ENVIRONMENT MANAGEMENT SYSTEM (EMS) …competency.synergyship.com/pdf/EMS/Ch_06_Voluntary_Environment… · strict adherence with International Maritime Organization ... Relation

ENVIRONMENT MANAGEMENT SYSTEM (EMS) MANUAL

CH.06 VOLUNTARY ENVIRONMENTAL COMPLIANCE PLAN

Rev. No. 2

Date 15-Apr-16

Page 1 of 31

6.1. INTRODUCTION

This section also reiterates the company policy of laying high priority on Environment protection and

highlights the company’s commitment to implement all reasonable and practicable actions to prevent

pollution.

a. Exceeding the statutory requirements, Company has initiated a Voluntary Environmental

Compliance Plan which is described in this section

b. To achieve company`s Environmental Objective it is necessary to ensure all pollution

prevention Equipment’s on-board are fully operational.

c. This will be one crucial step for achieving our goal of “Zero injuries, Zero damages and

Zero Spills to sea”.

The company is committed to a Zero tolerance approach to any non-compliance with the

international convention for the prevention of pollution from ships (MARPOL) and is committed to

strict adherence with International Maritime Organization (IMO) requirements concerning the use of

Oily water separators and all other Marpol equipment.

It is the company’s policy to operate its vessels in full compliance with regulations that are in force

and when there is a violation or non-compliance, the company will extend full co-operation to

authorities for them to take necessary legal actions.

Company encourages open reporting and voluntary disclosures of violations.

We introduce this voluntary compliance plan which will assist the shipboard and shore based

personnel to ensure 100% compliance with international regulations with regards to disposal of

shipboard wastes and effluents. Also VECP ensures that all vessels go beyond just compliance with

mandatory rules and regulations.

Uncontrolled when Printed



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Relation between EMS & Voluntary Environmental Compliance Plan

VECP Audits, EMS Tagging, VECP

Awareness training MARPOL poster, etc.

Compliance to EMS

standard and Audits

Local/Port state Requirements.VGP,

CARB,EU etc.

Open and

Anonymous

Reporting of

Non -

Compliance

Zero Tolerance Policy on non

compliance to Environmental

Regulations & Requirements

Compliance

to Statutory requirements IMO, MARPOL, Flag Admin etc.

Industry Requirements.

And best practices.

Environment

Friendly

initiatives use

of

Biodegradable

Chemicals etc..

EMS

VECP




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Date 15-Apr-16

Page 3 of 31

6.2. PROCEDURES FOR TAKING OVER A SHIP IN TO MANAGEMENT.

On taking over a ship into the management, as a minimum, the following should be checked as part

of Management of Change (MOC) and reported to office by Chief Engineer.

a. Thorough check of the Oily water Separator (OWS) to ensure its correct functioning.

b. Check of Type approval certificate of OWS.

c. Check calibration certificate and Type approval certificate of Oil Content Meter (OCM) is on

board and carry out zero check/function test.

d. Thorough search of the Engine room for any ‘magic pipes’, hoses etc. which could lead to

suspicion of MARPOL violation. If any such pipe exists, office to be informed and pipe removed

from vessel, with a clear change of custody.

e. Inspect bilge holding tank, clean up if required.

f. Inspect the OWS overboard pipeline internally, clean up if required.

g. Check maintenance routines / records for the OWS and associated machinery.

h. Check availability of critical spares for OWS and order missing spares in accordance with

company guidelines for minimum spare part requirement.

i. Check spectacle flange interconnection between bilge and Sludge system. Both systems should

be properly isolated and fitted with a tamper proof seals supplied by the company.

j. Open up and inspect direct bilge well suction filters leading to the Fire & GS and Bilge & GS

pumps. Clean up if required. Report condition before cleaning and after cleaning to the Office

with photographs.

k. Confirm that the details of the equipment, tank capacities etc. are entered correctly in the IOPP

certificate and that all bilge, sludge and drain tanks including scavenge drain tanks are included.

If there are any discrepancies found the office is to be informed of the same.

l. Check previous Oil record books, Bunker Delivery Notes (BDNs) and MARPOL Bunker samples.

