental Control Officer.
2.4 SHIPBOARD RESPONSIBILITIES FOR IMPLEMENTING THE GARBAGE MANAGEMENT PLAN

The Shipboard Personnel who have been assigned specific responsibilities for implementing the
Garbage Management Plan are the following:
x Master
x Chief Engineer /Environmental Control Officer
x Second Engineer
x Bosun
x Cook
x Messman
x Other Shipboard Personnel assisting the Chief Engineer
x Heads of Shipboard Departments
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The duties of the shipboard personnel are detailed in the Garbage Management Plan Booklet
(SF/MRS/213) -in Chapter 2,³Shipboard Responsibilities´ and in
Table 4-³Nominated Crew and Responsibilities for implementing the Garbage Management Plan´.
2.5 GARBAGE MANAGEMENT ACTIVITIES

To achieve an environmentally sound and cost-effective Garbage Management, the Company has
adopted a combination of four (4) complementary activities to manage garbage:
x Garbage Minimization / Garbage Compaction x Processing/ Incineration
x Collection/ Segregation x Disposal
x Storage
Procedures for the above activities are found in the Garbage Management Plan (SF/MRS/213) as
follows:
Chapter 4-³Garbage Minimization /Garbage Chapter 8-³Garbage Storing´
Compaction
Chapter 5-³Garbage Categories´ Chapter 9-³Garbage Processing´
(as applicable on Company Vessels)
Chapter 6-³Color Code of Receptacles´ Chapter 10-³Garbage Disposal´
Chapter 7-³Garbage Collection /Segregation Chapter 11-³Disposal Requirements of Wastes´
2.6 GARBAGE CATEGORIES (AS APPLICABLE TO COMPANY VESSELS) & COLOR CODE
CATEGORY COLOUR DESCRIPTION

CODE
Discharge into the Sea is PERMITTED
1. B WHITE Food Wastes
Discharge into the Sea is PROHIBITED
2. A RED Plastics
BLUE Domestic Wastes -Floating Dunnage, Lining & Packing Materials
3. C GREEN Domestic Wastes -Paper Products, Rags, Glass, Metal, Bottles ,
Crockery etc
4. D YELLOW Cooking Oil
5. E BLACK Iincinerator Ashes
6. F BROWN Solid Operational Wastes-chipping, scraped paint, sand, deck sweeping
7. H GREY Fishing Gear
8. I PURPLE E-waste
IN SLOP Liquid Operational Wastes, Cleaning Agents & Additives
TANKS * to be transferred to Slops Tanks for disposal to Shore Facilities
as per Marpol Annex I& II
9. F
IN SLOP Cargo Residues ( in Liquid Operational Wastes)
TANKS * to be transferred to Slops Tanks for disposal to Shore Facilities
as per Marpol Annex I & II
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Each component must be evaluated separately to determine the best waste management practice for
that waste, always in compliance with the MARPOL Regulations.
The following Categories are NOT applicable on Company Vessels:
G Animal Carcasses ( This is not Applicable on our Company Vessels
since they do not carry animals as ³Cargo´)
J CArgo Residues (Non- HME) ( Non Harmful to the Marine Environment )
K Cargo Residues (HME) ( Harmful to the Marine Environment )
2.7 GARBAGE COLLECTION /SEGREGATION /STORAGE

Garbage must be collected, segregated, store, processed and disposed as per Ship Specific Garbage
Management Plan and Marpol Annex V Regulations 1-10 i.e. landing to shore reception facilities,
Incineration, Discharge over-side.
Garbage must initially be stored in Primary Garbage Collection containers and emptied into the Main
Garbage Storage Receptacles, located at the Poop Deck or elsewhere (i.e dedicated Garbage Storage
Room, if available onboard).
The location of the Containers and Receptacles are listed in the Ship-Specific Section of Garbage
Management Plan (Form SF/MRS/213) i.e
o Table 1- Location and Color of the Garbage Storage Receptacles at the Main Garbage
Storage Location
o Table 3- List of Primary Garbage Collection Containers
The Garbage Receptacles must be made of steel or other non-combustible materials with no openings
in the sides or bottom. (Solas 2004 II-2/4.42).
Each receptacle must have a metallic lid.
The receptacles may be cans, bins etc and must be clearly identified either by colour, graphics, shape
or location, to indicate their use.
The Main Garbage Storage Receptacles must be covered, leak proof and inside the railings.
Primary Garbage Collection Containers in each area must be checked / emptied to the Main
Garbage Receptacles as follows :
x Food Wastes Every Day
x Other Garbage Every Second day
The storage of each Category of wastes must be carried out as per the instructions of the Garbage
Management Plan ± Chapter 8.
Particular consideration must be given to the storage of garbage that is designated as ³Special
Waste´, such as: Batteries, Sensors and Fluorescent Tubes.
At all times, the adequacy of Main Garbage Storage Receptacles must be evaluated, taking into
account the number of persons on board and the Vessel¶s trading pattern ( i.e voyage days).
In must always be kept in mind that the Main Garbage Storage receptacles must be sufficient for a
maximum period of storage equal to twenty (20) days.
Each Vessel must calculate the total capacity and record this in the Garbage Management Plan ±
Table 2-³Ship Specific Minimum Total Capacity of Storage Receptacles´.
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2.8 HAZARDOUS MATERIALS AND SPECIAL WASTES
2.8.1 HAZARDOUS MATERIALS (HM) /HAZARDOUS WASTE

Instructions on the control, storage, inventory and proper management and disposal of Hazardous
Material, are found in the Environmental Manual (09)±Section 08-³Miscellaneous Pollution
Sources´.
2.8.2 RAGS, MOPS AND SORBENTS

Rags, mop heads and sorbents used to clean up Hazardous Material spills shall themselves be treated
as used /excess HM.
These must be collected and stowed in tightly sealed steel containers to prevent release of toxic or
hazardous vapors into the ship spaces.
To avoid creation of fire hazards, rags and sorbents that contain dissimilar or incompatible
used/excess HM shall be stored in different containers.
Reference is made to Environmental Manual (09) ±Section 08-³Miscellaneous Pollution Sources´-

2.8.3 SOLVENTS
Various shipboard solvents (for example, acetone, and toluene) evaporate during use, leaving no used
/ excess HM except the rag or cloth contaminated during use.
Some solvents, however, evaporate slowly (for example, ethylene glycol, and xylene) and leave
substantial amounts of liquid material. Shipboard personnel shall follow appropriate disposal
guidelines when discarding these spent solvents. Chlorinated and non-chlorinated solvents (and
anything they have contaminated) shall be kept in separate containers.
Reference is made to Section 08-³Miscellaneous Pollution Sources´, of this Manual.
2.8.4 BATTERIES
Prevent the discharge of spent batteries into the marine environment. If not properly disposed of,
spent batteries may constitute a hazardous waste stream.
Spent batteries are collected and returned for recycling and/or disposal in accordance with Garbage
Management Plan requirements.
Discarded batteries are isolated from the refuse waste stream to prevent potentially toxic materials
from inappropriate disposal.
The wet-cell battery-recycling program is kept separate from the dry battery collection process.
Intact wet-cell batteries are sent back to the supplier. Dry-cell batteries are manifested to a licensed
firm for recycling.
Before storing used or discharged batteries prior to disposal/recycling, it is important to adhere to the
following procedures:
x Tape the positive terminals with electrical tape.
x In the case of 9-volt batteries, reuse the plastic insulating caps that snap onto the battery
terminals.
x Place the spent batteries back into their original packaging; make sure to keep positive and
negative terminals away from each other.
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x It is important not to store new and discharged batteries together, so use a separate plastic or
cardboard container to store your used-up batteries.
x Mark this storage container ³Ready for Disposal/Recycle.´
Again find a dry, cool location to store these spent batteries, but one that is a bit out of the way and
not so readily available.
There are many types of batteries, but basically only three disposal options as follows: alkaline and
rechargeable alkaline, nickel metal hydride, and carbon zinc.
These must be taken to the nearest hazardous waste collection site ashore.
Reference to the Environmental Manual (09 ±Section 08-³Miscellaneous Pollution Sources´-
).
2.9 MEDICAL WASTE

The discharge of medical waste is described below:
x Infectious medical waste shall be steam sterilized, suitably packaged, and stored for disposal
ashore. Autoclaving is the only currently approved method to treat shipboard infectious medical
waste.
x Sharps shall be collected in plastic sharps¶ containers.
Never recap, clip, cut, bend, or otherwise mutilate needles or syringes to avoid causing
accidental puncture wounds and infectious aerosols.
All sharps shall be retained on board for proper disposal ashore.
Unused sharps shall be disposed of ashore in the same manner as medical waste:
x Plastic and wet materials shall not be incinerated.
x Liquid wastes may be disposed of by discharging into the sanitary system.
x Non-infectious medical waste may be disposed of as trash and does not require steam sterilizing
or special handling
x Shore based management shall provide the required services for disposal of medical waste
generated by ships and ensure that disposal ashore is in compliance with applicable laws or
regulations.
It is the responsibility of all Masters to ensure that no medical materials are disposed of in a manner
that may pose a risk to public health and welfare or the marine environment
Reference is made to Environmental Manual (09) ±Section 08-³Miscellaneous Pollution Sources´-
.
2.10 PLACARDS, GARBAGE MANAGEMENT PLANS (MARPOL ANNEX V - REGULATION 10)

$VSHU0DUSRO$QQH[95HJXODWLRQEvery ship of 12m and more in length overall must
display Placards, which notify the crew of the Disposal Requirements of Regulations 3 4, 5 & 5 of
Marpol Annex V, (and section 5.2 of Part 5 II-A of the Polar Code) written in the Official and the
Working Language of the Vessel.
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The Company has issued the following Placards (which consist part of the Company¶s Garbage
Management Plan:
x PLACARD 1-SF/MRS/212A- Summary of at sea Garbage Disposal Regulations
(English & Russian)
x PLACARD 2-SF/MRS/212B- Shipboard Garbage Management Plan (English & Russian)
Placards must be posted in conspicuous places i.e. In the Galley, Messrooms, Corridors, and at the
Main Garbage Storage Location (i.e Poop Deck and/or Garbage Storage Room etc).
2.10 GARBAGE RECORD BOOK (MARPOL ANNEX V- REGULATION 10)

Every Vessel of 400+ gross tonnage and every Vessel, which is certified to carry 15 persons or more,
shall be provided with a Garbage Record Book, in which all discharge operations and incinerations
must be recorded.
The Garbage Record Book must be in the form specific in the Appendix II of Marpol Annex V.
As per Revised Marpol Annex V, the new Form of the Garbage Record Book consists of two (2)
Parts:
PART I: will be for the use of ALL Ships
PART II: will only be required for ships that carry solid bulk cargoes
Only Garbage Record Book±PART I, is applicable on Company Vessels
Each entry must be signed-for on the date of the discharge or incineration or discharge by the
Officer in Charge.
Each Completed Page must be countersigned by the Master.
All entries in the Garbage Record Book on Company Vessels must be in English.
The Garbage Record Book must be preserved onboard for a period of two (2) years
after the last entry is made in the record.
2.11 RECEIPTS FOR DISPOSING GARBAGE TO SHORE FACILITIES
The Master must obtain from the Port Reception Facilities Representative/Operator, or from the
Master of the Ship receiving the garbage, a receipt or certificate specifying the estimated amount of
garbage transferred.
The Receipts or Certificates must be kept on board the Ship
with the Garbage Record Book for two (2) years.
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2.12 TRAINING OF SHIPBOARD PERSONNEL IN GARBAGE MANAGEMENT

All joining Crew must be provided with an onboard familiarization on the Marpol Annex V
Regulations and on the Ship Specific Garbage Management Plan
(Location of Garbage Receptacles, Color Code of each category, frequency of Garbage Collection
etc).
This Familiarization is recorded in the IMS Form SF/CRW/505 ³Job Familiarization-General
Training Record´.
Periodical Training (every 4 months) is carried out on the Garbage Management Plan and is recorded
on the following IMS Forms:
x SF/CRW/507-³Extra Training Record´
x SF/SAQ/416-³Record of Drills performed and Other Training´
Contractors¶ Staff and 3RD Party Visitors are also familiarized with the Company¶s Garbage
Management Plan through dedicated Familiarization Checklists i.e.:
x SF/CRW/506C-³ Contractors Safety Familiarization Record ´
x SF/CRW/506V-³Visitors Safety Familiarization´
x SF/CRW/917- ³Armed Guards Safety and Security Familiarization Record´
Additionally, the Garbage Management Plan must be periodically discussed during

Safety Meetings (under Item # 13 ±Environmental Issues) including instructions on:
x The duties of the Environmental Control Officer (Chief Engineer )
x The duties and responsibilities of the other Officers and Crew
x Known sources and categories of garbage
x The impact of plastic debris on sea environment
x Incineration procedures & prohibitions
x The potential effects on ship operations in case of Garbage pollution.
x The potential effects on ship operations in case of Air Pollution
3. RECORD
x Summary of at Sea Garbage Disposal Regulations-Placard 1 SOM/SECTION 9/ SF/MRS/212A
x Shipboard Garbage Management-Placard 2 SOM/SECTION 9/ SF/MRS/212B
x Shipboard Garbage Management Plan (booklet) SOM/SECTION 9/ SF/MRS/213
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COMPLIANCE WITH MARPOL VI Eff. Date: 29/02/2020
Contents
1. PURPOSE.....................................................................................................................................2
2. PROCEDURE...............................................................................................................................2
2.1 General Procedure..................................................................................................................... 2
2.2 Reduction of NOx Emissions.................................................................................................... 2
2.2.1 Engine Certification and Survey Requirements.............................................................................................. 3
2.2.2 Procedure for Engine New Installations or Replacements..............................................................................4
2.2.3 Maintaining the Engines According to NOx Regulation Requirements......................................................... 4
2.2.4 NOx Emission Control Areas (ECAs)............................................................................................................ 5
2.3 Reduction of SOx Emissions and particular Matter.................................................................. 5
2.3.1 Facilitating Sulphur Inspection....................................................................................................................... 7
2.4 Guidelines for using SOx Scrubber Systems............................................................................. 8
2.4.1 Introduction..................................................................................................................................................... 8
2.4.2 Open and Close-Loop Systems........................................................................................................................ 8
2.4.3 Responsibilities................................................................................................................................................9
2.4.4 Operation of the System.................................................................................................................................. 9
2.4.5 Safety Precautions......................................................................................................................................... 10
2.4.6 Bunkering of Alkali Solutions (when applicable)..........................................................................................10
2.5 Carbon Emissions....................................................................................................................11
2.5.1 IMO Data Collection Systems (DCS).................................................................................................................. 11
2.6 Control of Emissions of Shipboard Ozone Depleting Substances (ODS)...............................12
2.6.1 European Union Requirements............................................................................................ 13
2.6.2 Leak Detection Procedure.................................................................................................14
2.7 Control of Emissions Produced by Shipboard Waste and Garbage Incineration....................16
2.8 Control of Cargo Vapour Emissions....................................................................................... 17
2.9 Volatile Organic Compound (VOC) Emissions...................................................................... 18
2.10 Control of Other Shipboard Emissions................................................................................ 18
2.10.1 Funnel Smoke................................................................................................................................................18
2.10.2 Inert Gas........................................................................................................................................................ 18
2.10.3 Crude Oil Wash............................................................................................................................................. 19
2.10.4 Vapour Balancing...............................................................................................................................................19
2.10.5 Vapour Compression..........................................................................................................................................19
2.10.6 Pressure Calculation........................................................................................................................................... 20
2.10.7 Authority to Conduct Operation.........................................................................................................................21
2.10.8 Emergency..........................................................................................................................................................21
2.10.9 Gauging and Sampling....................................................................................................................................... 21
3. RECORD.................................................................................................................................... 21
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1. PURPOSE
The scope of these procedures is to ensure that all effluents and aerial emissions shall be at least
within permitted levels (refer to MARPOL and National/regional limitations). In order to ensure that
the shipboard operations will be carried out according to these requirements with respect to the
measures for limitation of air pollution, the Company has developed and follows for each Vessel a
SEEMP with guidelines for compliance with MARPOL Annex VI. The purpose of this section is to
describe the procedures that must be followed for the control of aerial emissions and the limitation of
air pollution.
Reference is made to the stand-alone ship specific Ship Energy Efficiency Management Plan
(SEEMP) and the Bunkering Procedure of the Shipboard Operations Manual.
2. PROCEDURE
2.1 GENERAL PROCEDURE

The Chief Engineer is responsible for the proper maintenance of main engines and auxiliary
machinery equipment in order to improve their performance and reduce air pollution.
The Engineers must closely monitor the engine exhaust by ensuring:
x Optimum burn of fuels.
x The Vessel¶s plant is operated to minimize emission of smoke.
For that purpose the following must be complied with:

x All internal combustion engines must be made to function, as far as possible, under a load
corresponding to peak efficiency.
x The C/E shall monitor the performance of the main and auxiliary engines and make all necessary
adjustments so as to minimize their emissions to the air.
x For each voyage, the Technical Department must calculate the fuel consumption and compare the
new values with the old ones, to ascertain the possible need for hull cleaning.
x Soot blowing must be done prior arrival and avoided in port.
x When initially starting the main engine a watch must be kept and the E/R notified if smoke or
sparks are evident.
x If an occasion arises where an unavoidable emission of dark smoke is foreseen, prior notice must
be given to the Port Authorities, whenever possible, etc.
2.2 REDUCTION OF NOX EMISSIONS

All Vessels with engines installed onboard on or after 1/1/2000 with power output more than 130kW
have to comply with the NOx regulation.
This regulation applies also on older engines, installed onboard prior to 1/1/2000 but which undergo
a major conversion after this date.
A major conversion is any conversion involving modification of engine systems and components that
affect the engine¶s NOx emissions, or increase the engine MCR more than 10%.
These requirements do not apply to engines installed onboard and used solely in case of an
emergency (emergency generator, lifeboat engines, etc). For engines affected by the NOx regulation,
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there are NOx emission limits imposed, calculated as the total weighed emission of NOx, dependent
on the engine crankshaft RPM, as follows:
Ship Total weighted cycle emission limit (g/kWh)

