INFORMATION FROM DNV TO THE MARITIME INDUSTRYNO. 7 – DECEMBER 2005

Casualty Information

Ship Type: Any Size (GRT): Any Year of build: Any

By-pass of oily waterseparator at sea –detention and fineCourse of eventsWhen entering a US port, the port state authoritywas unofficially informed by a crew member thatbilge water had been discharged directly to sea with-out using the Oily Water Separator (OWS) and with-out making any entry into the Oil Record Book(ORB). The vessel was detained for possible viola-tion of MARPOL Annex I.

An investigation was started but ended up with asettlement which included a fine of several millionUSD and a probation period of four years, duringwhich time a compliance program was required tobe implemented on board.

The above is similar to other’s experience duringthe recent years, as many are not aware of what isgoing on until the vessel is detained, indicating thatthere is much room for improvement.

Extent of damageDischarge of oil-contaminated water to sea.

The owner suffered financial losses, damage tothe reputation and an extensive workload to estab-lish the required compliance program.

Probable causeBilge water was assumed to have been dischargeddirectly to sea, without being passed through theOWS and with no entry made in the ORB. The dis-charge had been carried out by the use of a by-passpipe (often referred to in the media as a “magicpipe”).

The basic practical problem on board this shipand others is that the production rate of contaminat-ed water in the engine room may be high comparedwith the capacity of the OWS. Further, the OWS can-not necessarily handle all sorts of waste productssuch as emulsions from cleaning chemicals, soot-contaminated water etc.

According to the owner, the crew had in generalfull understanding of what they were doing. How-ever, some of the engine crew were found to lackcompetence and additional equipment to treat theoily water in the engine room would have beenbeneficial.

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Lessons to be learnedThe following lessons were learned from the above:

1. Handling of waste products from the engine room

• Oily water into the engine room bilge wells may bereduced by better control of the drains from vari-ous components.

• MARPOL 73/78 Annex I Appendix III listsmachinery space operations which are to berecorded in the Oil Record Book (ORB).

2. Proper use of the OWS

• All discharges of oil or oily mixtures from theengine room to the sea are required to passthrough the OWS, except when the ship is in anemergency situation.

• Tampering with bilge system and/or discharge ofbilge water direct to sea is in violation of MARPOLrequirements and will result in environmental pol-lution and serious problems for the ship and man-agement when discovered.

• Workload and/or technical problems must neverbe an acceptable excuse not to follow correct bilgewater procedures:– When handling an oil leak, rather use the

sludge tank rather than the bilge water tank.– Do not use chemical cleaning products which

produce emulsions which cannot be handled by the OWS.

– Beware that drains from scavenging belt etc. are recommended to go into the sludge tank rather than to the bilge water tank.

• By reducing the amount of oil and emulsion inthe bilge water, the OWS will work much better,and additional pre-separation of oily water in atank is recommended before being put throughthe OWS.

• The OWS is to be properly maintained accordingto manufacturer’s recommendations.

• Any modification of the OWS is to be approved bythe Class Society/Flag State Authority.

Please also note the difference between MARPOLand SOLAS:

The MARPOL 73/78 regulations provide for non-emergency operational situations. Annex I Reg. 9covers control of discharge of oil while Reg. 10 cov-ers methods for prevention of oil pollution fromships operating in a Special Area. MARPOL Annex I,Reg. 11 lists exceptions for discharges in emergencysituations.

Both SOLAS (Ch.II-1 Regulation 21) and DNVRules for Steel Ships (Pt.4 Ch.1 Sec.4) require theship to be provided with 2 bilge pumping systems to

be operable under all conditions. The system isrequired for safety reasons and is to be operable onvery short notice, for instance, in connection with asudden flooding of the engine room or cargo hold.

3. Correct use of the Oil Record Book (ORB)

• All discharges of oil from the engine room to thesea are to be recorded in the ORB.

• Frequently forgotten oil leakages/transfersrequired to be recorded in the ORB are:a. Leakages from stern tube to the sea.b.Sludge transferred back to fuel oil tanks.

• All movements and transfers of sludge and bilgewater must be recorded in the ORB Part 1. It isimport that the total volumes accumulated insludge and bilge holding tanks are accounted forand correctly recorded.

• Recordings in ORB need to be correct and to cor-respond with other recordings on board. It isusually examined at Port state control, and itmay be copied and used as evidence. Presenta-tion of the ORB to US Coast Guard with falseentries is a criminal offence and subject to prose-cution, even if the discharge has taken place out-side US waters.

• Sludge tanks and other tanks for oil residues arelisted in table 3.1 of the Supplement to the IOPPCertificate. Tanks listed in the table need to corre-spond with the actual tanks entered in the ORB,and class is to be contacted for updating of IOPPsupplement if any difference between tanks in useand their volumes.

4. Proactive actions subsequently implemented by the

owners were as follows

• Systematic evaluation of the waste oil and chemi-cals produced in the engine room and how tohandle them.

• Upgrading of old equipment and pre-treatmentfacilities.

• The direct overboard bilge valve (Emergency situa-tion, SOLAS) was advised secured with a breakableseal (not formally required by Marpol). Any open-ing to be recorded in the ORB. At the same time itis vitally important that this valve is not made in-operable in an emergency due to this securing.

• The overboard valve from the OWS to besecured/locked by padlock when not in use. Themaster to be in control of the operation of thevalve.

• OWS to be properly maintained and spare parts tobe available on board.

• Provision of knowledge, attitude and skills trainingamong the crew handling bilge water on board.

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Casualty Information is published by

DNV Maritime, Maritime Technology and

Production Centre (Dept. for Ships in

Operation)

Det Norske Veritas

NO-1322 Høvik, Norway

Tel: +47 67 57 99 00

Fax: +47 67 57 99 11

The purpose of Casualty Information is to

provide the marine industry with ‘lessons

to be learned’ from incidents of ship

damage and more serious accidents. In

this way, DNV hopes to contribute to the

prevention of similar occurrences in the

future. The information included is not

necessarily restricted to cover ships classed

with DNV and is presented, without

obligation, for information purposes only.

Queries may be directed to DNV Maritime,

Maritime Technology and Production

Centre (Dept. for Development Learning

& Support), NO-1322 Høvik, Norway.

Fax: +47 67 57 99 11.

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