Records should be available for at least last 3 years or as per Flag requirements for Oil record

books and Bunker Delivery Notes. MARPOL Bunker samples to be retained on board for 12

months or as per flag requirements.

m. Oil Record book at least copy of the same for the last 3 years to be kept on board.

n. Master/ Chief Engineer to carry out training session highlighting company’s commitment for

environment protection and procedures for same.

o. Check that all bilge / sludge pipelines are in accordance with the original yard plans. In case

there are any modifications to the original - are they Class approved? In case of any deviation




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Date 15-Apr-16

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from the Original yard or Class approved plans, office must be informed immediately. In case

vessel has a set of plans that do not conform to the actual pipeline (not as per original or Class

approved) these should be destroyed to avoid any confusion.

p. Tamper proof seals to be fitted at all locations as specified in TE 41(List of general sealing

points)and records of same to be maintained as per TE37.(Summary of sealing points).

q. OWS maintenance to be carried out, photographic evidence of work done must be maintained.

r. Ozone Depleting Substances form TE 30(MARPOL Annex VI Record Book), and Garbage Log

must be started immediately.

s. Every ship taken into management with an oily water separator of the filtration type must have

minimum critical spares like spare coalescer/filter cartridges on board as per company

guidelines in Technical Manual & PMS.

t. Check the operation of Sewage treatment plant for proper functioning. Check availability of

critical spares for STP as per guidelines for minimum spare parts requirement.

u. Check the operation of W.O. Incinerator for proper functioning. Check availability of critical

spares for W.O. Incinerator as per guidelines for minimum spare parts requirement.

6.3. GUIDELINES FOR PREPARATION TO PORT STATE CONTROL INSPECTION FOR

MARPOL VIOLATIONS

a. It is most important that the authorities are escorted by the Chief Engineer and another

engineer or officer during the engine room inspection. Close communication with the Master

via Walkie-talkie must be maintained.

b. If the authorities take any samples of bilges or oil, the office to be advised immediately. The

authorities may provide the vessel with split samples (i.e. single sample drawn and divided

into two parts of which one is given to the vessel.) in case split samples are not provided,

vessel should also endeavor to take samples from the same location, seal them with the

counter-signature of all parties concerned, if the authorities agree to sign the ship’s

representative samples.

c. If the authorities take photographs of the installation and / or location form where the sample is drawn, vessel should also take similar photographs from the same viewpoint with the date, stamp on the camera operational to the local date and time. In any case, even if authorities do not take photographs the vessel must take them.




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Date 15-Apr-16

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d. Records of all conversation with the authorities are to be made at the earliest convenience

to avoid missing out any details later.

Following Checks have to be carried out for preparation prior arrival Port:

- Documentation and records must be precisely and correctly maintained.

- Latest shore calibration certificate of the 15 ppm Oil content Monitor.

- Alarm test of 15 ppm equipment and operation of 3-way valve / pump stop.

- Can the effluent from the OWS, after three way valve be tested? (with overboard valve

closed)

- OWS operation; 15ppm alarm test; check of data recorded in the OCM memory card.

- General condition of bilges and seawater, oil leaks in the engine room.

- Temporary repair on OWS casing by means of cold repair.

- Temporary repair done on sewage treatment plant casing.

- Spares for OWS and bilge pumps.

- OWS maintenance records.

- Incinerator operation – test operation on waste oil.

- Sewage plant operation. Check for residual chlorine content of treated water and presence

of any floating solids in the test sample.

- Check of activated sludge return flow through the flow return tubes for the sewage treatment

plant.

- Garbage Log – special care on garbage incineration and disposal of cargo residue. Logs

maintained must reflect the actual quantity of garbage generated / disposed. Care should be

taken when filling the logs as PSC’s are looking at these more stringently.

- Verify the quantity mentioned in individual tanks in oil record book tallies with the actual

retention in each of the tanks in engine room.

- Verify the timings recorded in oil record book tallies with what is recorded in the OCM

memory card (if applicable) and/or Oil Content Meter panel of the Oily Water Separator and

the panel of Incinerator.

- Verify the alarm log print outs of the Engine Control Room printer and may check the Oil

record book entries to establish when oily water separator or incinerator were used New




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Date 15-Apr-16

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version of oil record book is in use and the new codes are being used which have come into

force.

6.4. INSTALLATION AND MAINTENANCE OF TAMPER PROOF SEALS IN BILGE PIPE

LINES SYSTEM.

6.4.1. To maintain the ER bilge pipe line integrity

The main feature of this is to install numbered tamper proof seals in the ER bilge system and various

other system components as listed below and to maintain a log of all seals that are installed in

engine room at any given time in the MARPOL SEAL LOG. (Ref: Illustration No. 6.5)

Company has supplied 2 types of seals as shown in photo no. AA&BB.