Tier construction date n = engine¶s rated speed (rpm)
on or after n < 130 n = 130 - 1999 n 2000
45 x n(-0.2)
I 1 January 2000 17.0 9.8
e.g., 720 rpm ± 12.1
44 x n(-0.23)
II 1 January 2011 14.4 7.7
e.g., 720 rpm ± 9.7
9 x n(-0.2)
III 1 January 2016 3.4 2.0
e.g., 720 rpm ± 2.4
2.2.1 Engine Certification and Survey Requirements

Each engine installed onboard after the 1/1/2000 and required to comply with the NOx Technical
Code shall be certified by an Engine International Air Pollution Prevention Certificate (EIAPP),
issued by the ship¶s Class or Flag Administration, and a ³Technical File´ provided by the engine
manufacturer.
This Certificate is a statement of compliance supplemented by the engine Technical File, which is
also provided by the manufacturer and approved by the ship¶s Class or Flag Administration.
The engine Technical File contains the identification of all originally installed components and
settings which affect NOx emissions.
The Technical File for all engines affected by MARPOL Annex VI Regulation about NOx must
remain onboard the Vessel throughout their operating life.
Whenever engine components or settings mentioned in the Technical File are replaced or adjusted,
this action including spares particulars and settings values must be recorded in the ³Record Book of
Engine Parameters´ attached to the engine Technical File.
Each Vessel is also provided with an International Air Pollution Prevention Certificate (IAPP), which
remains valid only if the engine compliance with NOx regulation is validated at every IAPP survey.
To ensure engines compliance with the NOx regulation, an inspection method shall be employed by
Class surveyors, as prescribed in the NOx Technical Code.
The method employed is the ³Engine Parameter Check´ method, which is based on checking the
following:
x The EIAPP certificate is available for each engine.
x The engine NOx emission affecting components, as detailed in the Technical File, are maintained
in good condition.
x Components replacement complies with the Technical File requirements and is recorded in the
³Record Book of Engine Parameters´.
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x The engine settings affecting NOx emissions are maintained within the limits detailed in the
Technical File, and any adjustments are recorded in the ³Record Book of Engine Parameters´.
x Inspection of engine components included in the Technical File, as per the ³Onboard Verification
Procedure´ attached to the Technical File. This means that engine stripping down will be required
to the extent prescribed by the ³Onboard Verification Procedure´ and the surveyor¶s
requirements.
Since the ³Engine Parameter Check´ is an indirect method (as opposed to direct methods which
involve direct measurements of engine NOx emissions during operation), the following additional
documents must become available to the surveyor for examination:
x Engine logbook parameter records (mainly exhaust gas temperatures, but also fuel, lub oil,
cooling water and charge air temperatures and pressures).
x Records / diagrams of compression and combustion pressures.
To summarize, each engine subject to the NOx regulation must comply with the emission limits
imposed throughout the operating life.
Therefore, engine components and settings prescribed in the Technical File cannot be arbitrarily
changed during maintenance.
Any changes to components and/or settings shall conform to the specifications of the engine¶s
approved Technical File to ensure continuous compliance of the engine emissions with the NOx
regulation limits.
2.2.2 Procedure for Engine New Installations or Replacements

The following procedures present the basic steps to be followed for ensuring compliance with the
NOx regulation, when new engines are installed onboard, or existing engines are completely replaced
by other units:
x Assess if the engine characteristics (power, RPM, intended duty) fall within the NOx emissions
requirements. Remember that the NOx regulation applies to engines more than 130kW, which are
not solely used in emergency situations.
x During the engine selection process, ensure that the manufacturers provide the EIAPP Certificate
for the models considered.
x Verify that the engine will comply with the NOx regulation when delivered, without the need for
modification or installation of additional components or systems at a later stage.
x Verify that the EIAPP provided is acceptable by the Vessel¶s Class Society.
x During the final installation process verify that the components installed correspond to the
specifications presented in the Technical File. Correct components can be identified by the ID
numbers carved on them and written in the Technical File. These shall be identical.
2.2.3 Maintaining the Engines According to NOx Regulation Requirements

Ensuring that engine components and settings comply with the Technical File prescription is the
condition that indirectly guarantees the engine compliance with the NOx emission limits.
x The Chief Engineer must ensure that operational parameters logged at regular intervals
(temperatures and pressures) are within the manufacturer specified limits. Whenever sudden
changes arise he must identify the cause of the change and rectify the malfunctions. In case of a
complicated problem he must inform the Company and ask for external assistance. Basic critical
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parameters indicating deviations from normal operation are exhaust gas temperatures, charge air
temperature & pressure, compression and combustion pressures.
x Whenever replacement of components specified in the Technical File is carried out, the Chief
Engineer must ensure that suitable components are used and their ID numbers recorded in the
³Record Book of Engine Parameters´. In case of component repair or maintenance, the Chief
Engineer must ensure that the manufacturer¶s instructions are followed and the final calibration of
components is within specified range. Every intervention to components specified in the
Technical File must be recorded to the ³Record Book of Engine Parameters´.
x Whenever adjustments are carried out to engine settings specified in the Technical File, the Chief
Engineer must ensure that these are within the specified range and recorded in the ³Record Book
of Engine Parameters´.
x The engine¶s Technical File and the EIAPP must be maintained in an excellent condition.
Any changes of engine settings or components recorded in the ³Record Book of Engine Parameters´
must be signed by the responsible workshop representative or the Chief Engineer, as applicable.
2.2.4 NOx Emission Control Areas (ECAs)

The North American area comprises of the sea area located off the Pacific coasts of the United States
and Canada, the sea areas located off the Atlantic coasts of the United States, Canada, and France
(Saint-Pierre-et-Miquelon), the Gulf of Mexico coast of the United States, the sea area located off the
coasts of the Hawaiian Islands of Hawaii, Maui, Oahu, Molokai, Niihau, Kauai, LƗnai, and
Kahoolawe and the Unites States Caribbean sea area have been designated as NOx ECAs for Tier III
certified diesel engines as defined in MARPOL Annex VI, Regulation 13.
The Baltic Sea and the North Sea ECAs, previously designated as ECAs for SOx, have been
extended to also cover NOx. As of 1st January 2019, all the four ECAs under MARPOL cover both
SOx and NOx based on MEPC.301 (72). This implies that engines with a power output of more than
130 kW, to be installed on Vessels constructed on or after 1st January 2021, must be Tier III certified
if they are operated inside the Baltic Sea and the North Sea ECAs. The same will apply for non-
identical replacement engines or additional engines installed on existing ships on or after 1st January
2021.
The amended regulation also temporarily exempts the Tier III requirement to allow ships fitted with
dual-fuel engines or with only Tier II engines to be built, converted, repaired and/or maintained at
shipyards located inside NOx ECAs.
2.3 REDUCTION OF SOX EMISSIONS AND PARTICULAR MATTER

The purpose of these procedures is to ensure that Vessels operations will fully comply with the
MARPOL Annex VI regarding requirements for Sulphur Oxides (SOx) emissions, both inside and
outside SOx Emission Control Areas (ECAs, as defined in MARPOL Annex VI), as well as with the
relevant regional requirements imposed by local authorities.
The following table shows the applicable ³low sulphur´ limits allowed in the various areas and for
the various grades depending on the regulations in force at the time and location:
(See Table on next page)
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Sulphur
Enforcement
limit Grade Operating area Reference
date
(% m/m)
0.50 VLSFO Global limit 01/01/2020) Revised MARPOL Annex VI
Directive 1999/32/EC as amended by
EC territory and waters
0.10 MGO Regulation 1882/2003 and Directive
(since 01/01/2008)
2005/33
EC & Turkish inland Directive 1999/32/EC as amended by
waterways and when Regulation 1882/2003 and Directive
0.10 All grades
berthed at EC & Turkish 2005/33 & Turkish Maritime Regulations
ports applicable since 01/01/2012
CARB (mandatory use of either MGO or
MGO California waters and 24
MDO with the set maximum sulphur limit to
(DMA) NM of the California
0.10 main propulsion diesel engines, auxiliary
Already in MDO baseline (since
diesel engines and boilers. HFO is not
force (DMB) 01/01/2014)
allowed to be used)
North American ECA
(covering designated
coastal areas off the
United States and
Canada), US Caribbean
ECA (waters around Revised MARPOL Annex VI adopted by
0.10 All grades
Puerto Rico and the Res. MEPC. 176(58)
United States Virgin
Islands), Baltic ECA,
North Sea ECA &
English Channel
³Implementation Plan for Marine Air

. Vessels entering the
Distillate Pollutant Emission Control Areas´ from the
Already in inland water ECA must
(DMA, Ministry of Transport of the People¶s
force from 0.10 use fuel with lower or
DMZ, Republic of China on 30/11/2018, which
01/01/2020 equal to 0.1% sulphur
DMB) provides the updated Chinese ECAs
content.
regulations.
³Implementation Plan for Marine Air

Vessels entering the
Distillate Pollutant Emission Control Areas´ from the
regulated waters of
From (DMA, Ministry of Transport of the People¶s
0.1 Hainan Island must use
01/01/2022 DMZ, Republic of China on 30/11/2018, which
fuel with lower or equal
DMB) provides the updated Chinese ECAs
to 0.1% sulphur content.
regulations.
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The fuel oil received and consumed must satisfy the Annex VI maximum sulphur content limit.
The Chief Engineer must ensure this by verifying that the sulphur content is written on the Bunker
Delivery Note (BDN) and that it is not above the limit allowed.
In case the Vessel trading patterns include ECAs, then the Vessel must be provided with fuel with
maximum sulphur content as defined by MARPOL Annex VI, in addition to the ³normal´ sulphur
content fuel.
The low sulphur fuel/ MGO oil must be stored in separate bunker tank(s) designated for this purpose.
Under no circumstances must the low sulphur fuel be stored or mixed in a normal high sulphur fuel
bunker tank.
For Change-Over Procedures, please refer to Bunkering Procedure of the Shipboard Operations
Manual.
According to the new low-sulphur compliant fuel of 0.50% that Vessels have to use same from 1st
January 2020, regulations adopted on 2008 by Res. MEPC. 176(58). However, a provision was
adopted, requiring IMO to review the availability of low sulphur fuel oil for use by ships, to help
Member States determine whether the new lower global limit on sulphur emissions from international
shipping shall come into effect on 1st January 2020 or be deferred until 1 January 2025.
IMO¶s Marine Environment Protection Committee (MEPC 70), in October 2016, decided that the
0.50% limit shall apply from 1 January 2020.
The ship implementation planning guidance, prepared to be ship-specific for each company¶s Vessel,
as part of a set of guidelines being developed by IMO for consistent implementation of the MARPOL
regulation coming into effect from 1 January 2020 was approved in October 2018 by Res.
MEPC.1/Circ.878, includes sections on:
x Risk assessment and mitigation plan (impact of new fuels);
x Fuel oil system modifications and tank cleaning (if needed);
x Fuel oil capacity and segregation capability;
x Procurement of compliant fuel;
x Fuel oil changeover plan (conventional residual fuel oils to 0.50% sulphur compliant fuel oil;
and
x Documentation and reporting.
Reference is also made to Environmental Program EP-1.
2.3.1 Facilitating Sulphur Inspection

The sulphur inspection is to be initially limited to documentation checks, evaluating if enough
evidence is provided, to confirm the Vessel¶s compliance. If, however, proof is needed as to what
fuel is used or was used at one particular time in order to, among other cases, to substantiate any
non-compliances found during document verifications, to ascertain the sulphur content in cases of
on-board fuel mixing / contamination or to comply with any established national frequency of
marine fuel sampling, the Sulphur Inspector may proceed to draw a fuel oil sample either by
sampling from the ship¶s fuel system of the fuel µin use¶ or that stored or analysing of the
MARPOL representative samples.
For facilitating a MARPOL Annex VI SOX inspections by the Port State or another competent
authority, noting that some administrations may use dedicated sulphur inspectors working for a
different government authority than the Port State Control (PSC), the PSC Guidelines have been
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revised with the IMO Resolution MEPC.320 (74) (adopted on 17 May 2019), titles as ³2019
Guidelines For Port State Control Under MARPOL Annex VI Chapter 3.
Based on these guidelines, it is suggested the items described in the sections 2.3 µInitial
Inspection within an ECA¶ and section 2.4 µInspection outside and ECA¶ of the IMO
Resolution MEPC.320(74) to be provided as specific evidences for fuels loaded and used on
board.
Such evidences include, but they are not limited to:
The IAPP Certificate stating the ships means for compliance
BDN and accompanying MARPOL samples
Oil record book
Notes of Protest
Fuel change over records
Any other supporting evidence or cases where issues have had to be addressed such as
unavailability of compliant fuel (FONAR), etc.
2.4 GUIDELINES FOR USING SOX SCRUBBER SYSTEMS
2.4.1 Introduction
These guidelines refer to the particular Vessel design to be able to feature a SOx scrubber system for
SOx emission reduction, down to a compliant with the applicable regulations level.
The scrubber technology works by passing the dirty exhaust gas stream created by the engine
through several chambers that contain a carefully generated µscrubbing cloud¶ of water. Inside these
chambers, a high number of droplets rapidly capture the errant particles in the process stream.
Seawater is used to cool the scrubber water in circulation. The automation system during
commissioning is optimized to the lowest possibly energy consumption and keeps the emissions
within stipulated limits, regardless of Sulphur content in the fuel, and engine load or water alkalinity.
2.4.2 Open and Close-Loop Systems

A scrubber system can operate in different modes or loops, open, closed and hybrid systems.
When the scrubber system works in closed loop, an alkali, such as Caustic Soda (NaOH) or
Magnesium Oxide (MgO) is needed to clean the wash-water that is held in the wash-water tank. In
open loop there is no need for water treatment as the natural alkalinity in the seawater neutralizes
the acid. Wash water is continuously monitored at the inlet and outlet to make sure it is in line with
the relevant regulations from IMO before it is discharged into the sea.
Certain port authorities worldwide do not accept discharging of wash-water, whilst the Vessel in
areas of their jurisdiction.
In this respect, whilst in these ports, the open loop systems (if available), must be switched-off and
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compliant low Sulphur fuel oil must be used instead.
Also, attention must be placed that closed-loop scrubbers have a certain capacity, which is translated
into voyage days and passage time. After that, the Vessel has to give the heavy effluent to shore
facilities or simply change to open-loop. In this latter case the crew has to use the system just if it
were open-loop.
2.4.3 Responsibilities
The Vessel¶s Master in cooperation with the Technical Department of the Company, is utmost
responsible for the compliant operation of the scrubber system and for maintaining its certification
and Class notation status.
The Chief Engineer, supported by the rest Engine Officers and crew, is responsible for:
x Proper operation of the system, in accordance with the designed standards.
x Maintenance and inspections as per the Makers¶ instructions and the PMS.
x Bunkering of alkali solutions (in case of closed loop systems), including proper and safe storage
and transfer.
x Proper disposal of wash-water and alkali solutions drains and residues (as applicable).
x Implementation of safe working practices and use of Personal Protective Equipment (PPE), for
personnel involved in the operation of the system incl. bunkering and transfer of alkali solutions.
2.4.4 Operation of the System

Construction, control systems, tests, inspections and certification procedures related to SOx scrubber
are to comply with IMO Res. MEPC.259(68) "2015 Guidelines for Exhaust Gas Cleaning Systems",
adopted on 15 May 2015, as amended.
SOx scrubber system is designed to enable continued operation of the linked equipment (M/E, D/Gs
and Boilers) at the times the SOx scrubber system is not in operation, either through operational
selection (e.g. when operating the engines with compliant low Sulphur fuel), equipment failure, or
system deterioration through partial blocking/clogging. Similarly, SOx scrubber unit that
incorporate a wet wash-water scrubbing process can enable continued operation of the fuel oil
combustion units without the wash-water system in operation.
SOx scrubber system can be easily inspected and maintained via inspection port(s) available for
internal inspection of the main reaction chamber, and where applicable, for replacing internal
components.
The following parameters must be ensured during the operation:
x Function of alarm and shutdown arrangements, to prevent an abnormal rise of wash-water level
in the scrubber reaction chamber.
x In the event of failure of the essential SOx scrubber system pumps or fans, standby pump or fan,
where provided, is to be automatically started and put into service. This failure is to be alarmed
at the local and remote control station(s), as applicable.
x Function of automatic control (including wash-water discharge criteria), alarm, and safety
functions, so that operations remain within pre-set parameters for all fuel oil combustion unit(s)
and SOx scrubber system operating conditions.
x Function of the available automatic shutdown system.
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The following periodical tests must be made as per the PMS and at least 6 monthly:
x Visual inspection and verification of the foundations and attachments of the principal
components of the SOx scrubber unit and associated systems.
x Visual examination of the piping systems.
x Electrical wiring and connections continuity check and verification of proper workmanship.
x Instrumentation test, to confirm proper operation as per its predetermined set points.
x Test of pressure relief and safety valves installed on the unit.
x Test of all control system and shutdowns.
2.4.5 Safety Precautions

For the protection of crew members, suitable protective equipment must be available on board.
Hot surfaces of SOx scrubber unit or their associated equipment or systems likely to come into
contact with the crew during operation must be suitably guarded or insulated. Where the surface
temperatures are likely to exceed 220 & and where any leakage, under pressure or otherwise, of fuel
oil, lubricating oil, or other flammable liquid is likely to come into contact with the SOx scrubber
unit or exhaust pipes, these surfaces must be suitably insulated with non-combustible materials that
are impervious to such liquids. Insulation material not impervious to oil is to be encased in sheet
metal cladding or an equivalent impervious sheath.
2.4.6 Bunkering of Alkali Solutions (when applicable)

