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 The management and control of marine
pollution is steadily assuming a higher priority for shipowners
and masters as governments, official bodies and politicians focus
increasingly on MARPOL infringements and threaten key personnel
with criminal prosecution.
However, the industry should not simply
react to authorities’ requirements but take a positive approach
to avoid damaging the marine environment during operations.
Marine Pollution Prevention Pocket
Checklist, jointly published
by Lloyd’s Register and the UK P&I Club, aims to provide
practical advice for owners, operators and particularly seafarers
to help them comply with the MARPOL Convention and prepare for
Port State Control inspections – given a context of commercial
disruption, fines and the growing threat of criminal proceedings
against key personnel and the spectre of imprisonment.
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Marine Pollution
Prevention Pocket Checklist
Produced by
experts from Lloyd’s Register and the UK Club, the guide
advises masters and owners about their general approach to Port
State Control over prospective and actual pollution, and highlights
MARPOL deficiencies found in Lloyd’s Register’s own
classed fleet by PSC. It provides a detailed checklist of areas
that must be up to standard and highlights seven areas where
operational deficiencies are frequently found.
The checklist
highlights over 33 certificates, record books, plans and documents
applying to ships in general and particular vessel types, including
those specific to tankers and chemical carriers. There are a
series of annexes dealing with prevention of pollution by oil,
noxious liquids in bulk, harmful substances in packages, sewage,
garbage and air pollution. Although not directly linked to MARPOL,
an appendix on ballast water management is included. |
A measure of
quality
PSC rankings provide the industry
with a tangible measure of the quality of the world’s tonnage.
PSC authorities have become increasingly effective at squeezing
sub-standard operators out of the market, particularly through
targeted inspection campaigns.
The Paris and Tokyo Memoranda of Understanding
and the US Coast Guard’s annual reports give the industry
an effective measuring stick for gauging performance and deciding
on methods of improvement.
However, marine pollution and the criminalisation
of seafarers have become increasingly intertwined in recent months.
Increased vigilance, particularly by USCG and European coastal
state authorities, has revealed ‘magic pipes’ to bypass
oily water separators and the falsification of oil record book
entries.
The operational, social and political
realities of life at sea have changed dramatically and seafarers
now work in an environment where they can go to jail if they
make a mistake. Masters, chief engineers and shore-based managers
are being charged with, and convicted of, criminal offences such
as conspiracy and obstruction of justice.
PSC benchmarking
Lloyd’s Register monitored its
fleet’s PSC detentions to identify areas needing improvement.
Since 2002, it has used this data as the basis of a comprehensive
PSC benchmarking system and migrated the data to ClassDirect
Live, online class information system. This ensures surveyors
have up-to-date PSC information at their fingertips, providing
the most detailed possible view of any ship they are about to
board.
The system allows Lloyd’s Register
to identify potential risks to the safety of the ships themselves
and the personnel on board. Where a confluence of factors might
not individually be cause for alarm but together represent a
significant risk, Lloyd’s is able to warn the owner and
take action. For instance, a dirty engine room with flammable
material close by, an unattended machinery space and an inoperable
emergency fire pump would not necessarily pose substantial risks
in themselves. Occurring at the same time and in close proximity,
they would amount to a significantly hazardous situation.
Reducing claims
The UK Club supports the PSC system.
However, lowering detentions is not just about cutting down on
deficiencies but reducing environmental damage and insurance
claims. Class looks at environmental problems from a position
based on rules and standards. Insurers focus on risk.
Pollution accounted for 18 per cent of
all UK Club claims outgoings in 2005. Deficiencies with oily
water separators were down from 30 in 2001 to 14 in 2006. However,
MARPOL deficiencies were up from zero in 2001 to 22 in 2006,
an especially worrying trend as the increase in the past 12 months
was considerable. Taken together, MARPOL and OWS violations were
the most frequent reasons for UK Club ship detentions in 2006.
The variety of vessels involved in pollution
claims in 1987-2004 is perhaps surprising. As might be expected,
tankers featured in 46 per cent of incidents (24 per cent of
Club entry). However, the claims were spread widely across the
entire fleet, with bulk carriers (13 per cent) and dry cargo
ships (10 per cent) prominent.
It follows that the sources of large
environmental claims are also widely spread. Crude oil and fuel
oil as cargo accounted for just under one quarter each, with
chemical, clean and dirty products, dirty ballast, bilges and
smoke appearing in the analysis. However, 33 per cent were down
to bunkers.
This is highlighted by comparing the
quantities spilled in 1990-94 with those in 2000-04. Pollutions
of five to 1,000 tons have dropped dramatically from 59 to 16.
Those under five tons have only eased from 53 to 49. This illustrates
how important it is to guard against the smallest spillages.
The authorities can be expected to target all incidents with
increasing zeal, larger fines and, possibly, imprisonment for
certain onboard and shore personnel.
Underlying causes of pollution incidents
included failure and misuse of valves, overflows, defects in
plate and pipes, hose rupture, contaminated bilges and faulty
gauges.
The importance of human error in causing
large spills must be stressed. Given their responsibilities,
deck officers are most likely to commit the errors. They were
at fault in 27 per cent of incidents in 1987-2004. However, taken
together, crew, engineering officers, pilots and shore personnel
slightly exceeded this figure. Further, 75 per cent of claims
by value involved human error.
Deficiencies discovered by Port State
Control should be seen in a wider context. Oil filtering equipment
shortcomings mean pollution; an inadequate shipboard oil pollution
emergency plan means a reduced capability to contain spills;
and problems with the oil record books lead to fines and prosecutions.
The onus is on every shipowner and master
to take a responsible and constructive approach in managing those
operations which involve a risk of pollution.
Pollution checklist
Produced by experts from Lloyd’s
Register and the UK Club, the guide advises masters and owners
about their general approach to Port State Control over prospective
and actual pollution, and highlights MARPOL deficiencies found
in Lloyd’s Register‘s own classed fleet by PSC. It
provides a detailed checklist of areas that must be up to standard
and highlights seven areas where operational deficiencies are
frequently found: oil and oily mixtures from machinery spaces;
retention of oil on board; discharge violation; inconsistent
oil record book entries; garbage management; cargo residues;
and shipboard oil pollution emergency plans (SOPEPs).
In the master’s office, certification,
documentation and approved manuals must be up-to-date, original
and valid. If equipment is broken or missing or the ship damaged
en-route, the master must notify the port authorities prior to
entry. If permanent or temporary remedies have been agreed with
flag, Port State should not detain the vessel. Otherwise, it
has clear grounds for inspection, perhaps leading to detention.
The checklist highlights over 33 certificates,
record books, plans and documents applying to ships in general
and particular vessel types, including those specific to tankers
and chemical carriers. There are a series of annexes dealing
with prevention of pollution by oil, noxious liquids in bulk,
harmful substances in packages, sewage, garbage and air pollution.
Although not directly linked to MARPOL, an appendix on ballast
water management is included.
Marine Pollution Prevention Pocket
Checklist measures 15 cms X 10.5
cms and is printed on recyclable polypropylene. It will be distributed
to owners and operators of Lloyd’s Register-classed ships
and members of the UK P&I Club. Click Here to view the text of the checklist.
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