The company will supply these seals and it is for the sole purpose of use onboard vessels Managed

by the company. These seals shall not be used for any other purposes. These are non-reusable and

uniquely numbered.

Every time seal is broken new seal have to be obtained from Master and renewed.

AA MARPOL SEAL PHOTOS




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Date 15-Apr-16

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BB Photo of seal & illustration of procedure to fit the same

SEALS are to be fitted for various components in

a. Oily Water Separator System

b. Boiler Blow down line

c. Sewage Holding tank & EGB Soot tank System

d. Various overboard lines in Engine Room

e. Manhole doors of Bilge system tanks (IOPP Form TE39 A Sec 3.1 list of tanks.

f. Shore connections associated with Engine Room viz. Sewage, Sludge shore connection etc.

Each of the above is discussed in brief in the following section and few sample pictures are

attached.

Please note that in few of the pictures shown in this Manual, the seal shown is not our standard

supply of seal. The pictures are to be taken as guidance and only the standard supplied numbered

seals are to be used in our ships.

Since each component, piping etc. are of different size & construction, there are many methods by

which the seals can be fitted. The main aim is to prevent any unauthorized use. Recommended

practices are given at later sections in this Manual..

6.4.2. Oily Water Separator System

All the components including Flanges, Valves, Cocks, Copper Unions in the OWS associated

system are to be sealed using the numbered tamper proof seals.

As a guideline, the scope for above involves:

a. Piping from Bilge holding tank(s) up to Bilge Pump including all valves, flanges etc.

b. Piping from Bilge Pump up to OWS

c. The interconnection lines and valves within different OWS chambers

d. Piping from OWS final chamber up to OWS overboard valve

e. OWS Return & Drain line piping up to Bilge Holding tank(s)

f. Oil Content Monitor body itself to prevent tampering

g. FW flushing line to Oil Content Monitor from the Solenoid valve up to OCM unit.

h. The sample line from OWS discharge line prior to main 3-way valve up to OCM Unit

Depending on the ship, any other section associated with OWS operation also has to be sealed in




Rev. No. 2

Date 15-Apr-16

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such a manner so as to prevent unauthorized usage. Following guidelines can be used to seal small sections of copper piping like

a. 3-way copper piping b. Ball valve connection c. Inlet piping for Oil Content Monitor d. Small ferrules, copper unions etc. in copper piping.

The pictures give just an idea of how to go about. Vessel staff should take this guidance and to seal

the components in a thoughtful way suiting the particular location in order to prevent the

unauthorized opening.

Thin Metal Sheets are to be marked and cut as follows

Are to be bent as per required sizes as shown below




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Date 15-Apr-16

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Seals are to be fitted in a thoughtful way suiting particular location as shown below

As can be seen from the complete view above, Locking plates have been placed on the three-way

piping in such a way that 4 tamper proof seals are used to secure the unauthorized opening up of

three way piping.




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Date 15-Apr-16

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Arrangement to seal valve connections.

Arrangement to seal the inlet piping of an oil Content meter.




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Date 15-Apr-16

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Arrangement to seal any ferrules on the piping, pipe joints.

Once the sealing arrangement is in place

the pipe section must be painted with

high visibility Orange paint.

6.4.3. Boiler Blow down Valve

Since there are usually two valves in series in the Boiler blow down line, special emphasis is being

given to seal these valves. The flanges to be sealed in the manner as shown in the picture below.




Rev. No. 2

Date 15-Apr-16

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6.4.4. Sewage holding tank & EGB Soot tank disposal system

Since the above mentioned tanks in general, would have arrangements to be directly pumped overboard using an eductor through Fire & GS pump lines, these require special arrangements for sealing to ensure unauthorized usage. The manhole doors, outlet valves operating wheels & flanges of these tanks are to be sealed using

Tamper proof seals.

In-case of pipe line flanges, either a through hole is drilled in both the flanges and a seal is fitted or

one of the bolt can be taken out, a hole drilled at the bolt end and fitted back with the numbered seal.

In-case of man-hole doors, two seals are to be fitted at opposite sides through drilled holes in the flanges or by using 2 drilled bolts/studs in opposite sides. The corresponding tank outlet valve must be shut and locked with a chain and two of the links of the chain should be sealed in such a way that the valve cannot be opened without breaking the seal.

