Marine Pollution Prevention Pocket Checklist.pdf

MARINE POLLUTION PREVENTION

POCKET CHECKLIST

Reducing the risk of Port State Control detentions

In conjunction with:

Introduction

MARPOL infringements can result in both company

management and seafarers being liable to criminal

prosecution and imprisonment for deliberate violation of

MARPOL requirements or falsification of records. In addition,

there are risks of large fines amounting to millions of dollars.

In conjunction with an industry partner, the UK P&I Club, we

have analysed data including deficiencies found by Port State

Control Officers relating to marine pollution prevention. The

result is this convenient and re-usable Checklist, highlighting

the most common deficiencies listed by the MARPOL Annexes.

An Appendix covering Ballast Water Management is

included as this is an area, that, while not directly linked to

MARPOL is receiving increasing focus.

To help reduce these risks, as a minimum, the items on

the chart on page 4 should be included as part of your

final checks prior to voyage and port entry to ensure

they continue to conform to international convention

requirements. It is strongly advised that all items in this

aide memoire are checked on an ongoing basis to

supplement your own operational and maintenance

procedures and your flag State’s requirements.

This is the second in a series of pocket checklists to help you

comply with international convention requirements. For

information about our other checklists please visit www.lr.org.

Lloyd’s Register, its affiliates and subsidiaries and their respective officers, employees

or agents are, individually and collectively, referred to in this clause as the ‘Lloyd's

be liable to any person for any loss, damage or expense caused by reliance on the

information or advice in this document or howsoever provided, unless that person

has signed a contract with the relevant Lloyd's Register Group entity for the provision

of this information or advice and in that case any responsibility or liability is

exclusively on the terms and conditions set out in that contract.

Marine Pollution Prevention

Page 2

Are you prepared for a Port State

Control Inspection?

PSC officers always commence their inspection in the Master’s

office. It is essential that certification is up to date, original and

valid. All other necessary documents and manuals should,

where required, be approved and onboard.

If equipment is broken or missing, or the ship has suffered

damage en-route, the Master must notify the port authorities

prior to port entry. If the port authorities are informed of the

problem and of any permanent or temporary remedies agreed

with the flag State, the vessel should not be detained.

However, if notice is not given before entry, the Port State has

clear grounds for inspection, possibly leading to a detention.

If your ship is detained, or appears to be in the process

of being detained, you should contact the nearest Lloyd’s

The major PSC organisations publish their criteria for targeting a

ship on their web sites. Ship owners and operators should use

these criteria to calculate the target rating of their ships.

Paris MOU - www.parismou.org

Tokyo MOU - www.tokyo-mou.org

USCG - www.uscg.mil/hq/gm/pscweb

Other MOUs include Abuja, Black Sea, Caribbean, Indian

Ocean, Mediterranean, Riyadh and Vina del Mar.

A ship operator may disagree with the findings of the PSC

Authority and the majority of the regional PSC organisations

have guidelines on how to appeal against a detention. These

can also be found on the above web sites.

IMO Procedures for Port State Control, Appendix 1 also

provides guidelines on detentions [ISBN: 92-801-5099-5].

Marine Pollution Prevention

Page 3

MARPOL deficiencies

The following are the most common MARPOL

deficiencies (by number) found by Port State Control

Officers on Lloyd's Register Group classed ships in 2005

1730 oil filtering equipment [40]

1705 shipboard oil pollution emergency plan (SOPEP) [36]

1710 oil record book [27]

1745 15 PPM alarm arrangements [23]

1721 retention of oil on board [22]

1799 other (MARPOL - Annex I) [19]

0150 prevention of pollution by oil (IOPP) [18]

2330 garbage record book [17]

2320 garbage management plan [11]

1740 oil discharge monitoring and control system [9]

Marine Pollution Prevention

Page 4

1. Operational deficiencies

Some frequently occurring operational deficiencies.

■

Oil and oily mixtures from machinery spaces

– oily water separator (OWS) malfunctioning,

inoperative alarm and auto stop, illegal bypass

■

Retention of oil on board

– quantity of oily water retained on board does not

agree with Oil Record Book entries and/or IOPP

Record of Construction and Equipment

– quantity of oily water/sludge landed ashore or

incinerated does not reconcile with quantity

expected to be produced from machinery spaces

■

Discharge violation

– actual discharge violation noted by oil coating

inside clean discharge pipes from OWS

[ Note: pipes are often removed for inspection]

– indications of discharge pipe/valve removal

■

Inconsistent entries in Oil Record Books Parts 1

and/or 2

■

Garbage

Inadequate garbage segregation:

– garbage bins in accommodation/galley not of

approved type (should be non-combustible)

– inadequate Garbage Logbook entries

– falsified Garbage Logbook entries

– no receipts for garbage landed ashore

■

Cargo Residues

– cargo residues not correctly disposed

– disposal not correctly documented

Marine Pollution Prevention

Page 5

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