The present instructions mainly focus on bunkering of Caustic Soda / NaOH solutions; however they
evenly apply to other applicable Alkalis, such as Magnesium Oxide (MgO) solutions.
Precautions for receiving and using NaOH for the scrubber system are based on a Risk Assessment.
Bunkering of NaOH is supervised by the Chief Engineer and NaOH is transferred via a dedicated
piping system to the approved storage area.
The relevant Materials Safety Data Sheet (MSDS) must be delivered to the Chief Engineer, studied
before the commencement of the operation by all the personnel involved and posted in the vicinity of
the storage area. If the suppliers fail to deliver the MSDS, a letter of protest must be issued by the
Master and the Company immediately informed. For this case, MSDS documents provided in
previous bunkering operations must be retained on board, in order to be consulted in contingency.
Based on the MSDS and the available PPE Matrix, PPE used during NaOH bunkering must include
large aprons, rubber gloves with long sleeves, rubber boots, coveralls of chemical-resistant material,
and tight-fitting chemical safety goggles or face shields or both. The protective clothing and
equipment must be suitable to cover all skin so that no part of the body is left unprotected. An
eyewash and safety shower must be also available in proximity.
Prior to bunkering, all checks as per the Checklist ³NaOH / Alkali Solutions Bunkering Checklist´
must be ensured by the Chief Engineer.
Managing SOx Scrubber¶s and Alkali Solutions¶ Overflow, Residues and Drains
Further to the NaOH solution storage tank, an approved SOx scrubber residue / NaOH overflow tank
must also be available.
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In this designated tank, the residues generated from the exhaust gas cleaning process and, if
applicable, the NaOH overflows are to be stored, separate from the engine room sludge tank, and
arranged for discharge to appropriate shore reception facilities. Especially with respect to the NaOH
solution, drains from the relevant storage tank may be alternatively drained locally and/or remotely
on deck to appropriate collection Vessels, in order thereafter to be disposed to shore facilities.
This tank must be provided with the following arrangements, which are to be verified by the OOW
during operation:
x High level alarm.
x Local & remote temperature monitoring arrangements.
x Local & remote level monitoring / sounding arrangements.
x Mechanical exhaust ventilation with ventilation inlets.
2.5 CARBON EMISSIONS

The issue of carbon dioxide emissions from ships, and how to control them, as requested by the
Kyoto Protocol of 1997 to the United Nations Framework Convention for Climate Change, is being
studied at IMO with a view to developing guidelines relevant to the implementation of Annex VI.
The control of CO2 emissions can be achieved through sound plant maintenance and improved
propulsion and propeller designs.
Similar controls are encouraged to limit black smoke emissions and un-burnt hydrocarbons.
2.5.1 IMO Data Collection Systems (DCS)

On 1st March of 2018, the amendments to MARPOL Annex VI, Regulation 22A, on the fuel oil data
collection of ships came into force.
Starting from 1st January 2019, ships of 5,000 Gross Tonnage (GT) or above shall collect fuel
consumption data, hours underway and distance travelled according to procedures, systems and
responsibilities to be outlined in a Data Collection Plan (DCP), which is to be included in the Ship
Energy Efficiency Management Plan (SEEMP) Part II by December 2018.
The SEEMP shall be amended using the template outlined in Appendix 2 of the 2016 Guidelines for
the development of a SEEMP.
The Data Collection Plan describes the ship's particulars as well the procedures, systems and
responsibilities used to monitor fuel consumption, hours underway and distance travelled. It must be
created within the Part II of the Ship Energy Efficiency Management Plan (SEEMP) and be available
on-board the Vessel.
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The Data Collection Plan is very similar to the EU MRV Monitoring Plan but consists in only 9
sections:
x Ship particulars.
x Record of revision of Fuel Oil Consumption Data Collection Plan.
x Ship engines and other fuel oil consumers and fuel oil types used.
x Emission factor.
x Method to measure fuel oil consumption.
x Method to measure distance travelled.
x Method to measure hours underway.
x Processes that will be used to report the data to the Administration.
x Data quality.
The Data Collection System '&6 KDV been prepared in DFFRUGDQFHZLWK the 2016 Guidelines for the
Development of a Ship Energy (IILFLHQF\0DQDJHPHQW Plan adopted by Resolution MEPC.282 (70),
and shall be reviewed by the Flag Administration or an organisation duly authorised by it.
A Confirmation of Compliance is issued by the Flag Administration confirming the successful review
of the DCS, which must be kept on board for the period of its validity.
Following the end of each calendar year and no later than 31st March of the subsequent year, ships
shall submit to the Flag Administration or an organization duly authorized by it, the fuel oil data,
hours underway and distance travelled for the previous calendar year.
Upon verification of the data in accordance ZLWK5HVROXWLRQ MEPC.292(71) adopting
the 2017 Guidelines for Administration verification of ship fuel oil consumption data, the Flag
$GPLQLVWUDWLRQVKDOO issue by 31st May 2020 to the ships a Statement of Compliance
related to fuel oil consumption which must be kept on board for the period of its validity.
2.6 CONTROL OF EMISSIONS OF SHIPBOARD OZONE DEPLETING SUBSTANCES (ODS)

The following procedures provide guidance for handling and maintaining equipment that contain
Ozone Depleting Substances (ODS), in accordance with the requirements of MARPOL Annex VI.
During installation, maintenance and final disposal of equipment containing ODS, the deliberate
emission of these substances to the air is strictly prohibited.
ODS must be recovered and disposed to appropriate shore reception facilities for further treatment.
ODS commonly encountered onboard ships (as refrigerants or firefighting substances) include the
following:
x Chlorofluorocarbons (CFCs)
x Halon
x Carbon tetrachloride, Methyl chloroform
x Hydrobromofluorocarbons (HBFCs)
x Hydrochlorofluorocarbons (HCFCs) (R22, R141b)
x Methyl Bromide
x Bromochloromethane (BCM)
The use of CFCs and Halons onboard ships is prohibited. Halons are prohibited both for refrigerant
and fire-fighting applications.
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Use of HCFCs in existing installations is permitted until 1/1/2020, subject to phase-out scheme as per
the following list.
However, there are more substances subject to restriction of emissions to the atmosphere. In case of
maintenance by the shipboard personnel, if in doubt that a substance is subject to emission
restrictions, the C/E must contact the Company.
Refrigerants are categorized as follows with respect to their contribution on Ozone Depletion:
Category 1 Prohibited in new installations Halon, R11, R12, R13, R111, R112, R113,
from 19/5/1995 R114, R115, R211, R212, R213, R214, R215,
R216, R217.
Category 2 Prohibited in new installations R21, R22, R31,R121 to R124, R131 to R133,
from 1/1/2020 R141 to R142
R151, R221 to R226, R231 to R235, R241 to
R244, R251 to R253, R261 to R262, R271
Category 3 No restrictions apply R290, R134a, R32, R404a, R407a, R407b,

R407c, R410a, R413, R417, R507, R600,
R717, CO2
The substances of Category 3 are not considered and controlled as ozone depleting, unless the
Company opts to handle as ODS all types of shipboard refrigerating substances.
2.6.1 EUROPEAN UNION REQUIREMENTS

The use of hydro-chlorofluorocarbons (HCFCs) was permitted until 31st December 2014 in
accordance with Regulation 2037/2000 (EC) of the Council dated 29th June 2000 on Substances that
Deplete the Ozone Layer1.
As from 1st January 2010, the provisions of Regulation (EC) No. 1005/2009 are applied and the use
of virgin HCFCs for the maintenance or servicing of equipment is prohibited.
Until 31st December 2014, only reclaimed HCFCs may be used for the maintenance or servicing of
existing equipment. After that day (31/12/2014), the use of HCFCs is no longer allowed.
Equipment containing ODS include, but may not be limited to, the following:
x Central provision refrigeration units.
x Central air conditioning systems.
x Accommodation local refrigerator and air conditioning appliances.
The ozone depleting substances and equipment containing such VXEVWDQFHVVKDOOEH delivered to
DSSURSULDWHUHFHSWLRQIDFLOLWLHVZKHQUHPRYHGIURPVKLSV
During maintenance and disposal of central refrigeration and air conditioning equipment components
by external workshops, the latter must use appropriate equipment for recovering the refrigerant. The
refrigeration system must ideally be designed so that the compressor may be used for collecting the
refrigerant into an existing liquid receiver. Alternatively, recovery units may be used, evacuating the
refrigerant into cylinders dedicated for this purpose. All company¶s Vessels are provided with
recovery units.
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In case this maintenance needs to be done by the shipboard personnel, the C/E must ensure the
recovery of the refrigerant and, as far as practicable, not allow emissions to the atmosphere. The
refrigerant can be collected in the condenser by closing the condenser outlet valve and operating the
compressor until stopping by low suction trip.
For monitoring purposes the following records must be maintained onboard regarding ODS:
x A list of HTXLSPHQWFRQWDLQLQJR]RQHGHSOHWLQJVXEVWDQFHV as per the ³ODS Equipment List´ in
³Vessel¶s Specific Environmental Performance Workbook´.
x $Q2]RQH'HSOHWLQJ6XEVWDQFHVRecord%RRN when rechargeable systems containing ODS are
available onboard. This record book may be part of an electronic recording system of a hard
copied record book as approved by the Administration. The ODS Equipment List in Form
³Vessel¶s Specific Environmental Performance Workbook´ is used for this purpose.
(QWULHVLQWKH2'6Record%RRNVKDOOEHrecordHGLQWHUPVRIPDVV (kg) of substance and shall be

FRPSOHWHGZLWKRXWGHOD\RQHDFKRFFDVLRQLQUHVSHFWRIWKHIROORZLQJ
x UHFKDUJHIXOORUSDUWLDORIHTXLSPHQWFRQWDLQLQJ2'6
x UHSDLURUPDLQWHQDQFHRIHTXLSPHQWFRQWDLQLQJ2'6
x GLVFKDUJHRI2'6WRWKHDWPRVSKHUH
o GHOLEHUDWHDQG
o non-deliberate;
x GLVFKDUJHRI2'6WRODQGEDVHGUHFHSWLRQIDFLOLWLHV
x VXSSO\RI2'6WRWKHVKLSDQG
x recovered ODS quantities.
In case of disposal of the installation, the recovered refrigerant must be transferred by special
equipment to special containers, provided by shore disposal companies.
During disposal of household air conditioning units these must be dismantled by shore companies
having special equipment required for the recovery of the ODS refrigerants.
Disposal of appliances that do not require special dismantling, like household refrigerators, must be
sent to shore facilities without any deliberate or accidental dismantling or damage to the refrigerant
system.
The Technical department must closely monitor and restrict the Vessel orders for refrigerants and
ensure the provision of all necessary technical support and equipment to the Vessel, as this is
required for minimizing ODS emissions.
2.6.2 LEAK DETECTION PROCEDURE

In case an ODS is being used, such as HCFC R-22, and the Flag Administration of the ship requires
compliance with other Statutory Instruments or legislation such as Reg. (EC) No. 842/2006 or Reg.
(EC) 1005/2009 for EC countries, a refrigerant leak monitoring system is required.
A leak detection system appropriate to the applicable refrigerant is to be provided to monitor
continuously the spaces into which the refrigerant could leak.
An alarm is to be given in a permanently manned location when the concentration of refrigerant in
the space exceeds a predetermined limit (300ppm for halogenated fluorocarbons).
Remedial measures to repair the leakage are to be implemented as soon as practicable after an alarm
is activated.
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Independently to the above leak monitoring system, and to reduce the possibility of leaks occurring,
periodic leak detection must be undertaken. A simple leak detection method uses a solution of soap in
water.
This is painted onto all joints and connections which are then inspected for the formation of bubbles.
A more effective method is to use an electronic leak detector which is specifically calibrated for the
refrigerant in use.
The periodicity of recalibration must be in accordance with the manufacturer¶s instructions.
A further system of leak detecting involves adding a small amount of fluorescent dye to the
refrigerant circulating around the system.
Any leaks from flanges, glands, connections, etc. will include a small amount of the dye.
As this has smaller molecules than the refrigerant it is more susceptible to leaking.
The location of any leaks can then be easily identified by illuminating the area with an infrared lamp.
The periodicity of leak detection is at the discretion of the Company and is recorded in e-PMS.
If a system is completely sealed, with no breakable connections, then leak testing may be waived.
Any detected leakage must be repaired as soon as possible.
The equipment or system shall be checked for leakage after the repair and then again within one
month to ensure that the repair has been effective.
Refrigerant leakage is to be minimized by leak prevention and periodic leak detection procedures.
By using the ODS log book, an annual refrigerant usage figure can be established and maintained for
each system.
This would allow a refrigerant usage trend to be determined and so indicate whether a system has
started to leak significantly.
An allowable annual leakage figure is hard to be estimated but the following may be used as an
indication:
x 30% of initial charge for small systems
x 10% of initial charge for medium systems
x 3% of initial charge for large systems.
A. Refrigerant recovery procedure

Systems are to be arranged with suitable means of isolation so that maintenance, servicing or repair
work may be undertaken without releasing the refrigerant charge into the atmosphere.
Unavoidable minimal releases are acceptable when using recovery units.
For the purpose of refrigerant recovery, the compressors shall be capable of evacuating a system
charge into a condenser (pump-down).
Additionally, recovery units are to be provided to evacuate a system either into the existing liquid or
into a cylinder dedicated for this purpose.
The number of cylinders is to be sufficient to contain the complete charge between the systems¶
isolating points.
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B. Pump-down procedure
Pump down means that refrigerant in the refrigeration system is collected temporarily in the
condenser. Pump down is required when the refrigerant circuit needs repair, the unit cooler is stopped
for a prolonged period or it is moved to minimize the risk due to refrigerant leakage.
How to pump-down the Refrigerant
1. Close the condenser liquid outlet stop valve. Open the solenoid valve in the liquid line by hand or
electrically.
2. Short circuit the terminal so that the low pressure side of the dual pressure switch will not
function.
3. Operate the compressor and draw the refrigerant on the low pressure side.
4. Stop the compressor when low pressure gauge reading becomes 0.1 kg/cm2 and leave it for a
while. When low pressure rises, once again operate the compressor until low pressure gauge
reading becomes 0.1 kg/cm2. Low pressure will not rise when this procedure is repeated 2-3
times.
5. Stop the compressor and close the condenser inlet stop valve quickly and then close the suction
stop valve.
6. After finishing pump down, stop condenser water supply.
7. Cut off power supply to master and control currents.
8. Inspect receiver, condenser and pressure Vessels as well as piping connections and apparatus for
leakage.
Caution!!!
1. If pump down continues for a long time, oil pressure may be lowered more or less but does not
short circuit the oil pressure protection switch circuit.
2. After finishing pump down, do not forget to restore the short circuit of the terminal on the low
pressure side of the dual pressure switch.
2.7 CONTROL OF EMISSIONS PRODUCED BY SHIPBOARD WASTE AND GARBAGE INCINERATION

The purpose of these procedures is to provide guidance to the shipboard personnel to ensure that the
requirements of MARPOL Annex VI for shipboard incineration are complied with.
For detailed information on the proper use of the incinerator, reference to the maker¶s instructions
must be made.
Incineration of the following substances is strictly prohibited for avoiding the pollution of air:
x Cargo residues of substances subject to MARPOL Annexes I, II and III requirements.
x Cargo residues of crude oil and oil like substance cargoes, chemicals substances included in
chapter 17 of the IBC Code and presenting an environmental pollution threat according to Annex
II, and harmful substances identified as marine pollutants in the IMDG Code.
x Polychlorinated biphenyls (PCBs) which are mainly liquid substances used as coolants and
lubricators in electrical apparatus like transformers. Trade names are Aroclor (USA), Clophen
(Germany) and Kanechlor (Japan).
x Garbage as per Annex V of MARPOL when containing more than traces of heavy metals.
x Refined petroleum products containing halogen compounds.
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x Polyvinyl Chlorides (PVCs) unless the incinerator is IMO type approved for burning these
category of substances. Check that the incinerator Certificate states approval as per the MEPC
59(33) or MEPC 76(40) specifications prior to processing PVCs.
Incineration of sewage and oil sludge is permitted, but shall not take place in ports, harbours and
estuaries.
Incineration is only allowed in Class approved incinerators specially built for the types of waste
intended to be incinerated. Incinerator operation must follow the maker¶s procedures.
The persons responsible for the operation must be trained and records of the training must be kept.
Company¶s Vessels do NOT incinerate Plastics
Incineration is prohibited in the entire Baltic Sea Area as defined by the Helsinki Convention,
on the Protection of the Protection of the Marine Environmental of the Baltic Sea Area ( 1992).
The Incinerator is characterised as Environmental Critical Equipment.
Before De-activating the Incinerator, the relevant Risk Assessment A-11- must be referred to and all
the Hazards and Safety Control Measures must be taken into consideration.

prepared and submitted to office for approval prior to every De-activation of Incinerator.
Regarding documentation to be kept for incinerator operation, the following must be recorded in the
Garbage Record Book:
x Incineration operations documentation (date and time of starting/stopping of the operation,
position of Vessel, type and amount of garbage in m3).
x Exhaust gas temperature of incinerator which must be in line with the Makers¶ Incinerator
Manual.
2.8 CONTROL OF CARGO VAPOUR EMISSIONS