6.5. VARIOUS OVERBOARD VALVES

Following is the general list of various overboard valves in the Engine room but not limited to:

a. Fire & GS pumps overboard

b. IG Scrubber overboard

c. Main SW Pumps overboard

d. Ballast Pumps overboard

e. Auxiliary SW Pump overboard

f. AC Condenser SW overboard

g. FWG Overboard

h. Sewage overboard




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Date 15-Apr-16

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i. Galley disposer overboard

j. Grey Water overboard

k. Hospital Drain overboard.

l. Eductor overboard

m. Soot Collection tank Eductor Overboard etc.

All these overboard valves in ER must be clearly marked with its name and its number as per the

Ship’s piping diagram and the flange previous to the overboard valve is to be sealed. Either a

through hole is drilled in both the flanges and a seal is fitted or one of the bolts can be taken out, a

hole drilled at the bolt end and fitted back with the numbered seal.

Sample pictures as follows.

Ballast overboard Eductor overboard

Eductor overboard Fire and GS Pump, Bilge Ballast pump obd




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Date 15-Apr-16

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6.6. MANHOLE DOOR FLANGES OF BILGE SYSTEM TANKS (IOPP FORM A SEC. 3.1 LIST

OF TANKS)

The manhole door flanges for all the tanks as listed in IOPP Form TE 039 A Sec. 3.1 is to be sealed

using tamper proof Seals . Two seals are to be fitted at opposite sides through drilled holes in the

flanges of the manhole doors or by using 2 drilled bolts/studs in opposite sides.

6.7. SHORE CONNECTION FLANGES

All the Shore connection flanges associated with Engine Room viz. Sewage Shore Connection,

Sludge Shore Connection etc. are to be sealed by one of the following methods. Either a through

hole is drilled in both the flanges and a seal is fitted or one of the bolt can be taken out, a hole drilled

at the bolt end of the bolt and fitted back with the numbered seal. The general shore connections

available are as follows but not limited:

a. Sewage Shore Connection (P) & (S).

b. Sludge Shore Connection (P) & (S)




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6.8. COLOUR CODING.

6.8.1. The OWS & OCM Associated Piping

All the OWS and associated piping are to be painted with following Color scheme. 6.8.2. High visibility Orange Color

The Sections to be painted are as follows as applicable to individual Ships

a. Piping from Bilge holding tank(s) up to Bilge Pump including all valves, flanges etc.

b. Piping from Bilge Pump up to OWS

c. The interconnection lines and valves within different OWS chambers

d. Piping from OWS final chamber up to OWS overboard valve e. OWS Return & Drain line piping up to Bilge Holding tank(s)

6.8.3. Blue Colour

a. FW flushing line to Oil Content Monitor from the Solenoid valve up to OCM unit.




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6.8.4. Brown Colour

a. The sample line from OWS discharge line prior to main 3-way valve up to OCM Unit.

b. All the pipelines should be marked with the direction of flow after painting with above

mentioned colours.

Below shown are some examples of the actual appearance of the OWS overboard piping with

respect to above scheme.




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6.9. The sludge system piping.

All the items viz. valves, flanges etc. in the following sections of the Sludge System Piping to be

painted with RED Color.

a. Piping from double bottom Waste Oil tank(s) (that is tanks used to store Waste Oil) up to




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Sludge Pump suction side including all valves, flanges etc.

b. Piping from Sludge Pump up to Waste Oil Service tank (that is tank used to store Waste oil

for Incinerator service) including all valves flanges etc.

c. Piping from Sludge Pump up to Shore Connection sections in both Port and Stbd. Side of

the Poop Deck including all valves flanges etc.

All the pipelines should be marked with the direction of flow after painting with above mentioned colours. Below shown are some examples of the actual appearance of the OWS overboard piping with

respect to above scheme.




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6.10. LOCKING THE OWS OVERBOARD VALVE

It is recommended to lock the OWS Overboard valve with a metal box that is locked by two separate

locks, as shown below .One of the key must be with C/E’s Custody and the other with the Master’s

Custody at all times.

By the above system, it is ensured that at no time, the OWS can be operated to pump out E/R Bilges without the knowledge of both Master & the Chief Engineer.




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6.11. SLUDGE AND BILGE INTERCONNECTION

As per this Manual it is recommended that the interconnection pipe between the Sludge Pump &

Bilge Pump must be removed from place and stowed at a visible location near the sludge pump. The

pipe must be distinctly marked as shown in the photo.

