Following several enquiries the Association would like to draw the attention of Members to the Club’s Technical Bulletin No. 24 published in 2007. In this Bulletin a number of anomalies were noticed in the recording of entries in the Oil Record Book (ORB) under Part 1 - Machinery Spaces by the Club’s Ship inspectors, this bulletin was an effort to clarify what was intended by the MARPOL regulations.
These anomalies specifically relate to the common use and recording of bilge water tanks (Para 3,3 of the IOPP Supplement) as sludge tanks and the common procedure of heating sludge tanks as a method of reducing the volume of the sludge by evaporation and retaining in the tanks listed in Para 3.2 of the IOPP Supplement.
The Marine Environment Protection Committee (MEPC) has issued the following statement in October 2008 as ‘interim guidance’ and we would urge Members to follow the amended recording procedures and entries.
“INTERIM GUIDANCE ON THE USE OF THE OIL RECORD BOOK CONCERNING VOLUNTARY DECLARATION OF QUANTITIES RETAINED ON BOARD IN OILY BILGE WATER HOLDING TANKS AND HEATING OF OIL RESIDUE (SLUDGE)
1 The Marine Environment Protection Committee, at its fifty-eighth session
(6 to 10 October 2008), agreed that (MEPC 58/23, paragraphs 10.33 and 10.35):
.1 where a voluntary declaration of quantities .retained on board. in oily bilge water holding tanks is entered in the Oil Record Book, Part I, the entry should be made under Code (I) (Additional operational procedures and general remarks);
.2 the heating of oil residue (sludge) as a method of reducing its volume by evaporation should be recorded in the Oil Record Book, Part I, under Code (C) (Collection, transfer and disposal of oil residues (sludge)), paragraph 12.4.
2 The Committee agreed to disseminate the above information by means of an MEPC circular and to bring the circular to the attention of the FSI Sub-Committee to ensure alignment with Port State control procedures.
3 Member Governments are invited to communicate the above to their maritime Administrations, including port State control officers, industry organizations and other stakeholders to ensure uniform application of the aforementioned understandings.”
This Bulletin does not supersede Technical Bulletin No. 24 but the Club would suggest that it be added as an additional notice (amendment) for the benefit of Officers on board and to prevent any possible problems with Port State Control in the future.
Source of information:
Ship Inspection Department