All tankers undergoing closed cargo operations in terminals, at which vapour emissions are to be
controlled must be provided with:
x A Vapour Emission Control System (VECS), approved by the Administration taking into account
latest issued International and National Regulations.
x A Vapour Emission Control Manual (VEC Manual), which covers all necessary operational and
crew training procedures related to cargo vapour transfer to shore terminals.
The VECS must be used during loading of relevant cargoes, whenever appropriate shore facilities are
available
During use of VECS, all relevant instructions contained in the VECS manual must be followed,
together with all applicable terminal regulations.
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Regarding United States of America based on 46 CFR 39.1015 for foreign-flagged tank Vessel
certification procedures for vapor control system designs it is stated that the owner or operator of a
foreign-flagged tank Vessel in order to comply has to either:
x Follow the procedures in 46 CFR 39.1013 and submit plans, calculations, and specifications
for the VCS to the Marine Safety Center (MSC) for review and approval; OR
x Submit certification by the classification society stating that the VCS meets the requirements
of 46 CFR Part 39 to the MSC. Once that certification is received, the local OCMI can
endorse the Vessel¶s Certificate of Compliance.
There is no requirement for the MSC to review the VCS manual specifically. More often than not,
certification from Class is received, and that is sufficient for the Vessel to operate in the U.S.
2.9 VOLATILE ORGANIC COMPOUND (VOC) EMISSIONS

Regulation 15 of Annex VI of MARPOL 73/78, as revised by IMO Resolution MEPC, regulates the
VOC emissions from a tanker in designated port(s) or terminal(s) of a Party regulating such
emissions.
It also requires that a tanker carrying crude oil shall have on board and implement a VOC
Management Plan (VOC Plan) approved by the Administration.
Reference is made to this Plan which is specific to each crude carrier ship of the fleet.
This plan contains all necessary operational and crew training procedures related to VOC emission
control.
The VOC emissions calculation sheet part of VOC Management Plan (VOC Plan) has been included
in Form ³Vessel¶s Specific Environmental Performance Workbook´ in order to be properly reported
by company¶s Vessels carrying crude oil when required.
2.10 CONTROL OF OTHER SHIPBOARD EMISSIONS

All cargo discharge, COW and cargo tank ballasting operations must be carried out in a manner that
prevents the emission of hydrocarbon vapours to atmosphere.
This can be effected by methods which result in the displaced vapour being retained onboard or sent
to the shore facility.
2.10.1 Funnel Smoke

In many ports the discharge of smoke from the funnel is prohibited.
All plant machinery must be operated so as to minimise this type of emission.
Crewmembers must inform the OOW immediately if smoke is noticed coming from the funnel.
The deck OOW must immediately advise the E/R if excessive funnel smoke is observed and
immediate action must be taken to rectify the situation.
2.10.2 Inert Gas

The IG plant must be operated as per maker's instructions.
Under normal circumstances the system must be operated in an automatic mode, so that the tank
vapour pressure can be maintained with the normal limits prescribed in the IG manual.
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2.10.3 Crude Oil Wash

COW must generally be conducted during cargo discharge operation.
This process enables the in tank pressure to be controlled by the correct operation of the IG system,
and negates the need to vent cargo vapours to atmosphere. If the in-tank pressure rises to within 200
mmwg of the relief setting of the pressure relief valve, then COW operations must cease.
2.10.4 Vapour Balancing

Vapour balancing is a simultaneous cargo and ballast transfer operation, with vapour from the
ballasted cargo tanks being transferred to those tanks from which cargo is being discharged.
Vapour compression involves ballasting in the normal manner but with all cargo tank outlets, which
would permit the release of vapour to the atmosphere, secured and the displaced vapour being
dispersed through and absorbed within the empty cargo tanks.
Crude oil tankers are required to be able to carry out a simultaneous discharge/ballast operation in
order to prevent the emission of vapour ³wherever local conditions require it´ (ǿȂȅ ³COW Systems´
1983, Revised Specs paragraph 6.8).
An example of a typical operation can be found in the ship's COW Manual. Whilst circumstances
may preclude carrying out the operation exactly as per the example, it must be used for guidance
when planning the operation.
Apart from the simultaneous operation included in the COW manual, no other method is permitted.
Thus a ³Vapour Compression" operation can only be considered where this is addressed in the
Manual.
Ships other than crude oil carriers are restricted to a ³Vapour Balancing" operation. Because of the
various combinations of cargo grade and ship types, it is impossible to designate a preferred
procedure.
There are advantages and disadvantages to both operations and it is for the Master to decide which is
the most appropriate for any one cargo discharge.
ǹ final decision as to which method to employ will depend on a number of factors including the
known condition of segregation valves, vent valves, P/V valves and any special circumstances of the
ship/shore interface e.g. cargo arm operating envelope in relation to freeboard and tide.
However, the restrictions imposed may result in a vapour balancing operation being the only feasible
choice.
2.10.5 Vapour Compression

In the case of a vapour compression operation with simultaneous cargo discharge and ballast
operation with vapour balancing on ships where this is approved by their Flag State and where
procedures are detailed in the COW manual, the following provisions must be taken:
x The C/O must develop a written plan and he must supervise the operation.
x In order to achieve the MARPOL designated departure draft and remain within the pressure limit
specified in the following paragraph, it may be necessary to load the ballast in 2 stages, i.e.
discharge, ballast, discharge, ballast. In such cases, during the first ballast operation, there must
be effective two-valve segregation between the ballast and cargo remaining on board.
x Only one (1) pump is to be used for ballasting.
x No more than one (1) pump is to be connected to one (1) tank.
x Apart from those valves being used for part of the vapour transfer route, all other cargo tanks or
vent system outlets, which could release vapour to the atmosphere, must be secured.
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x The vapour from the tanks being ballasted must be transferred simultaneously to all the other
cargo tanks. Prior to commencing the operation, to ensure that all tanks are common, the C/O
must personally verify that all the requisite valves are open.
x The amount of ballast must be kept to the minimum necessary to safely level the berth.
x The anticipated pressure rise must be calculated as per the following example. The amount of
ballast loaded must be such that the final tank pressure remains more than 0.5 psi below the
pressure relief setting of the cargo tank P/V valves. In the case of a two-stage operation, this
calculation must be done for each stage.
x Cargo and ballast handling rates must be established such that there is always a positive pressure
within the tanks.
x The pressure in all cargo tanks must be monitored continuously throughout the operation. The
maximum permitted tank pressure must be at a pressure 200 mmwg lower than the setting of the
pressure relief valve.
The operating plan must have been approved by the Master and authorised by the Company.
2.10.6 Pressure Calculation

In order to provide maximum ³pressure space", the pressure in the cargo tanks at the beginning of a
vapour compression operation must not exceed 100 mmwg.
This will require a judicious and controlled reduction of IG supply during the latter stages of the
cargo discharge.
When calculating the amount of ballast which can be loaded in this manner, it is vitally important to
use the correct pressure in the pressure/volume equation.
The pressure used must be the absolute pressure, i.e. atmospheric plus gauge pressure and not simple
the gauge pressure.
An example of the calculation is given below:
x Total cargo tank volume = 340,000 m3
x Initial gauge pressure = 100mm wg (100mm wg = 0.14 psi)
x P/Valve setting = 2.5 psi
How much cargo tank ballast can be loaded after all cargo has been discharged?
Atmospheric pressure = 14.7 psi.
Initial tank pressure = 14.84 psi (ȇ1)
P/V setting = 2.5 psi.
Max over-pressure (20% less p/Ȟ setting) = 2.0 psi.
Final tank pressure = 14.7 + 2.0 = 16.7 psi (ȇ2)
Initial tank volume (all tanks empty) = 340,000 m3 (V1)
Note: In the case of a two-stage operation, V1 is the remaining empty space at each stage.
Final empty volume on completion ballast = V2
P1.V1 = P2.V2
14.84 x 340,000 = 16.7 x V2
From which V2 = 302,132 m3
Ballast which can be loaded = V1 - V2 = 37,868 m3.
Note: Although the units used are not important, they must be consistent on both sides of the
equation.
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2.10.7 Authority to Conduct Operation

Because of the potential hazards associated with each method, regardless Ƞf which option is used,
authorisation must be taken by the Company. When requesting authority to carry out a ³no emission´
ballast operation, Masters must confirm that all applicable requirements have been taken into
consideration in developing the operating plan.
2.10.8 Emergency
In the event of any problems arising from an emission free operation which may affect the safety of
the ship or environment, then all operations must be stopped and pressure released to atmosphere if
required. Must such a situation ever arise the Company must be advised immediately.
2.10.9 Gauging and Sampling

Another source of vapour release is during gauging and sampling operations. All Company¶s ships
are fitted with vapour lock gauging and sampling points which permit these operations to be carried
out without releasing the tank pressure.
3. RECORD
x Chemicals / Gases MTN/SECTION 1/TEC/110
Monthly Consumption Report
x Fuel Type Change-over Log Book SOM/SECTION 11/SF/TEC/128A
x Ozone Depleting Substances - EMS/SECTION 6/SF/TEC/132
Delivery to Reception Facilities
x Critical Equipment De-activation MTN/SECTION 1/SF/TEC134
x EMS Environmental Workbook PRO/PRO 25 / SF/TEC/139
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(009) COMPLIANCE WITH BALLAST WATER Revision: 06
MANAGEMENT REQUIREMENTS Eff. Date: 29/02/2020
Contents
1. PURPOSE.....................................................................................................................................2
2. PROCEDURE...............................................................................................................................2
2.1 Ballast Water Management Plan............................................................................................... 2
2.2 International Ballast Water Management Certificate................................................................ 3
2.3 Ballast Water Record Book....................................................................................................... 3
2.4 Inspections on BWM Implementation...................................................................................... 4
2.5 Ballast Water Exchange Standard............................................................................................. 4
2.6 Ballast Water Exchange............................................................................................................ 4
2.7 Ballast Water Treatment System............................................................................................ 4
2.8 Ballast OPA-90 and VGP Controlled Discharges Handling..................................................... 5
2.8.1 General............................................................................................................................................................ 5
2.9 Vessel General Permit (VGP)................................................................................................... 5
2.10 OPA-90 (OIL POLLUTION ACT 1990)...............................................................................6
2.10.1 Interim Final Rule±IFR................................................................................................................................... 6
2.10.2 Vessel Response Plan (Tankers)..................................................................................................................... 7
2.11 International Convention on Civil Liability for Oil Pollution Damage (1969)..................... 7
3. RECORD...................................................................................................................................... 7
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1. PURPOSE
In order to ensure that ballasting/de-ballasting procedures are carried out according to National and
International requirements, the International Convention for the Control and Management of Ships'
Ballast Water and Sediments and the IMO Resolution A.868(20) ³Guidelines for the control and
management of ships' ballast water to minimize the transfer of harmful aquatic organisms and
pathogens´, the Company has developed and follows a Ship Specific Water Ballast Management Plan
(WBMP) for each Vessel.
Also, for Vessels sailing in USA waters, the requirements of the Tank Vessel Response Plan (VRP)
and Vessel General Permit (VGP) apply, in order to ensure that the necessary safety and
environmental protection measures are maintained.
Reference is made to the approved stand-alone ship-specific Ballast Water Management Plan.
2. PROCEDURE
This procedures is based on:
x BWM/CONF/36-³International Convention for the Control and Management of Ship¶s
Ballast Water and Sediments, 2004, adopted 16 February 2004´.
x IMO Assembly Resolution A.868 (20) - Guidelines for the Control and Management of
Ships¶ Ballast Water to minimize the transfer of harmful Aquatic Organisms and Pathogens,
adopted 28 November 1997.
x IMO Resolution MEPC.127 (53) Guidelines for Ballast Water Management and development
of Ballast Water Management Plans (G4) adopted on 22 July 2005.
2.1 BALLAST WATER MANAGEMENT PLAN

Each Vessel shall have onboard and implement a Ballast Water Management Plan (BWMP).
The Ballast Water Management Plan shall be:
x Specific to each Vessel.
x Approved by the Administration
The BWMP shall:
x Detail safety procedures for the Vessel and crew associated with Ballast Water Management.
x Provide a detailed description of the actions to be taken to implement the BWMP.
x Include procedures for the disposal of sediments at sea and to shore.
x Include procedures for coordinating BWM, which involves discharge to sea with the
Authorities of the State into whose waters such discharge will take place.
x Designate the Officer onboard in charge for the implementation of the BWMP.
x Contain the reporting requirements.
x Be written in the Working Language of the Vessel (i.e English for Company Vessels).
x Include associated Guidelines, National and Local Requirements.
The Ballast Water Management Plan must be accompanied by an International Ballast Water
Management Certificate.
As per Regulation B-6 of BWM /CONF/36, Officers and Crew shall be familiar with their duties in
the implementation of the BWMP particular to the ship on which they serve.
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The Chief Officer shall ensure that all Key Personnel who participate in BWM Exchange have made
themselves familiar with its contents and shall confirm the same by signing on the dedicated page of
the Ship Specific BWMP.
Any changes to the Mandatory Sections of the Ship Specific BWMP must be approved and endorsed
by the Classification Society and the Flag Administration.
2.2 INTERNATIONAL BALLAST WATER MANAGEMENT CERTIFICATE

Each Ship must be holder of an International Ballast Water Management Certificate, issued by
the Classification Society under the Authority of the Flag Administration, which must have the
format and information as found in the Appendix I, of the convention BWM/CONF/36.
The International Ballast Water Management Certificate has a validity of five (5) years.
The following Surveys must take place:
A Renewal Survey -at intervals not exceeding five (5) years

An Annual Survey -within three (3) months before or after each anniversary date
shall take place.
An Intermediate Survey -must be carried out within three (3) months before or after the
2nd Anniversary Date or
within three (3) months before or after the 3rd Anniversary date
which shall take the place of the Annual survey.
Additional Surveys -either general or partial shall be made after each change,
replacement of significant repairs of the structure, equipment
systems, fitting, arrangements etc.
2.3 BALLAST WATER RECORD BOOK

Each Vessel shall maintain a Ballast Water Record Book that may be in Hard Copy or an Electronic
Record System or may be integrated in another Record Book or System.
The Ballast Record Book must fulfill the following requirements:
x Be maintained onboard for a minimum period of two (2) years.
x Be maintained by the Company for a minimum of three (3) years.
x Each Entry must be signed by the Officer in Charge of the Operation concerned and
countersigned by the Master.
x The entries must be in the Working Language of the Vessel (i.e English).
x Must include entries describing the circumstances and reasons of discharge, if the discharge is
not included in the acceptable exemptions of the relevant Convention.
The Ballast Water Record Book Format includes instructions for the entries to be made on each
occasion (code/number) and includes a diagram of the ship indicating the Ballast Tanks and the
capacity of each (M3) which must be filled in with Vessel Specific Information.
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2.4 INSPECTIONS ON BWM IMPLEMENTATION

All Ships to which this convention applies, may in any port or Offshore Terminal, be subject to an
Inspection for the purpose of verifying:
x That the Vessel holds a Valid Ballast Water Management Certificate.
x Is properly maintaining the Ballast Water Management Log.
x A sampling of the Ship¶s Ballast Water.
Such inspections may be carried out by the Administration or by Surveyors nominated or recognized
by the Administration.
2.5 BALLAST WATER EXCHANGE STANDARD

As per Regulation D-1 of the Convention BWM/CONF/36, Ships performing Ballast Water
Exchange in accordance with this Regulation shall do so with an efficiency of at least 95 %
volumetric exchange of Ballast Water.
For ships exchanging Ballast Water by the Pumping ±through method, pumping through three (3)
times the volume of each Ballast Water Tanks will meet the standard of Regulation D-1.
Pumping through less than three (3) times the volume may be accepted, provided that the ship can
demonstrate that at least 95 % volumetric exchange is met.
Sequential method is also available by all company¶s Vessels and in most cases preferred for reasons
of energy efficiency.
2.6 BALLAST WATER EXCHANGE

A ship conducting Ballast Water Exchange as per Regulation D-1 (applicable for Company Vessels),
shall carry out Ballast Water Exchange at least 200 Nautical Miles from nearest land and in water
200 meters in depth.
If the Vessel is unable to conduct Ballast Water exchange as stated above, then the BW Exchange
shall be conducted as far from the nearest land as possible and in all cases at least 50 Nautical Miles
from the nearest land and in water at least 200 meters in depth.
A ship shall not be required to deviate from its intended voyage or delay the voyage in order to
comply with any particular requirement for Ballast Water exchange as expressed in this paragraph.
The above requirements shall not apply, if the Master reasonably decides that such exchange would
threaten the safety or stability of the ship.
When a ships is required to conduct Ballast Water exchange and does not do so, the reasons shall be
entered in the Ballast Water Record Book.
Please also refer to 010 ± Cargo Operations Manual / Section14 / 2.4 ± Ballast Water Decanting En
Route.
2.7 BALLAST WATER TREATMENT SYSTEM

For Company Vessels equipped with BWT regulation D-2 is also applicable as described in their
International Ballast Water Management Certificates mentioning the specific method of treatment.
Please also refer to 010 ± Cargo Operations Manual / Section14 / 2.6 ± Ballast Water Treatment
Systems (BWTS)
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The Ballast Water Treatment System is characterised as Environmental Critical Equipment.
Before De-activating the Ballast Water Treatment System, the relevant Risk Assessment A-11-
must be referred to and all the Hazards and Safety Control Measures must be taken into
consideration.

prepared and submitted to office for approval prior to every De-activation of BWTS.
2.8 BALLAST OPA-90 AND VGP CONTROLLED DISCHARGES HANDLING

It is the Master¶s responsibility to inform Officers and crew of these instructions and ensure their
efficient implementation.
He is responsible to ensure that the Vessel¶s specific Water Ballast Management Plan is properly
implemented. He is also responsible to comply with any National requirements of the ports of calls.
The Chief Officer is responsible to prepare the ballast plan in co-operation with the Master and
conduct all ballast operations, taking into account the stability and stress of the ship and cargo tanks,
the type of tanks which are going to be ballasted (segregated, cargo tanks, etc) and their condition
(inerted or not).
The Chief Officer is also responsible for the correct position and operation of the cargo valves and
specifically for the sea and overboard valves. He may delegate their routine monitoring to the Deck
ȅȅW.
However, when Ballasting/De-ballasting of Cargo Tanks, the Chief Officer must have personal
responsibility of the operation during the following activities:
x Start of ballast operations.
x Topping-off/Stripping tanks.
x Completion of ballast operations.
x At any critical part of the ballast operation.
2.8.1 General
Ballast operations must always be carried out in accordance with a pre-planned written Plan,
prepared by the Chief Officer and approved by the Master. This Plan must be discussed with and be
clearly understood by all Officers dealing with the operation. Operational measures to be
implemented before and during ballast operations are described in ³Shipboard Operations Manual´.
2.9 VESSEL GENERAL PERMIT (VGP)