The open sections in both the Pump suction manifolds are to be sealed with Blind flanges and seals

are to be fitted to these flanges

6.12. MARKING, SEGREGATION & STOWAGE OF VARIOUS HOSES IN ENGINE ROOM

As per this Manual, it is advised that there are no unaccounted hoses in the Engine Room at any

instant. Every hose in the engine room is being identified, a ship specific ID no. is given and a tag is

made indicating this ID no. and the same is fitted to the hose in a suitable way depending on the size

and material of hose.

All the hoses are also to be segregated and properly stowed under lock & key in 2nd Engineer’s

custody along with Wilden Pump.

Pictures below give an idea about how to stow and how to fix the tags etc. A Form TE 040 Record of various hoses in ER is being introduced to maintain inventory of hose in

the engine room. This form gives the details of all the hoses used in E/R with the details of location




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and application etc. Any hose that is newly put in use should be entered in this form and any hose

that is taken out of service is also to be entered as“DISCARDED”in the remarks column.

Various hoses used in Engine room are as follows but not limited up to

1. Hose for general Air/Water service

2. Hose for used oil, sludge transfers while cleaning tanks, LO sumps etc.

3. Hose for Oxygen & Acetylene Gas cutting operations

4. Hose for cleaning of Heat exchangers by Chemical Circulation method.

Illustrations for different methods to Tag the Hoses




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Compressed Air hose

.

Drain hoses.




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Other hoses.

Using Brass tags/punch




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All the hoses are to be properly secured. There should be a location fixed for each.




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6.13. INSPECTIONS TO ENSURE PROPER IMPLEMENTATION OF VECP

6.13.1. Chief Engineer’s Responsibility

As the Chief Engineer is the ECO on-board, is responsible for implementation of EMS onboard with the Master of the vessel.

6.13.2. Visiting Tech. Superintendents & Internal Auditors Responsibility

When carrying out vessel inspections and internal audits, the Superintendent shall randomly check

and compare the OCM recorded data and ORB entries. The superintendent shall make an entry in

ER log book about this verification and duly signed by Superintendent and Chief Engineer. Any

discrepancies found must be investigated and a note of the observation has to be put in the

Inspection Report.

Inspect the seal nos. in all the sealing points as per this manual and ensure they are tallying with the

Form TE 037 - Seal Renewal History Log Form maintained on board. Any discrepancies found must

be investigated and a note of the observation has to be put in the Inspection Report.




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Inspect the internal condition of Bilge Holding tank and OWS and a note of the observation to be put

in the Inspection Report.

6.13.3. Taking Over Chief Engineer’s responsibility

At the time of change of Chief Engineer, incoming Chief Engineer must:

Inspect the condition of Bilge Holding tank and OWS prior to take over. To facilitate this,Bilge holding

tank and OWS shall be kept opened immediately upon berthing where there is a change of Chief

Engineer. Once inspected, suitable entries to be made in ER log book duly signed by Outgoing CE

and Incoming CE. Any discrepancies found must be brought to the attention of Technical

Superintendent as early as possible.

Inspect the seal nos. in all the sealing points and ensure they are tallying with the TE 037 Seal

Renewal History Log Form maintained on board. Any discrepancies found must be brought to the

attention of EMS Cell and Technical Superintendent as early as possible. The TE 037 Seal Renewal

History Log Form should be endorsed by taking over C/E and send to Ems Cell.Randomly check

and compare the OCM recorded data and ORB entries. The incoming CE shall make an entry in ER

log book about this verification. Any discrepancies found must be brought to the attention of

Technical Superintendent as early as possible.

6.14. MARPOL EQUIPMENT SPARES.

V E C P SPARES




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As per this Manual , it is advised to make a separate Box and label as VECP SPARES to store the

minimum critical spares required to ensure satisfactory operational condition of all E/R related IOPP

& associated equipment viz. OWS, Incinerator, Bilge Pump, Sludge Pump, Sewage Plant.

The list of critical spares for the above equipment may vary from ship to ship. SMS Technical

Manual can be referred to arrive at the list of spares that are critical and those items are to be stored

in this box. Also, the “Form TE 04 - Monthly MARPOL Report “gives information about the critical

spares related to this equipment. Company will prioritize on supply of these environmental critical

spares.

The idea is that, when these spares are identified and stored separately, the awareness of its

importance is highly increased among the ship board members and probability to fail in making

timely requisitions for these items and procuring these becomes very less thereby reducing the

possibilities of operational failures of these equipment.

An Inventory of all the spares stored inside this box must be placed in the box and updated on a

monthly basis.




