Further to our Bulletin 66/1998, we have been advised that SIPBS (State Inspection for Protection of the Black Sea) are continuing to take infringements of the ballast water regulations very seriously.

It is common practice now, particularly at Nikolayev, that upon completion of inward clearance formalities, a SIPBS inspector will take samples of ballast water. The samples are taken to a SIPBS laboratory for analysis. Tests are performed for oil content, iron and suspended matter. The normal fine for exceeding the iron limit is $600 USD.

SIPBS is a state organisation, and appears to be very active at the moment in collecting fines in most Ukrainian ports. We understand it is very difficult, if not impossible to appeal against their findings. Many of the fines imposed are quite large, but these we are advised can be negotiated down although not always possible at Odessa and Ilyichevsk and impossible at Nikolayev.Unfortunately, there are no laboratories for independent analysis, as they tend to follow the results from the SIPBS analysis without question.

SIPBS do not recognise analysis results from any laboratory other than their own in any case.A recent case in Nikolayev highlighted a common sewage problem:The vessel concerned did not have a certificate relating to the cleanliness of their sewage system. The authorities took samples for analysis. This is standard practice for vessels without such certification.The analysis results showed that the chlorine content -17mg/l - exceeded the permissible limit of 5mg/l.

The vessel was subsequently fined. However, the Master, who was sure that there wouldn’t be a problem with his sewage plant, started to pump treated sewage overboard before the results were confirmed.The collection of sewage from vessels by barge is accounted for in the vessel’s payment of the port’s sanitary fees, so it was not known why the Master decided to pump directly overboard. 

The fine for exceeding the chlorine limit was only $40 USD, however, when it was discovered that the vessel was pumping sewage overboard, and additional fine of $5000 USD was imposed.

We would advise Members trading to the Ukraine to get confirmation from their agents of local sanitary and ballast regulations before their vessels arrive in order to best advise the Master. It appears that some sort of 

"fine" will be inevitable, but with a little care, these can be minimised.

Source of Information:

External through Susanne Hall L7