For Vessels operating in U.S. waters, the requirements of the VGP shall be followed.
The VGP applies to discharges incidental to the normal operation. In this respect the Company must
meet certain requirements, including seeking coverage for most Vessels, assuring their discharges
meet effluent limits and related requirements, and requirements for inspections, monitoring,
recordkeeping and reporting.
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These requirements include:

x Submission of a Notice of Intent (NOI):If the Vessel is greater than or equal to 300 gross tons or
the Vessel has the capacity to hold or discharge more than 8 cubic meters (2113 gallons) of
ballast water, a complete and accurate NOI must be submitted, as per guidance provided in
Appendix E of the VGP.
x If the Vessel is less than 300 gross tons and has the capacity to carry less than 8 cubic meters of
ballast water, but is larger than 79 feet, submission of an NOI is not necessary, but the Vessel
must still comply with all applicable provisions of the VGP.
x Corrective Actions: In case of violation of any of the limits in the VGP, a corrective action
assessment must be carried out, investigating the nature, cause, and potential options for
eliminating the problems.
Depending upon the extent of the problem, the VGP provides deadlines for resolving the issues.
A full description of the corrective action process is provided in Section 3 of the VGP Manual.
x Routine Visual Inspections and Annual Inspections: Routine visual inspections of all accessible
areas of the Vessel must be conducted, in order to verify that effluent limits are being met.
A more comprehensive inspection must be conducted once every 12 months.
The findings of each routine visual inspection and annual inspection must be documented in the
Bridge logbook or as a component of other recordkeeping documentation.
Refer to Parts 4.1 and 4.2 of the VGP for specifics.
x Reporting: All Vessel owners or operators must submit (or must have submitted in the past) a
one-time report. For Vessels with ballast water treatment systems samples of ballast water have
to be landed to laboratories for analysis as pre relevant instructions of VGP and must submit
analytical data to EPA and/or the US Coast Guard. If Vessels have any instances of
noncompliance, they must report those instances of noncompliance to EPA annually. Refer to
Parts 4.4, 5.1, 5.2, and 5.8 of the VGP Manual for specifics.
Parts 2 and 5 of the VGP contain complete lists of effluent limits for different types of discharges
including ballast water, deck runoff, bilge water, and grey water.
Reference is made to the Vessel General Permit.
2.10 OPA-90 (OIL POLLUTION ACT 1990)

OPA-90 established statutory deadlines for Owners/Operators to:
x Prepare a VRP ³Vessel Response Plan´ (VRP) and submit it for approval to USCG.
x Comply with VRP when required (U.S. waters).
IFR (Interim Final Rule), was issued by USCG to provide guidelines for preparation and submission
of VRP as required by OPA-90.
2.10.1 Interim Final Rule±IFR

x Applicable to tank Vessels regardless of size.
x Planning applicable to discharge or substantial danger of discharge of oil that is carried in bulk.
x Requires an appendix listing relevant contacts and response resources located in US ports of call.
x Requires procedures/agreements for oil spill notification/clean-up.
Other specific requirements and information are found in instructions and publications, which are
referred to in this chapter. VRP is subject of inspection by USCG.
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2.10.2 Vessel Response Plan (Tankers)

Company managed tankers are provided with a copy of the Vessel Response Plan (VRP), which
complies with requirements of OPA 90.
Officers and other personnel are expected to be familiar with the VRP, particularly:
x Reporting requirements.
x Duties delineated in plan.
x Training & Drill Procedures
2.11 INTERNATIONAL CONVENTION ON CIVIL LIABILITY FOR OIL POLLUTION DAMAGE (1969)
This convention provides a means for securing adequate monetary compensation for persons
suffering damage resulting from discharge or escape of oil from ships.
x Frees Owner from liability when pollution is a result of acts by persons/entities over which
Owner has no control.
x Entitles Owner to limit liability under convention, though this right is forfeited if proved that
pollution resulted from Owner¶s actual fault or privacy (not sharing/ reporting information).
x Each Company¶s tanker Vessel must carry a ³Certificate of Insurance or Other Financial Security
In Respect of Civil Liability For Oil Pollution Damage´ issued by the Vessel¶s Flag
Administration. This Certificate states the type of security, the duration of the security, the name
and address of the Insurer and the date to which the Certificate is valid.
3. RECORD
x Critical Equipment De-activation MTN/SECTION 1/SF/TEC/134

x De-activation of BWTS A-11
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MISCELLANEOUS POLLUTION SOURCES Eff. Date: 29/02/2020
Contents
1. PURPOSE.....................................................................................................................................2
2. PROCEDURE...............................................................................................................................2
2.1 Hull or Bulkhead Failure........................................................................................................... 2
2.2 Machinery Operations............................................................................................................... 2
2.3 Ship-To-Ship Transfer Operations............................................................................................ 3
2.4 Inert Gas Scrubber Discharge....................................................................................................3
2.5 Hull Anti-Fouling Systems........................................................................................................3
2.6 Purging...................................................................................................................................... 4
2.7 Tank Cleaning........................................................................................................................... 4
2.8 Shipboard Energy Conservation................................................................................................4
2.9 Medical Waste........................................................................................................................... 5
2.10 Noise Pollution.......................................................................................................................5
2.11 Hazardous Materials / Hazardous Waste............................................................................... 6
2.11.1 Inventory of Hazardous Material.................................................................................................................... 7
2.11.2 Emergency Overboard Discharge................................................................................................................... 7
2.11.3 Hazardous Material (HM) Collection and Storage Containers....................................................................... 7
2.11.4 Handling Precautions...................................................................................................................................... 8
2.11.5 Rags, Mops and Sorbents.............................................................................................................................. 10
2.11.6 Protecting Drainage Systems........................................................................................................................ 10
2.11.7 Solvents......................................................................................................................................................... 10
2.11.8 Batteries.........................................................................................................................................................11
2.11.9 Spent Acid..................................................................................................................................................... 11
2.12 Other Instructions for the Prevention of Pollution...............................................................11
3. RECORD.................................................................................................................................... 12
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1. PURPOSE
The purpose of this section is to describe the procedures for controlling other shipboard pollution
sources.
2. PROCEDURE
2.1 HULL OR BULKHEAD FAILURE

During bunker and cargo operations all personnel must regularly monitor the water alongside the ship
for any indication of hull leaks.
Whilst at sea, the OOBW must monitor the sea astern of the ship for any indication of hull leaks.
Particular attention must be paid to this requirement during and after periods of heavy weather.
During all loaded and ballast passages, all empty spaces must be sounded on a daily basis in order to
detect any internal leaks at an early stage.
Every opportunity must be taken, either when alongside a jetty or from boats, to visually examine the
external hull for any sign of leaks or potential defects.
Cargo and ballast tanks must be inspected on a regular basis and inspections must include
examination for leakage or potential defects.
Whenever any tank, cofferdam or void space is entered for maintenance purposes, it must be
thoroughly examined for any sign of leaks or potential defects.
On such occasions, attention to be paid to examining the tank bottom for pitting.
2.2 MACHINERY OPERATIONS

It is not just the cargo and ballast operations or E/R bilge handling which have the potential to cause
oil pollution. Routine machinery operations can also cause pollution.
The following problems might arise on most of the ships:
x Many coolers or heat exchangers, particularly those cooling lub-oil, would cause pollution if
there are any internal leakage of lub-oil into the water stream.
x Stern tubes are always a potential source of pollution as a result of lub-oil leakage.
x Oil carry over, as the result of poor combustion, into the IG scrubber could result in pollution via
the scrubber discharge.
x Poor combustion in the boilers could result in pollution via the blow-down system.
x Boiler blow down valve flanges must have Marpol seals and must be painted in orange colour.
x Seals must be included in Form SF/TEC /135C- ³Bilge Suction/Discharge Valves Flanges Seals
Identification Register.
Every time a seal has to be removed, appropriate entries have to be made in form TEC 135C ³Oil
Record Book Supplement´ Form.
x Cylinder liner leakage could result in contamination of the main engine and diesel generator
cooling systems.
This list is not comprehensive. E/R staff must be familiar with all machinery and must be alert to the
possibility of oil pollution in the event of any internal equipment / system failures.
Close monitoring of all such equipment / systems are essential if any such leakage is to be detected.
Any unusual consumption of lubricating or bunker oils must be investigated immediately.
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Anticipated or metered usage must be compared against measurements based upon tank soundings in
order to identify abnormal usage.
2.3 SHIP-TO-SHIP TRANSFER OPERATIONS

Whilst carrying out STS operations it is normal practice to carry out COW, ballast or cargo transfer
operations between off-takes.
During these operations there is the possibility for the transfer hoses, which normally remain on
board the mother ship, to become charged with oil.
On completion of cargo discharge, the manifold valves must be closed and steps taken to ensure that
the hoses are effectively drained into the off taking ship or barge.
The hoses must be securely blanked using all the bolt holes before being raised or transferred.
If the hoses are not disconnected between off takes, prior to swinging them to the next off taker the
following procedures must be followed:
x drain all main deck lines to a cargo tank via the drop line.
x open the manifold drain valve and vacuum breaker and drain manifold lines to the drip tray or a
cargo tank.
For further information reference is to be made to the ship specific STS Manual.
2.4 INERT GAS SCRUBBER DISCHARGE

In some ports the discharges of heavy soot from the scrubber overboard discharge is regarded as
pollution.
Although the MARPOL regulations do not specifically cover the discharge of soot deposits into the
sea, ships have to comply with local requirements.
Masters must take all possible steps to ensure that such a situation does not arise and ensure that:
x The scrubber system is cleaned after use and that it is confirmed as being clean prior to arrival.
Reference must be made to the IG Manual and manufacturer's instructions.
x The scrubber system is functioning correctly and efficiently.
x There is optimum boiler control to maintain good combustion thereby keeping the carbon build
up to a minimum.
The above list is not exhaustive, as the actual procedures will depend upon the design of the
particular IG system.
If oil is entrained in any soot discharged into the sea, then the ship would be in breach of the
MARPOL, in addition to local requirements restricting heavy soot discharge.
2.5 HULL ANTI-FOULING SYSTEMS

Anti-fouling paint is applied to the hull in order to prevent the build-up of marine growth which
would otherwise reduce the speed of the ship and increase her fuel consumption.
Certain types of anti-fouling paints that include tri-butyl-tin (TBT) compounds can create adverse
impacts on the marine environment and human health. TBT or Tri-Butyl-Tins or Tri-organotins are
chemical compounds, containing at least 3 bonds between carbon and tin.
These paints slowly leach out organotin compounds which act as biocides against certain marine
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organisms.
Vessels will therefore need proof of compliance to the International Convention on the Control of
Harmful Anti-fouling Systems and this will be in the form of an International Anti-Fouling System
Certificate issued by the Flag Administration or an Organization duly authorised by it.
In addition, the Flag Administration will require a Declaration signed by the Company stating that
the coating is compliant with the Convention along with the types of coating and date of application.
A Deck Officer must be responsible for supervision of hull and underwater painting.
Painting shall be carried out in accordance with the suppliers' suggestions and recommended painting
schemes.
Particular attention must be paid to the following:
x Environmental conditions (especially important prior to first primer coating application).
x Proper thickness of successive coatings.
x Application of antifouling paint at a proper time prior to undocking.
x No antifouling paint shall be admitted without ȉǺȉ-Free antifouling Certificate issued or
approved by the Vessel¶s Class.
For further details and best practices reference is made to the stand alone Ship-Specific Biofouling
Management Plan.
2.6 PURGING
Purging or venting of cargo tanks within port limits must only be conducted after permission has
been obtained from the Port and/or Terminal authorities.
2.7 TANK CLEANING

Tank cleaning (water washing) must not be carried out within Port limits, unless permission has been
obtained from Port/Terminal authorities.
It must be carried out in such a manner that prevents emissions of hydrocarbon vapours to
atmosphere.
If tank vapours have to be vented for operational reasons, then prior to doing so, permission must be
obtained.
An entry is to be made in the Bridge logbook of such permission being granted along with the actual
times of venting.
2.8 SHIPBOARD ENERGY CONSERVATION

The Company recognises that the burning of fossil fuels, such as diesel and heavy fuel oil, can result
in many environmental impacts.
When fuel is combusted, pollutants such as the oxides of Carbon, Nitrogen and Sulphur are emitted
to the atmosphere.
These can contribute to the effects of greenhouse gases and acid rain.
The prime way in reducing the effects of the above emissions is to efficiently control and conserve
energy wherever possible.
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This can be done through the Ship¶s Energy Efficiency Management Plan (SEEMP) by ensuring that:
x The main and auxiliary engines are operated according to the manufacturer¶s instructions.
x The main and auxiliary engines are properly maintained as per the manufacturer¶s instructions
and the Vessel¶s PMS.
x Funnel exhaust is correctly monitored to ensure efficient combustion.
x Speed is correctly adjusted to avoid excess fuel consumption whilst staying within the parameters
of the charterer¶s requirements for speed and ETA¶s.
x Speed is reduced in heavy weather to avoid excess pounding and consumption.
x The automatic pilot is correctly adjusted to avoid frequent and excess helm movements.
x The condition of ship¶s bottom is regularly inspected for signs of fouling or damage to coating.
x The condition of the ship¶s propeller is regularly inspected for signs of damage.
x Ancillary systems, including lighting, ventilation systems, galley ranges, steam supplies, etc are
turned off when not required, etc.
The Company is committed to environmental training including energy conservation.
The Company shall also ensure that records of energy conservation are kept and periodically
reviewed.
Any non-conformities relating to energy conservation shall be identified and corrected.
Reference is made to the stand-alone ship-specific Ship Energy Efficiency Management Plan and
002-PRO-Procedures / PROC 25 - Environmental Issues and PROC 26 ± Energy Efficiency Issues.
2.9 MEDICAL WASTE

Refer to the Shipboard Operations Manual (007)±Section 09- Garbage Management - 2.9- Medical
Waste.
2.10 NOISE POLLUTION

Control of noise emission is an important aspect of pollution control.
Noise above certain sound levels can cause a wide variety of unwanted effects on personnel, ranging
from discomfort and anxiety to illness and deafness.
Except for navigational and testing requirements and during actual emergencies, alarms must be
operated only to the extent necessary to assess proper operation.
Use of the general announcing circuit must be curtailed.
Topside speakers must not be used unless absolutely necessary.
The use of powered tools and machinery or any other devices which emit excessive must be
restricted to normal working hours when possible.
The use of powered tools, machinery, outboard loudspeakers, or any other devices that emit
excessive noise, either directly or indirectly through re-radiation, shall be restricted to normal
daylight working hours to the maximum possible extent.
Underwater noise pollution is also an important aspect of pollution control.
Since, as per the UN Conference on Trade and Development (UNCTAD), the seaborne trade is
increasing year by year, along with the traffic, the noise also increases. This affects how marine
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species communicate for finding food and their mates or avoiding predators. As such, when the
sound of the ships matches the frequency of their communication signals, this affects them internally.
In 2014, IMO approved guidelines on reducing underwater noise from commercial shipping, to
address negative impacts on marine life. The Guidelines focus on primary sources of underwater
noise, namely on propellers, hull form, on-board machinery, and various operational and
maintenance recommendations such as hull cleaning.
The biggest part of the issue comes from cavitation caused by sub-optimally performing propellers.
Company optimises the propeller and other related parts such as nozzles, rudder, even the hull form
in her newbuilding and retrofit projects drastically reducing the level of underwater sound.
Underwater inspection of the propeller and in most cases polishing and cleaning has been established
on an annual basis.
Please also refer to Procedure 26 ± Energy Issues for all actions related to underwater cleaning,
Procedure 04/2.7 - New-Building Policy and Environmental Programs related to Newbuildings.
Regarding the increase of shipping traffic and the impact on mammals such as belugas and whales
which rely on a quiet environment to communicate and forage, company follows local regulations
about speed reduction even these are applied on a voluntary basis.
Restriction on Vessel speed will reduce the likelihood of collisions and contribute to reducing noise
levels.
Once a state worldwide announces initiatives for special zones where speed reduction measures will
be applied, the Vessels Masters and Officers will be informed accordingly either by EMS Circulars
or by daily communication with the office prior their calls in order to comply accordingly.
2.11 HAZARDOUS MATERIALS / HAZARDOUS WASTE

This section provides guidance applicable to shipboard management of used Hazardous / Potential
Dangerous Material (HM).
Any material that, because of its quantity, concentration, or physical or chemical characteristics, may
pose a substantial hazard to human health or the environment when incorrectly used, purposefully
released, or accidentally spilled.
Subcategories of Hazardous Material (HM) / Hazardous Waste include:
x Flammable / combustible materials
x Toxic materials
x Corrosive materials (including acids and bases)
x Oxidizing materials
x Aerosol containers
x Compressed gases
x Cleaning waste fluids and contaminated materials (chemicals)
x Photo Copying and Laser Printer Cartridges
x Unused And Outdated Pharmaceuticals
x Fluorescent And Mercury Vapour Lamp Bulbs
x Batteries
The Chief Officer has the overall control of the shipboard Hazardous Materials (HM) and is tasked
with effecting proper management of all shipboard Hazardous Materials.
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Personnel protection is necessary in every phase of Hazardous Materials and used / excess Hazardous
Material operations. Proper clothing and teamwork is a must when handling HM.
Many shipboard chemicals and HM will react spontaneously when in contact with each other, and so
shall not be mixed, stowed, or handled together. Mixing these incompatible HM¶s can produce heat
or pressure, fire or explosion, violent reaction, or toxic, irritating, or flammable dusts, mists, fumes,
or gases.
Not all unlike substances react violently as soon as they are combined. Dissimilar substances form a
mixture that is potentially dangerous when a third factor, such as open flame, is applied.
2.11.1 Inventory of Hazardous Material

The (IHMB) provides shore based management and ships¶ crew with the capability for determining
HM authorized in order to maintain an accurate inventory of potential hazardous materials, and to
preclude stocking of dangerous material for which the ship has no use.
Chief Officer of each ship shall keep on board the ³Dangerous Goods and Hazardous Substances
List´.
This inventory shall be kept also by the Environmental Representative.
Any change in the status of Shipboard Hazardous Materials must be communicated to the
Environmental Representative.
Reference is made on EMS / SECTION10/ 2.3.4 Excluding Materials and 2.4 Hazardous Materials
cannot be Purchased or Brought onto the ship.
Reference is also made in 002-PRO-Procedures / PROC 08_PURCHASING / 2.4.4 Forwarding
Goods to the Vessels for IHM and stand-alone ship-specific Inventory of Hazardous Materials and
Ship Security Plan.
2.11.2 Emergency Overboard Discharge

If Hazardous Materials (HM) must be discharged overboard under an emergency situation, the ship
shall follow the procedure below.
The following information accompanying any emergency release of HM shall be maintained and
included in any message release:
x The physical and chemical characteristics of material dumped.
x Precise times and location of dumping.
x Explanation of how human life at sea was in danger and how the emergency dumping reduced the
danger.
The crew shall prepare for possible HM spills. Overboard spills of HM can have a serious impact on
the environment.
2.11.3 Hazardous Material (HM) Collection and Storage Containers

Correct identification of used / excess Hazardous Materials is necessary to ensure its safe collection,
handling, stowage onboard and its proper disposal ashore. Identification of a used / excess HM
requires knowledge of the material, operation, or process from which the material originated.
A material is hazardous not only if it results from using HM but also if a non-HM has been
contaminated with a HM (for example, rags contaminated with solvent).
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Used / excess HM must NOT be added to any container that once held dissimilar or incompatible
materials.
This is essential to avoid any violent chemical reactions.