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Also monthly MARPOL report is to be made and forwarded to the technical Superintendent

regarding the condition of the pollution prevention equipment on board with the points that require

special attention in the remarks columns.

6.14.1. PROMINENT MARKING OF INTERCONNECTION VALVES WITH ER BILGE SYSTEM

Prominent Marking of Valves that are interconnected with ER Bilge System that are to be regularly

operated for either Testing or Operational purposes viz.

a. Emergency Bilge Suction

b. Direct Bilge Suction

c. Cargo holds Bilge Suction

6.14.2. Emergency Bilge suction valve

The Emergency Bilge suction valve shall be clearly identified as can be seen below. The valve

operating wheel should be painted with Black & Red paints as indicated.

Two separate chain links connected with a lock and key on one end (which can be opened & locked

during routine check) and with a tamper proof seal (made of plastic) fitted on the other end. As

shown below. In case of emergency same can be broken).The valve operation to be tested as per

the interval mentioned in PMS and the same should be recorded..

Illustration of locking the valve with two separate chain links .




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6.14.3. Direct Bilge Suction valve

The Direct Bilge suction valves shall be clearly identified as can be seen below. The valve operating

wheel should be painted Black as indicated. The valves should fitted with seal as mentioned in

above section 6.14.2, similar to emergency bilge suction valve. The valves operation to be tested

weekly.

.




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6.14.4. Cargo hold bilge suction valves.

The Cargo Hold Bilge suction valves shall be clearly identified as shown below. The valve operating

wheel should be painted with White & Red paints as indicated. There should not be any seal fitted to

these valves. Depending on the frequency of usage, the valves to be tested as suitable and should

be ensured to be in good working condition at all times.

6.15. All overboard Blank Flanges

To prevent unauthorized connections within engine room and machinery spaces, every blank flange

associated with any piping leading overboard, on systems such as Auxiliary sea water service, main

engine sea water cooling, steam blow/air blow connections to shipside valves, Boiler Blow down

valve, Sewage overboard valve and any other valve or flange, which C/E feels can lead to

unauthorized connections in engine room piping shall be permanently secured and fitted with the

seals.

Valve wheel on main deck for shore disposal of bilge water / sludge shall be locked with a chain, key

for the pad lock to be in possession of the Chief Engineer ONLY. Seals to be fitted on all flanges

between deck penetration and the valve.




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6.15.1 INVENTORY CONTROL OF SEALS

a. The Chief engineer shall keep a record of TE 37 when the seals are fitted. This record shall

be a part of the Masters/Chief Engineer Handover notes.

b. The Master shall retain the new replacement seals. Proper records of seals issued must be

kept in Seal inventory log (TE-38A).

c. If a seal has to be broken for any reason (maintenance, etc.), details of the reasons and new

seal number fitted to be entered, record (TE 38 Seals renewal log) maintained.

d. Record of seal numbers used along with their location shall be maintained by the Chief

Engineer. (TE 37 Summary of sealing points).

e. Vessel should prepare a ship specific schematic diagram identifying all relevant flanges and

valves. The flanges and valves are to be identified in numerical order (Starting with “1” from

the 1st flange on Oily Water Separator bilge pump discharge side). This diagram shall be

maintained.

f. The integrity of the seals should be checked on a 3-monthly basis by the Chief Engineer.

Entries of checks done must be made in the “Engine Room Log Book”

g. In case any evidence of tampering of seals is noticed, management office and the

Environmental Compliance officer should be informed immediately and investigation should

be carried out onboard.

h. The seals will be checked at random during Superintendent and internal auditor visits.

6.16. PROCEDURE FOR OPEN REPORTING OF NON COMPLIANCE

ENVIRONMENTAL COMPLIANCE OFFICER

The chief engineer shall be the designated environmental compliance officer (eco) on board and is

fully responsible for the implementation of the environmental compliance policy on board. The duties

and responsibilities of the environmental compliance officer are laid down in EMS manual.

ENVIRONMENTAL COMPLIANCE DECLARATION FORMS (Form M-29)

a. At the time of sign-on, each crew member shall sign a declaration in writing that they are

aware of company`s Environmental Management System and completed forms are to be

retained on board.

b. Environmental compliance declaration forms should be retained on board in Master’s

custody for 3 years after the date of sign off of the ship’s staff.


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ENVIRONMENT MANAGEMENT SYSTEM (EMS) …competency.synergyship.com/pdf/EMS/Ch_06_Voluntary_Environment… · strict adherence with International Maritime Organization ... Relation