All used / excess HM that is collected and stored for disposal ashore shall be kept in containers that
are durable enough to resist damage from routine handling and that are suitable for the particular
used / excess HM they contain.
Containers shall carry clear warning labels. Each container would ideally be reused only to collect as
used / excess HM the same substance it originally contained as HM.
Inspect containers for damage to: closures, open head drum covers, rims, gaskets, and body surfaces.
Discard containers with serious defects, such as pitting, deep rust, creases, or cracks.
If there is any question regarding the integrity of the original container, the contents shall either be
transferred to a new container or the damaged container shall be placed into an ³over pack´ container
(a steel drum with removable cover.
The over pack container shall be filled with sorbent material to absorb possible leakage and to
prevent movement of the original container in the over pack container.
The following are additional guidelines for empty containers:
x HM containers suitable for reuse shall be safeguarded against incidental damage.
x Empty HM containers can contain hazardous, vapor producing residues. Seal the containers
tightly, and store in the same manner as full HM containers until reused to store similar HM. The
original hazard labeling shall remain on these containers.
Some shipboard HM containers are non-reusable or one-trip.
These containers are stamped or marked NRC (for non-reusable container) or STC (for single trip
container). Such containers are never reused for the storage of used / excess HM.
They shall be kept tightly sealed and stored as used / excess HM until final disposal.
2.11.4 Handling Precautions

Used / excess HM released into the ship¶s environment through improper handling can adversely
affect both personnel and the ship¶s structure.
These substances, if inhaled or contacted directly by personnel, can cause injury or irritation; they
can also accelerate corrosion or pitting of decks or other ship structures.
Additionally, injury can result from improper container handling.
Handling used / excess HM requires the same safety precautions as handling HM.
Personnel may need protective clothing and equipment when handling used / excess HM. Because
degrees of hazard differ for various substances, personnel shall match protection requirements to the
hazards of each particular used / excess HM. Address any questions concerning protection
requirements to the ship¶s Chief Officer.
Personnel must work in teams when transferring or handling used / excess HM.
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At least two (2) crewmen with appropriate personnel protective equipment, i.e
( protective clothing, gloves, face shield, and respirator ),
shall handle the transfer of used / excess Hazardous Material:
x One (1) crewman to effect the Transfer, and
x One (1) to assist or remain on Emergency Standby.
Showers and eyewash fountains must be ready for use where corrosive chemicals are used.
These Self-contained supplies of potable water for eyewash shall be of sufficient capacity to provide
a minimum of fifteen (15) minutes of eyewash.
Strategically place fire extinguisher, suitable to common used / excess HM types (class A or B fire
risks), within the used / excess HM transfer area.
Provide HM spill containment barriers in and around HM and used / excess HM transfer areas.
These barriers may include:
x coamings,
x partitions,
x protective coverings for decks, and self-closing or manually closing deck drains.
Containment barriers must be able to contain the maximum amount of transferred used / excess HM.
When transferring HM, observe the following safety procedures for two-wheeled hand trucks and
other transport equipment:
x Keep the load¶s center of gravity as low as possible. Place heavy objects on the bottom. When
loading transport equipment, keep feet clear of the wheels.
x Place the load so the weight will be carried by the axle, not by the handles.
x Place the load so it will not slip, shift, or fall. Load only to that height where the view ahead
remains unobstructed.
x Raise a two-wheeled truck or dolly cautiously to traveling position from its horizontal loading
position, to prevent slippage and overturning.
x Never walk backwards with a handcart or dolly except when necessary to go up or down an
incline. When going down an incline or steps, keep truck or cart ahead. When going up, keep
truck or cart behind.
x Wear protective shoes and gloves when using transport equipment.
x Take extreme care if drums must be rolled on their bottom edge or rim; such rolling can result in
dropping the drum, which could release the head cover (if clamped with a circular ring clamp) or
burst the drum and discharge its contents.
x Raise and lower material through hatches in accordance with safety procedures.
x Use extra caution when lifting a load across a sill. If necessary, unload the transport device; lift
the containers and device individually across the sill; and then reload the device.
x During used / excess HM transport, use passageways with the minimum number of doors, deck
level changes, and cramped transit zones.
x Avoid areas where used / excess HM could ignite or come into contact with ship¶s personnel.
Also avoid hot work areas, living spaces, and restricted areas.
x Stowage facilities must be appropriate and meet the storage requirements associated with the
collected used / excess HM (e.g., flammable stowage).
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x Used / excess HM stowage and handling areas shall be clean, dry, uncluttered, and free from
combustible refuse to prevent container corrosion, prevent fires, and facilitate emergency
access. Inspect these areas weekly and correct any problems.
x Replace damaged or leaking containers immediately.
Damaged PCB containers shall be packaged in an approved tightly sealed container. Clean up
used / excess HM spills immediately.
x Correct slippery conditions promptly.
x Remove any water that has collected in the stowage area or on used / excess HM containers;
for example, water on the top of an upright drum could corrode the lid.
x Many used / excess HM¶s are flammable.
Inspect fire extinguishing systems and equipment for proper working order.
x Check permanently installed fire extinguishing systems for such problems as inadequate
pressure or quantity of agent, corrosion, and leaking joints.
x Also inspect portable fire extinguisher according instructions or at least monthly.
Replace extinguisher immediately if they are below minimum required pressure, below
required quantity of agent, or discharged.
Smoking and open flames are prohibited in used / excess HM stowage areas.
Flammable or toxic atmospheres can develop within poorly ventilated used / excess HM stowage
compartments. Standard shipboard ventilation equipment will usually provide the required airflow in
used / excess HM stowage compartments.
However, additional airflow to the atmosphere may be required in these spaces at certain times,
portable explosion-proof ventilation units may be used in such situations.
Harmless items contaminated by HM shall be collected and disposed of in the same manner as the
contaminating substance; special precautions shall be taken when PCBs are the contaminants.
2.11.5 Rags, Mops and Sorbents

Refer to Shipboard Operations Manual (007 ±Section 09- Garbage Management- 2.8-³Hazardous
Materials and Special Wastes´.
2.11.6 Protecting Drainage Systems

If discharged through the ship¶s drainage system, caustic or corrosive used / excess HM may damage
the ship¶s piping.. Additionally, the discharged waste may react violently with incompatible residues
present in the piping. Therefore, all industrial waste water (for example acid cleaning, solvent
cleaning, and painting materials) shall not be disposed of through ship¶s sewage or graywater
systems. If used / excess HM is discharged overboard through the drainage system first dilute with
large amounts of seawater. Acids and alkalis shall be neutralized before dilution. All drains shall be
rinsed to remove any residues of the disposed waste after discharge.
2.11.7 Solvents
Refer to Shipboard Operations Manual (007) ±Section 09- Garbage Management 2.8-³Hazardous
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2.11.8 Batteries
Refer to Shipboard Operations Manual (007) ±Section 09- Garbage Management 2.8-³Hazardous
2.11.9 Spent Acid

Spent acid shall be neutralized and diluted before discharge overboard through the drainage system.
To neutralize acid, slowly add sodium bicarbonate or a weak alkaline (basic) solution to the acid.
The neutralized acid solution can then be safely diluted with large amounts of seawater and flushed
overboard through the drainage system. The overboard discharge of neutralized acid solution from a
HM spill is permitted and the acid solution shall be contained safely for later disposal.
2.12 OTHER INSTRUCTIONS FOR THE PREVENTION OF POLLUTION

There is a number of other sources of oil pollution, many of which individual actions can address
successfully.
When draining or collecting waste oil from any equipment, it must always be returned to a designated
tank or container for later disposal. It must NEVER be disposed of overboard and must NEVER be
flushed down toilets or sinks.
Never over grease or over lubricate machinery, particularly deck machinery, as the excess will
simply run off and be a potential source of pollution.
Residues removed from a bunker tank prior to repairs must NEVER be disposed off overboard.
They must be stored in drums onboard for later return to the tank or disposal to a shore reception
facility as per the Vessel¶s Garbage Management Plan.
This applies equally to the small amounts accumulated during onboard repairs or the large volumes
collected prior to shipyard repairs.
Hydraulic oil can cause pollution.
During cargo and ballast operations, personnel must be alert to the possibility of leaks from small
bore cargo ȞalȞe hydraulic lines.
Whenever machinery oil is changed, e.g. winch gear case oil, the old oil must be pumped into a drum
or container or transferred direct to sludge and / or slop tank.
It must never be discharged into the sea.
Whenever any maintenance is being carried out, which might result in the spillage or release of oil,
always ensure that sorbent materials are readily available.
Spilled oil must always be cleaned up immediately.
When in port or at anchor, the area in the vicinity of the ship must be carefully monitored for signs of
oil on the water which might drift towards the ship.
Never attempt to clean an oil spill at sea by your own initiative and never drop cleaning chemicals
directly onto the sea.
In such cases, the local authorities must be advised and an appropriate entry made in the Bridge
logbook.
Similar action must be taken if signs of oil are encountered during coastal passages, river transits etc.
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3. RECORD
Garbage Management Plan SOM/SECTION 09 SF/MRS/213
Placard 1-Garbage Disposal Regulations SOM/SECTION 09 SF/MRS/212A
Placard 2-Garbage Management Plan SOM/SECTION 09 SF/MRS/212B
Dangerous Goods and Hazardous Substances List Ship Security Plan/SF/SEC/915
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OFFICE ENVIRONMENTAL REQUIREMENTS Eff. Date: 29/02/2020
Contents
1. PURPOSE.....................................................................................................................................2
2. PROCEDURE...............................................................................................................................2
2.1 Recycling and Energy Conservation in Office..........................................................................2
2.1.1 Recycling.........................................................................................................................................................2
2.1.1.1 Paper, Plastic and Aluminum.............................................................................................................................. 2
2.1.1.2 Batteries...............................................................................................................................................................2
2.1.1.3 Ink Cartridges...................................................................................................................................................... 2
2.1.1.4 Office Lamps, Electrical Devices and Computer Hardware............................................................................... 3
2.1.2 Energy Conservation....................................................................................................................................... 3
2.1.2.1 Electricity............................................................................................................................................................ 3
2.1.2.2 Water................................................................................................................................................................... 3
2.2 Environmental Work Instructions............................................................................................. 3
2.2.1 Purpose and objective......................................................................................................................................3
2.2.2 Environmental Aspects................................................................................................................................... 4
2.2.3 Specific Policy.................................................................................................................................................4
2.2.4 Environmental Objectives............................................................................................................................... 4
2.2.5 Scope of Application....................................................................................................................................... 4
2.3 Environmental oriented practices.............................................................................................. 4
2.3.1 Electricity........................................................................................................................................................ 4
2.3.1.1 Air Condition Unit Energy Efficiency............................................................................................................ 4
2.3.2 Water............................................................................................................................................................... 5
2.3.3 Paper................................................................................................................................................................5
2.3.4 Battery Management....................................................................................................................................... 7
2.3.5 Other Products & Materials Consumption...................................................................................................... 7
2.4 Office Waste Management........................................................................................................ 7
2.4.1 General............................................................................................................................................................ 7
2.4.2 Resource Management Methodology..............................................................................................................8
2.4.2.1 Contamination/Pollution Control.................................................................................................................... 8
2.4.3 Responsibilities............................................................................................................................................... 9
2.5 Other Activities......................................................................................................................... 9
3. RECORD...................................................................................................................................... 9
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1. PURPOSE
This section describes the procedures implemented by the Office for recycling, energy conservation
and other environmental issues.
2. PROCEDURE
2.1 RECYCLING AND ENERGY CONSERVATION IN OFFICE
2.1.1 Recycling
2.1.1.1 Paper, Plastic and Aluminum
The Company has a contract with the company ³Elliniko Kentro Anakyklosis´, which specializes
on the recycling of:
x Paper,
x Aluminium, and
x Plastic
This Company has provided special receptacles for separating paper, aluminum and plastic
wastes.
Paper, Plastic and Aluminum are collected in regular intervals (i.e. when the receptacles are
filled), and a special receipt is issued on a Monthly basis.
This receipt is held in the files of the Office Administrator.
The Company as a member of Green Angels, supports the initiative to collect plastic covers,
which are destined for recycling in order to be "turned into" wheelchairs for our fellow humans
in need. A wheelchair is equivalent to a ton of caps; equivalent to about 540,000 pieces of plastic
covers.
A special carton bin has been installed in order to collect plastic covers separately. A large
number of plastic covers and has been already collected and delivered to Green Angels with the
aim not only to recycle plastic caps but also turn them into wheelchairs that will be offered to our
fellow humans in need.
This particular initiative is being implemented in partnership with the Pan-Hellenic Association
for the Prevention of Traffic Accidents in Minors "Love for Life", identifying the important
environmental objective of recycling with a great social act.
2.1.1.2 Batteries
A recycling bin provided by AFIS has been placed in a specific point of the office building ,
where the expired batteries are placed.
When the box is filled, AFIS is contacted for collection and relevant receipt is received.
Batteries which are used in the Office are also recycled.
2.1.1.3 Ink Cartridges

Ink Cartridges are collected by the IT Department and delivered to the Hewlett-Packard (HP).
Relevant receipts are received.
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2.1.1.4 Office Lamps, Electrical Devices and Computer Hardware

Office lamps are collected in a specific bin.
When an adequate quantity of lamps is collected they are delivered to ³Fotokiklosi´ and relevant
receipt is issued.
Electrical devices and Computer Hardware are collected by IT department and disposed
periodically to electronic stores in order to get recycled and relevant receipt is issued.
2.1.2 Energy Conservation

Energy Efficiency Certificates have been published for each and every floor of Company¶s premises
as per regulation on Buildings Energy Efficiency (K.E.N.A.K.) and Dir.2002/91.EC.
2.1.2.1 Electricity
The Company has established the following procedure for the conservation of electric energy:
x All the Office Lights are of the ³PL´ type, which are designed for energy conservation.
x The Office Lights are switched on every morning, by the Office Secretary/receptionist, at
9:00 am- official opening hour of the Company.
x In the evening, they are switched off by the Office Cleaning Team, as each office space is
cleaned.
x The Building Security Personnel have been instructed to make a final Patrol at 23:00 pm to
ensure that all the lights are closed, and that various electric appliances (coffee pots, water
boilers etc) are switched off.
x All Office Personnel have been instructed to switch off their computers before leaving the
Office.
x Contracts are available for the maintenance of air conditioning etc for energy conservation (a
well maintained electric appliance consumes less energy).
x Installation of lighting systems with motion detector in non-public areas of the building (e.g.
WCs and lavatories).
2.1.2.2 Water
The Company has established the following procedure for the conservation of water:
x Once a day, the Building Security Personnel check the water counters to ensure that there are
no leakages, extreme consumption etc.
x The Company has a contract for the maintenance of water pipelines etc, to ensure that no
water is leaking etc.
x The Building Security Personnel have been instructed to make a final patrol, at 23:00 to
ensure that no taps are running.
x Installation of dual flush cisterns.
2.2 ENVIRONMENTAL WORK INSTRUCTIONS
2.2.1 Purpose and objective

These Work Instructions are established following the implementation of an EMS according to ISO
14001 in our Company, aiming to eliminate depletion of resources related to our activities and to
promote environmental best practices.
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2.2.2 Environmental Aspects

x Electric energy consumption.
x Fresh water consumption.
x Paper consumption.
2.2.3 Specific Policy

x Rational use of electric energy.
x Rational use of fresh water.
x Rational use of paper.
2.2.4 Environmental Objectives

x Continual reduction of specific consumption of electric energy.
x Continual reduction of specific consumption of fresh water.
x Continual reduction of specific consumption of paper.
2.2.5 Scope of Application

These Work Instructions apply to all shore side and shipboard staff, related to Company¶s
operations and activities.
The instructions are not exhaustive.
Personnel is encouraged to take common sense initiatives that may contribute to energy
saving.
It is also strongly suggested that everyone might take similar measures in his personal and
social life and set an example for fellow employees.
2.3 ENVIRONMENTAL ORIENTED PRACTICES
2.3.1 Electricity
x Turn-off lights when you are the last to leave
x Turn-off equipment not needed for continuous use
x Shut-off domestic appliance when you do not need them
x Use stand-by or energy saving mode in electronic devices, if available
x Window blinds/shades must be closed in summer during daylight to prevent office
overheating and in winter during dark to avoid heat losses
x Use steps rather than the elevator, in particular when going down. Energy is saved and it
is a good exercise
x Use warm rather than hot water
x Avoid frequent opening of doors or windows to minimize heating or cooling losses
x Follow Authorities and Public Power Corporation instructions through press, radio, TV
channels, concerning reduction of energy consumption during peak hours.
2.3.1.1 Air Condition Unit Energy Efficiency

Efficient use of air conditioning central or local units must be ensured. The basic steps to be
taken include:
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x Local units and fan coils must be shut down when no personnel is present in the office.
x Central unit temperature settings must be lowered 3-4 & during after office hours
(conservation mode).
2.3.2 Water
x Water taps must tightly closed to avoid dripping.
x Leaks in plumbing fixtures must be promptly reported to repair staff.
x Amount and flow of water in WC must be adjusted as required.
x Watering of the grass around the building must be adjusted according to weather
conditions.
x Follow Authorities and Public Water Corporation instructions through press, radio, TV
channels, concerning reduction of water consumption during peak hours.
2.3.3 Paper
Most of the waste production from office activities is paper, e.g. printer and photocopy paper,
stationary, packaging material etc. It is accepted that paper, in particular printers and copiers,
accounts for more than 50% of solid waste of an office.
The main effort must be directed to ³Reduce¶¶ by changing habits and/or implement specific
measures.
Photocopy
x Make only the amount of copies needed. Think before you print.
x Copy documents double-sided when possible.
x Be familiar on how to use the copier.
x Keep the copier in top running order properly maintained, timely changing toner.
x Before printing, see if reducing margins will fit more on fewer pages.
Filing, Circulation and Communication

x Edit on computer screen to avoid printing multiple drafts
x Use electronic file(s) to the maximum extent. It is the Head of Departments¶ task to define
required hard-copies and electronic files within their department
x Develop a ³pending´ browse (file) in your computer to file temporarily messages
requiring action soon, rather than printing out them and lost in desk papers
x Wherever possible, modify the format of standard documents to use less paper e.g. margin
width, space between paragraphs/ lines, etc.
x Post documents of general information or much better distribute them electronically,
rather than in hard copies. File them in a central electronic folder for future reference.
x Regularly review and update distribution lists on a ³need to know¶¶ basis
x Send internal memos electronically rather than written memos or messages copied
x Collect scrap paper and use the clean side for notes, informal messages, drafts, etc.
Recovered paper and paperboard needs to be clean, dry, and free of contaminants in order for
industry to use it as a raw material for making new paper products.
Although small amounts of contaminants may be acceptable in certain paper products, steps
must be taken to limit contaminants as much as possible.
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Contaminants can severely injured workers and damage equipment, which can lead to
expensive downtime at the paper mill. Broken glass, in particular, is a serious hazard.
Contaminants include, though are not limited to:

x Plastic (e.g., report covers, spiral bindings)
x Glass
x Metal
x Most tapes, glues, and some adhesives (e.g., sticky notes, self stick labels, book binding)
x Food wastes
x Some coatings
Other Initiatives:
x Review subscriptions to newspapers and magazines and eliminate the unnecessary ones
x Share newspapers, magazines and books with colleagues
x Establish a common circulation systematic approach for newspapers and magazines
x Re-use file folders and dividers
x Re-use cardboard boxes
x Check commonly ordered supplies. Packaging paper may be reduced by ordering in bulk
x Null, invalid and useless paper documents have to be separated from domestic garbage
and disposed according to municipality¶s garbage disposal programs
x Loose leafs of A4 paper must be placed in the bins free from any metal staples or clips
x At the end of daily work, cleaning staff must collect all waste paper from the bins and
dispose it to applicable recycling bin. Employees will be informed about paper disposal
results on a quarterly basis.
Paper Recycling
Up to 50% of office waste is recyclable paper.
By diverting usable paper from the waste stream, we help to reduce the volume disposed in
garbage sites.
Recycling paper also reduces the need for virgin wood pulp (1 ton of paper production
requires 19 trees).
Paper production from recycled paper requires less energy and creates less air and water
pollution than using virgin pulp.
It is also expected that any expenses or effort to separate paper from other waste, will be
compensated by income from the sale or recycled paper.
The Heads of Departments are responsible to implement and monitor the progress of the
Program within their Departments.
The EMR is responsible to co-ordinate the activity and submit evaluation reports.
The main effort of paper recycling activity is directed to ³COPIERS¶ and ³PRINTERS´ A4
paper which presents a significant volume of waste.
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2.3.4 Battery Management

Not all batteries have the same type. Some are non-toxic (such as alkaline or lithium types),
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This is why it is very important to be aware of the following guidelines in battery safety in
order to reduce the risk of fire and to safeguard the safety of the user and the environment:
Instructions on safe handling of batteries
x Install and use batteries properly;
x Keep batteries dry and away from any heat sources (including direct sunlight);
x Remove batteries from equipment when not in use;
x Install batteries in well ventilated areas to prevent the build-up of explosive gases;
x Remove depleted or weak batteries from device;
x Enforce No Smoking policies in the battery storage/charging area;
x Wash area of skin with soap and water if exposed to battery electrolyte. If acid enters the
eyes, rinse them thoroughly with cold running water and consult a doctor;
x Avoid mixing batteries of different chemistries, ages or brands and avoid using damaged
batteries;
x Do not attempt to charge non-rechargeable batteries;
x Do not charge batteries in temperatures higher than 40oC;
x Do not connect batteries in parallel;
x Lithium batteries must be placed one by one in a plastic bag to reduce fire hazard. All
other types (chemistries) must be stored by placing tape over the electrodes (poles).
2.3.5 Other Products & Materials Consumption

The Purchasing department, handling also several office supplies, must carry our market
research for the selection and order process focusing on the following criteria:
x Bulk supplies are preferred over separate packaging.
x Re-usable parts are preferred, such as rechargeable batteries.
x Energy saving material is also preferred such as fluorescent lamps, printers and copiers
with double-side capability.
x Non-polluting products and chemicals are preferred.
x Devices/equipment having long service life and good after sales services are preferred.
x Environmentally friendly suppliers¶ preference.
x Preference of products marked with the Environmental µ¶Eco¶¶ Logo.
x Use/prefer non disposable equipment.
2.4 OFFICE WASTE MANAGEMENT
2.4.1 General
The control of the office and ships activities with an impact to the environment is of high
priority and requires efforts from all employees, including changes in everyday living and
working habits. The following instructions define how office and ships activities can be more
environmentally friendly.
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Office activities are divided in 2 main categories i.e. resources consumption including energy
and garbage management. The target is to make the most efficient use of resources, material,
electricity, heat and water, as well as to reduce the quantity of garbage and minimize the
impact from contamination.
2.4.2 Resource Management Methodology

The key words for efficient use of resources are:
Reduce, Re-use, Recycle and Recover (4R).
Reduce
Wherever possible, it would be best to reduce material, energy and water consumption, so as
to produce as little waste as possible.
Re-use
Once a product or material, solid, liquid, energy, etc has been used, every effort must be made
to re-use it, if feasible.
Recycle
Recycling must be considered only for materials and products that cannot be re-used.
Although, recycling does help to converse resources and reduce waste, there are economic
and environmental costs associated with waste collection and recycling process. Company¶s
involvement is restricted to the collection and forwarding of material for recycling.
Recover
It may be possible to recover materials or energy from solid waste that cannot be reduced, re-
used or recycled at source. However, it is a specialized activity, not within Company¶s
capabilities.
2.4.2.1 Contamination/Pollution Control

Minimizing chemical contamination or pollution of the environment is an important
objective. Many of the products used in the office contain ingredients that are harmful to the
environment therefore, every possible effort must be made to retain these substances out of
the air, water and waste stream.
In principle, the resources management methodology is applicable.
The best way to minimize pollution from environmentally harmful materials is to reduce the
use of products containing such materials to a minimum, by changing processes or by
substituting them with more environmental friendly products.
Where reduction is not possible, chemicals must be re-used (as long as this is permitted under
applicable regulations). Similarly, chemicals that cannot be reduced or re-used must be
recycled wherever possible.
Many products and wastes contain toxic chemicals in insufficient quantities or concentration
to be considered as hazardous under current legislation, but must still be used and disposed of
with care.
Products such as correction fluid, markers, dry cell batteries, photocopy toner and cleaning
products contain small quantities of harmful substances, and wastes from their use (e.g. spent
containers, soiled rags) can be considered as ³environmentally harmful´. Although the
quantity of harmful material in any individual product or waste container may be small, the
cumulative effect to the environment of a large number of these wastes is significant.
Initial Data Collection
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Implementing the Waste Management procedures, current practices must be examined and
changes must be considered.
Opportunities to Reduce, Re-use and Recycle, to save energy and to improve the management
of chemicals must be investigated as well.
It is expected that a lot of cases will be activities that individuals can do their own, by
changing their attitudes and habits.
Other cases will require substantive involvement from managers, personnel and external
parties.
Some will be simple, with low or no-cost; others will require the development of existing
infrastructure or supply of new equipment.
To address all of the above cases the following two-fold approach has been selected:
x Cases that data is not available or cannot be measured or determined. Mostly, they are
simple cases of no or low-cost implementation that mainly require changes in habits.
x Cases that data must be collected and measured prior to define targets. The process
includes the development of Environmental Programs, as defined in the EMS.
2.4.3 Responsibilities
All Managers are responsible to implement selected environmental programs encouraging all
employees in taking initiatives that promote environmental issues, as well as assigning
responsibilities for the monitoring of relevant activities and evaluating the results.
EMR and DEMR are both responsible to coordinate actions as required.
2.5 OTHER ACTIVITIES

Other office related activities may contribute to save energy or reduce environmental
pollution.
x Use public transportation when possible.
x Organize a car pool and encourage others to do the same.
x Use email, rather than tel/con or fax.
Communicate any new ³green¶¶ ideas to colleagues. ³Green Boards´ are available to post
environmental information, announcements, posters, results of implemented programs, etc.
Since September 2015, the Company is a member of ³Green Angels´, a Standard Greek
Community for Environmental Responsible Business founded by ICAP Group and Greenit
Environmental.
The main objective is the activation of business community for coordinated reduction of the
environmental footprint of Greece.
Also, the company has been certified with ISO 14064:2012 and verified by Eurocert with
annual endorsement of certificates for all emissions and environmental footprint raised by
employees¶ activities and their transportation from and to the office and from and to the
Vessels.
Reference is made on stand-alone Prime Marine GHG Information Management System and
annual Carbon Footprint Report.
3. RECORD
None
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SHIP RECYCLING Eff. Date: 29/02/2020
Contents
1. PURPOSE.....................................................................................................................................2
2. PROCEDURE...............................................................................................................................2
2.1 Introduction............................................................................................................................... 2
2.2 Ship Recycling Policy............................................................................................................... 3
2.3 Inventories of Hazardous Materials.......................................................................................... 3
2.3.1 Inventory of Hazardous Materials...................................................................................................................3
2.3.2 Inventory of Hazardous Materials for New Vessels....................................................................................... 5
2.3.3 Inventory of Hazardous Materials for existing ships...................................................................................... 5
2.3.4 Excluding Materials........................................................................................................................................ 5
2.3.5 Maintenance of the Inventory Hazardous Materials....................................................................................... 5
2.4 Hazardous Materials cannot be Purchased or Brought onto the ship........................................6
2.5 Other Activities for Ship Recycling.......................................................................................... 6
2.5.1 Preparation for ship recycling......................................................................................................................... 6
2.5.2 Ship Recycling Plan........................................................................................................................................ 7
2.5.3 Surveys and Certificates..................................................................................................................................7
2.5.4 Initial notification and reporting requirements................................................................................................7
2.6 Development of Part I of the Inventory for existing ships........................................................ 7
2.6.1 Step 1: Collection of necessary information................................................................................................... 8
2.6.2 Step 2: Assessment of collected information.................................................................................................. 8
2.6.3 Step 3: Preparation of visual/sampling check plan......................................................................................... 8
2.6.4 Step 4: Onboard visual/sampling check.......................................................................................................... 9
2.6.5 Step 5: Preparation of Part I of the Inventory and related documentation...................................................... 9
2.6.6 Testing Methods.............................................................................................................................................. 9
2.6.7 Diagram of the location of Hazardous Materials on board a ship.................................................................10
3. RECORD.................................................................................................................................... 10
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1. PURPOSE
This procedure describes the Company¶s commitment to the voluntary implementation of the Hong
Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009,
and undertakes to give effect, to the greatest possible extent, to its provisions in order to prevent,
reduce, minimize and, to the extent practicable, eliminate accidents, injuries and other adverse effects
on human health and the environment caused by Ship Recycling, and enhance ship safety, protection
of human health and the environment throughout a ship¶s operating life.
It also adopts the Regulation (EU) on ship recycling No 1257/2013, which amends Regulation (EC)
No 1013/2006 and Directive 2009/16/EC.
On the basis of the aforementioned EU Regulation, the requirements apply both to ships flying the
flag of a European Member State and to ships flying the flag of a third country calling at a port or
anchorage of a European Member State (Reference is made to Article 12 of the Regulation).
2. PROCEDURE
2.1 INTRODUCTION
The regulations of the Hong Kong International Convention for the Safe and Environmentally Sound
Recycling of Ships, 2009, contain the following compliance provisions:
1. An International Certificate on Inventory of Hazardous Materials is required for all ships, except
ships of less than 500 gross tonnage, ships operating throughout their life only in waters subject
to the sovereignty or jurisdiction of the State whose flag the ship is entitled to fly, and existing
ships for which both an initial survey and a final survey are conducted at the same time, in which
case the International Ready for Recycling Certificate is issued after the survey;
2. Administrations may establish appropriate alternative measures to demonstrate compliance by
ships of less than 500 gross tonnage and/or ships operating throughout their life only in waters
subject to the sovereignty or jurisdiction of the State whose flag the ship is entitled to fly; and
3. An International Ready for Recycling Certificate is required for all ships of 500 gross tonnage or
above being taken out of service and before the recycling of the ship has started.
In order to comply with the Hong Kong International Convention for the Safe and Environmentally
Sound Recycling of Ships, 2009 the following actions must be taken:
x The Company shall take all measures to the extent practicable to restrict the installation or use of
Hazardous Materials listed in Appendix 1 of the Hong Kong Convention and Annex I of the
Regulation (EU) No 1257/2013, on ships belonging to its fleet.
x Prior to assigning a ship for recycling, the Company shall ensure that the ship will have on
board an Inventory of Hazardous Materials.
The Inventory shall be verified either by the Vessel¶s Flag Administration or by any person or
organization authorized by it taking into account the guidelines developed by the IMO.
The plan shall be prepared describing the visual / sampling check by which the Inventory of
Hazardous materials is developed, taking also into account the relevant IMO guidelines (Reference is
made to MEPC.269(68).
An International Certificate on Inventory of Hazardous Materials is required also for Regulation
(EU) no 1257/2013 of the European Parliament and of the Council of 20 November 2013 on ship
recycling.
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2.2 SHIP RECYCLING POLICY

The company has established Ship Recycling policy, as follows.
This Policy is designed to achieve safe and environmentally sound ship recycling. It may also lead to
other through-life benefits across the fleet.
The company is committed to the following:
x All new building Vessels will be ordered with Inventories of Hazardous Materials.
x All existing ships will achieve Inventories within 4 years, but no later than the end of 2019 or
before going for recycling if this is earlier.
x All new building Vessels and new installations will exclude the following materials: Asbestos,
TBT antifouling, PCB (polychlorinated biphenyls), CFCs, HCFCs, HFCs, CBBs, PBDE, PVC
and mercury.
x All ships will have procedures to ensure that, as much as practicable, these hazardous materials
cannot be purchased or brought onto the ship in any manner during operations.
x All ships will be recycled in yards which:
o are authorised in accordance with the IMO Convention / are licensed by the local authorities
in accordance with national law; or
o have accredited certification to ISO 30000; or
o are members of ISRA.
x Before recycling, we will:
o ensure export/import requirements are met
o carry out the Final Survey, with the Ship Recycling Plan and a complete Inventory of
Hazardous Materials
o conduct a facility assessment visit
x During recycling, we will receive signed confirmation from the yard that the ship has been
recycled and make this information available to stakeholders.
x The initial survey for compliance with the Regulation (EU) No 1257/2013 of a new ship by the
Vessel¶s Flag administration or a recognized organization authorized by it, shall be conducted
before the ship is put in service, or before the inventory certificate is issued. For existing ships, an
initial survey shall be conducted by 31 December 2020.
The Technical Manager has the overall responsibility for the implementation of this procedure.
2.3 INVENTORIES OF HAZARDOUS MATERIALS
2.3.1 Inventory of Hazardous Materials

The objectives of the Inventory are to provide ship-specific information on the actual Hazardous
Materials present on board, in order to protect health and safety and to prevent environmental
pollution at Ship Recycling Facilities.
This information will be used by the Ship Recycling Facilities in order to decide how to manage the
types and amounts of materials identified in the Inventory of Hazardous Materials.
The Inventory consists of:
x Part I: Materials contained in ship structure or equipment;
x Part II: Operationally generated wastes; and
x Part III: Stores.
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As previously mentioned, the Inventory shall be verified either by the Administration or organization
(Vessel¶s class) authorized by it taking into account guidelines, including any threshold values and
exemptions contained in Convention and IMO guidelines.
The Inventory of Hazardous Materials shall be specific to each ship and shall at least:
x identify as Part I, Hazardous Materials listed in Appendices 1 and 2 of the Convention or
Appendix 1 of the IMO guidelines MEPC.197(62) or Annex II of the Regulation (EU) No
1257/2013 and contained in ship¶s structure or equipment, their location and approximate
quantities; and
x clarify that the ship complies with Regulation 4 of the Resolution MEPC.269 (68).
For existing ships a plan shall be prepared describing the visual/sampling check by which the
Inventory of Hazardous Materials is developed, taking into account the IMO guidelines MEPC.
197(62).
Part I of the Inventory of Hazardous Materials, both for new or existing Vessels, shall be properly
maintained and updated throughout the operational life of the ship, reflecting new installations
containing Hazardous Materials listed in Appendix 2 of the Convention or Appendix 1 of the
MEPC.197(62) and relevant changes in ship structure and equipment.
Prior to ship recycling, the Inventory shall, in addition to the properly maintained and updated Part I,
incorporate updated Part II for operationally generated wastes and Part III for stores, and be verified
either by the Administration or organization authorized by it, taking into account the above IMO
guidelines.
Reference is made to the IMO Resolution MEPC.269 (68) ³Guidelines for the Development of the
Inventory of Hazardous Materials´ as amended.
The Resolution provides guidelines relevant to:

1. Requirements for the Inventory
x Scope of the Inventory
x Materials to be listed in the Inventory
x Materials not required to be listed in the Inventory
x Standard format of the Inventory of Hazardous Materials
2. Requirements for development of the Inventory
x Development of Part I of the Inventory for new ships
x Development of Part I of the Inventory for existing ships
x Maintaining and updating Part I of the Inventory during operations
x Development of Part II of the Inventory (operationally generated waste)
x Development of Part III of the Inventory (stores)
x Description of location of Hazardous Materials on board
x Description of approximate quantity of Hazardous Materials
Regulation (EU) no 1257/2013 of the European Parliament and of the Council of 20 November 2013
on ship recycling, EMSA¶s Best Practice Guidance on the Inventory of Hazardous Materials and
EMSA¶s Study of two hazardous substances (PFOS and HBCDD) included in the annexes of
Regulation EU 1257/2013 on ship recycling are also included in ship specific Inventory of
Hazardous Materials.
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2.3.2 Inventory of Hazardous Materials for New Vessels

Most major shipyards for new building Vessels can easily accommodate a request for an Inventory
It is the responsibility of the company¶s Technical Manager to make members of the site team aware
of the aforementioned requirements for extra materials controls and for ensuring that the sub-
contractors are also controlling their materials.
The Technical Manager is also responsible to ensure that the Inventory Hazardous Material List, as
required by the Convention and EU Regulation, is properly completed under the responsibility of the
Shipyard.
2.3.3 Inventory of Hazardous Materials for existing ships

The Technical Manager appointed a specialist contractor to carry out sampling and complete the
Inventory Hazardous Material List.
During the process of choosing a contractor, special emphasis was made on confidence that the
service they provide would be acceptable to the approving class society.
The majority of the IACS member classification Societies maintain lists of ³approved service
suppliers´ relevant to this service.
Company then addressed Inventory of Hazardous Materials to Vessels¶ Classification Society in
order to verify the Inventory list.
During this procedure, the Technical Manager took all reasonable measures to find the required
information, especially by asking sub-suppliers and checking plans, and include this information as
far as practicable in the Inventory.
Also, experts within the company such as safety officers or technical superintendents, can also be
trained to collect and submit the information.
Preparation of Inventory of Hazardous Materials is in progress for all company¶s Vessels, has
already contacted class for approval and initial onboard verification and procedure is expected to
completed within 2019.
2.3.4 Excluding Materials

In accordance with the requirements specified in Appendix 1 to the Hong Kong Convention, each
Party:
1. shall prohibit and/or restrict the installation or use of Hazardous Materials listed in Appendix 1 on
ships entitled to fly its flag or operating under its authority; and
2. shall prohibit and/or restrict the installation or use of such materials on ships, whilst in its ports,
shipyards, ship repair yards, or offshore terminals, and shall take effective measures to ensure that
such ships comply with those requirements.
2.3.5 Maintenance of the Inventory Hazardous Materials

In order to ensure the conformity of Part I of the Inventory with the requirements, the company has
assigned the following responsibilities:
1. The Technical Manager designates an Environmental / Energy Performance Engineer as
responsible for maintaining and updating the Inventories of all Vessels. The Environmental /
Energy Performance Engineer shall communicate with the Masters and Chief Engineers for
gathering information. The Masters and Chief Engineers are responsible for informing the
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designated Environmental / Energy Performance Engineer of any change / new installation

occurring onboard;
2. The Technical Manager shall establish and supervise a system to ensure the necessary updating of
the Inventory in the event of new installation;
3. The designated Environmental / Energy Performance Engineer shall maintain and duly sign the
Inventory including dates of changes or new deleted entries; and
4. The Technical Manager must provide related documents as required for the survey or sale of the
ship.
Further to the responsibilities above, Part I of the Inventory shall be appropriately maintained and
updated, especially after any repair or conversion or sale of a ship.
Updating of Part I of the Inventory in the event of new installation is required. If any machinery or
equipment is added to, removed or replaced or the hull coating is renewed, Part I of the Inventory
shall be updated.
Updating is not required if identical parts or coatings are installed or applied. All new machinery and
equipment must be accompanied by MD and SDoC forms. These must be collected and maintained.
Reference is also made in 002-PRO-Procedures / PROC 08_PURCHASING / 2.4.4 Forwarding
Goods to the Vessels for IHM and stand-alone ship-specific Inventory of Hazardous Materials.
Part I of the Inventory shall belong to the ship and the continuity and conformity of the information it
contains must be confirmed, especially if the flag, owner or operator of the ship changes.
The Technical Manager is responsible to incorporate updated Part II for operationally generated
wastes and Part III for stores prior to ship recycling.
2.4 HAZARDOUS MATERIALS CANNOT BE PURCHASED OR BROUGHT ONTO THE SHIP

In order to ensure that hazardous materials cannot be purchased or brought onto the ship, a degree of
central control has been established within the Technical Department.
The Technical Manager is responsible for the awareness of the relevant requirements of all personnel
involved in purchasing activities.
In addition, shipboard staff will also need to be trained so that they are familiar with these
requirements.
In general, any staff with purchasing authority (onboard and ashore), as well as superintendents, will
need to be made aware of the excluded materials and their exclusion must be noted on any purchase
orders or invoices.
Purchase orders and invoices must also be kept, as objective evidence of compliance.
2.5 OTHER ACTIVITIES FOR SHIP RECYCLING
2.5.1 Preparation for ship recycling

Ships intended to be recycled shall:
1. Only be recycled at Ship Recycling Facilities that are:
x authorized in accordance with the Hong Kong Convention and, for Vessels flying EU Flag,
are included in the European List; and
x fully authorized to undertake all the ship recycling which the Ship Recycling Plan specifies to
be conducted by the identified Ship Recycling Facility;
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2. Conduct operations in the period prior to entering the Ship Recycling Facility in order to
minimize the amount of cargo residues, remaining fuel oil, and wastes remaining on board;
3. In the case of a tanker, arrive at the Ship Recycling Facility with cargo tanks and pump room(s)
in a condition that is ready for certification as Safe-for-entry, or Safe-for-hot work, or both,
according to national laws, regulations and policies of the Party under whose jurisdiction the Ship
Recycling Facility operates;
4. Provide to the Ship Recycling Facility all available information relating to the ship for the
development of the Ship Recycling Plan;
5. Complete the Inventory; and
6. Be certified as ready for recycling by the Administration or organization recognized by it, prior to
any recycling activity taking place.
2.5.2 Ship Recycling Plan

A ship-specific Ship Recycling Plan shall be developed by the Ship Recycling Facility prior to any
recycling of a ship.
2.5.3 Surveys and Certificates

Ships to which the Hong Kong Convention applies shall be subject to surveys specified within the
Convention, after the Convention shall enter into force.
Upon successful completion of the surveys relevant Certificates shall be issued or endorsed, as
applicable. Same requirements are imposed by the Regulation (EU) No 1257/2013 regarding both
new and existing Vessels flying EU flag or call EU ports.
It is pointed out that for existing Vessels intended for ship recycling, the initial survey and final
survey may be conducted at the same time.
2.5.4 Initial notification and reporting requirements

The company shall notify the Vessel¶s Flag Administration and Classification Society in due time
and in writing of the intention to recycle a ship in order to enable them to prepare for the survey and
certification required by the Convention.
2.6 DEVELOPMENT OF PART I OF THE INVENTORY FOR EXISTING SHIPS

In order to achieve comparable results for existing ships with respect to Part I of the Inventory, the
following procedure has been followed.
The determination of Hazardous Materials present on board existing ships must, as far as practicable,
be conducted as prescribed for new ships in the IMO guidelines of the Resolution MEPC.269 (68).
Alternatively the below procedures may be applied for existing ships, but these procedures must not
be used for any new installation resulting from the conversion or repair of existing ships after the
initial preparation of the Inventory.
2.6.1 Step 1: Collection of necessary information

The company shall identify, research, request, and procure all reasonably available documentation
regarding the ship.
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Information that will be useful includes:

o maintenance,
o conversion, and
o repair documents;
o certificates, manuals, ship's plans, drawings, and technical specifications;
o product information data sheets (such as Material Declarations);
o and hazardous material inventories or
o recycling information from sister ships.
Potential sources of information could include previous Shipowners, the ship builder, historical
societies, classification society records, and ship recycling facilities with experience working with
similar ships.
2.6.2 Step 2: Assessment of collected information

The information collected in Step 1 above shall be assessed.
The assessment must cover all materials listed in Table A of Appendix 1 of the Resolution
MEPC.269 (68) materials listed in Table B must be listed as far as practicable.
The results of the assessment shall be reflected in the visual/sampling check plan.
2.6.3 Step 3: Preparation of visual/sampling check plan

To specify the materials listed in Appendix 1 of the Resolution MEPC.269 (68), a visual/sampling
check plan shall be prepared taking into account the collated information and any appropriate
expertise.
The visual/sampling check plan based on the following three lists:
1. List of equipment, system and/or area for visual check (any equipment, system and/or area
specified regarding the presence of the materials listed in Appendix 1 of the Resolution
MEPC.269(68) by document analysis, shall be entered in the List of equipment, system and/or
area for visual check);
2. List of equipment, system and/or area for sampling check (any equipment, system and/or area
which cannot be specified regarding the presence of the materials listed in Appendix 1 of the
Resolution MEPC.269 (68) by document or visual analysis) must be entered in the List of
equipment, system and/or area as requiring sampling check. A sampling check is the taking of
samples to identify the presence or absence of Hazardous Material contained in the equipment,
systems, and/or areas, by suitable and generally accepted methods such as laboratory analysis);
and
3. List of equipment, system and/or area classed as ³potentially containing Hazardous Material´
(any equipment, system and/or area which cannot be specified regarding the presence of the
materials listed in Appendix 1 of the Resolution MEPC.269 (68) by document analysis may be
entered in the List of equipment, system and/or area classed as ³potentially containing Hazardous
Material´ without the sampling check. The prerequisite for this classification is a comprehensible
justification such as the impossibility of conducting sampling without compromising the safety of
the ship and its operational efficiency).
Visual/sampling checkpoints must be all points where:
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x the presence of materials to be considered for the Inventory Part I as listed in Appendix 1 of the
Resolution MEPC.269(68) is likely;
x the documentation is not specific; or
x materials of uncertain composition were used.
2.6.4 Step 4: Onboard visual/sampling check

The onboard visual/sampling check shall be carried out in accordance with the visual/sampling check
plan.
When a sampling check is carried out, samples shall be taken and the sample points must be clearly
marked on the ship plan and the sample results referenced.
Materials of the same kind may be sampled in a representative manner. Such materials are to be
checked to ensure that they are of the same kind.
The sampling check shall be carried out drawing upon expert assistance.
Any uncertainty regarding the presence of Hazardous Materials shall be clarified by a
visual/sampling check.
Checkpoints shall be documented in the ship's plan and may be supported by photographs.
If the equipment, system and/or area of the ship are not accessible for a visual check or sampling
check, they shall be classified as ³potentially containing Hazardous Material´.
Any equipment, system and/or area classed as ³potentially containing Hazardous Material´ may be
investigated or subjected to a sampling check at the request of the company during a later survey
(e.g., during repair, refit or conversion).
2.6.5 Step 5: Preparation of Part I of the Inventory and related documentation

If any equipment, system and/or area is classed as either ³containing Hazardous Material´ or
³potentially containing Hazardous Material´, their approximate quantity and location shall be listed
in Part I of the Inventory.
These two categories must be indicated separately in the remarks column of the Inventory of
2.6.6 Testing Methods

Samples may be tested by a variety of methods. ³Indicative´ or ³field tests´ may be used when:
x the likelihood of a hazard is high;
x the test is expected to indicate that the hazard exists; and
x the sample is being tested by ³specific testing´ to show that the hazard is present.
Indicative or field tests are quick, inexpensive and useful onboard the ship or on site, but they cannot
be accurately reproduced or repeated, and cannot identify the hazard specifically, and therefore
cannot be relied upon except as ³indicators´.
In all other cases, and in order to avoid dispute, ³specific testing´ must be used. Specific tests are
repeatable, reliable and can demonstrate definitively whether a hazard exists or not.
They will also provide a known type of the hazard.
The methods indicated are found qualitative and quantitative appropriate and only testing methods to
the same effect can be used. Specific tests are to be carried out by a suitably accredited laboratory,
working to international standards (for example ISO 17025) or equivalent, which will provide a
written report that can be relied upon by all parties.
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Specific test methods for Appendix 1 materials are provided in Appendix 9 of the same Resolution
MEPC 269(68).
2.6.7 Diagram of the location of Hazardous Materials on board a ship

Preparation of a diagram showing the location of the materials listed in Table A of the Appendix 1 of
the Resolution MEPC. 269(68) is recommended in order to help Ship Recycling Facilities gain a
visual understanding of the Inventory. Such a diagram shall be attached to Part I.
3. RECORD
None
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Prime Tanker Management Inc.

Prime Gas Management Inc.

Manual Code: EMS (009)

Amendment Date Position /

SECTION No Title Issue Issue

2.1 PROTECTION OF THE ENVIRONMENT

2.2 GENERAL REQUIREMENTS

2.2.1 PORTABLE EMERGENCY TRANSFER PUMPS

2.2.2 SORBENT MATERIAL AND TOOLS

2.2.3 SCUPPERS AND ACTIONS ON DECK IN THE EVENT OF RAIN

2.2.4 OIL RECORD BOOK WEEKLY REPORTING AND REVIEW

2.2.5 ENVIRONMENTAL CRITICAL EQUIPMENT

2.1 MARPOL 73/78 - ANNEX I

2.2 MARPOL 73/78 - ANNEX II

2.3 MARPOL - ANNEX IV

2.4 MARPOL - ANNEX V

2.5 MARPOL - ANNEX VI

2.7 KYOTO PROTOCOL

2.9 BHC CODE

2.10 IBC CODE

2.11 IMDG CODE

2.12 INTERNATIONAL CONVENTION ON THE CONTROL OF HARMFUL ANTIFOULING SYSTEM ON

Under the terms of the convention, ships either:

2.13 DIRECTIVE 75/442/EC

2.15 MARITIME LABOUR CONVENTION AND STCW CODE

2.16 USA REQUIREMENTS AND REGULATIONS

2.17 VRP / NTVRP

2.18 US GOVERNMENT CWA (CLEAN WATER ACT)

2.19 TMSA 3 REQUIREMENTS

2.19.1 PARTICULATE MATTER

2.19.1.1 DATA SOURCES

2.20 DIRECTIVE 2015/757/EC

2.1 BUNKERING TANKS CLEANING

The following Terminology is used in order to describe this procedure:

Oily bilge water can be handled in two ways:

2.2.1 Oily Water Separator (OWS)

The OWS is characterised as Environmental Critical Equipment.

1. The OWS is to be tested on a WEEKLY BASIS

7. The weekly test must include at least the following:

The above standing Orders must be posted near the OWS.

A Critical Equipment De-activation / Re-activation Report (MTN/SECTION 1/SF/TEC134) has to be

2.2.2 Bilge main cross-connections

Dedicated emergency bilge suction valves shall be painted brightly.

2.2.3 Overboard valves

2.2.4 Oil to Sea Interface Management

Vessels that call US waters are subject to VGP requirements.

2.2.5 Handling of oil sludges

Prior to commencing the discharging operation:

³This pump can only be connected to the Bilge System,

2.2.7 Discharge of E/R oil and oily water to shore facilities

2.3 HANDLING OF SLOPS

When a Vessel is loaded, the Decanting Operation is permitted

The ODME is characterised as Environmental Critical Equipment.

A Critical Equipment De-activation / Re-activation Report (MTN/SECTION 1/SF/TEC134) has to be

2.4 BILGE, SLUDGE AND SLOP MANAGEMENT RECORD KEEPING

2.4.1 Oil Record Book Part I and Part II

In order to ensure compliance with the Regulations the Company requires:

2.4.2 Bilge and Sludge receipts

2.4.3 Oil Content Meter (OCM) Calibration Log

2.4.4 Engine logbook

Risk Assessments to be referred to:

³Sewage´ refers to:

2.1 REQUIREMENTS FOR SEWAGE DISCHARGE