Ecp Training Handout Master and Engine Officers

Alpha Marine Consulting Ltd.
Environmental Compliance Plan

(ECP) Training
INITIAL
© 2015 | COLUMBIA Shipmanagement | Prepared by: Alpha Marine Consulting Ltd. 1 of 96 | Revision C | September 2015
Sections
• ECP Introduction • Garbage Pollution Prevention
1 (MARPOL Annex V)
8
• ECP Audit Process
2 • Open Reporting System
9
• ECP Applicability and Duties
3
• Record Keeping
10
• Framework of ECP requirements
4
• Employee Training Program
11
• Environmental Tag System (ETS)
5
• Common Deficiencies
• Oil Pollution Prevention (MARPOL 12
6 Annex I)
• Sewage Pollution Prevention • Guidelines

13
7 (MARPOL Annex IV)
ECP Introduction
Environmental Compliance Plan (ECP)

Compliance with the ECP is a requirement of the Plea
Agreement and a special condition of CSM probation.
Applicability
The ECP applies to all oceangoing vessels that are technically
managed by CSM and carry a Certificate of Financial Responsibility,
as well as to all shore side employees and crew who are involved in
their management.
The purpose of the ECP is to introduce additional (over and above

the mandatory ones) requirements and to ensure that all these
vessels fully comply with all applicable marine environmental
protection rules and regulations.
Environmental Compliance Plan (ECP)
The Story
• Whistle Blowers (present photos or give verbal
statements to USCG or PSC)
• Investigation begins: wrong entries in ORB or “tools”
are discovered i.e. Indications of MARPOL violations
• Evidence of MARPOL violations e.g. Flexible hoses,
samples from the OWS overboard valve / piping
• 99% accept the Plea Agreement in order to avoid costly
and endless trials. This means: Probation, fines
(according to Company’s financial capacity) and ECP to
be implemented to all Company’s vessels
• Fulfillment of ECP requirements is verified by the TPA
and CAM who are appointed by the US Authorities
The “tools”
The “tools”
The “tools”
Flexible hoses shall be stored in a secure location
ECP Audit Process
Third Party Auditor (TPA)
As part of the ECP, the TPA, appointed by the US

Court, shall report to US Authorities and to the
Court during the entire period of probation.
Court Appointed Monitor (CAM)

As part of the ECP, the CAM appointed by the US
Court, shall monitor CSM performance and
capabilities, review the relationship between CSM
and TPA and report to the US Authorities and to
the Court throughout the probation period.
TPA/CAM and auditing process
1st Year 2nd Year 3rd Year

TPA TPA TPA
Initial Audits Ongoing Audits Final Audits
TPA TPA TPA

Quarterly/Annual Quarterly/Annual Quarterly/Annual 4th Year
Reports Reports Reports CAM
Review of
Internal Audits
CSM CSM CSM
Internal Audits Internal Audits Internal Audits
Review by Review by Review by

CAM CAM CAM
TPA and auditing process
The duties of the TPA

shall be to conduct the assess Company’s policies, ensure regulatory
procedures and equipment compliance, correct non-
audits described in the in place, to assure compliance and prevent
ECP and to issue Reports compliance with the ECP future non-compliance
of Findings, in order to…
Vessel Audits, Office Audits and

Training Center Audits
• TPA reports are submitted to CSM, US Authorities and CAM

• TPA shall function independently of CSM and must have no
other ongoing relationship with CSM
ECP Applicability and Duties
CSM is committed to full compliance with the

applicable requirements of:
• International Conventions (SOLAS, MARPOL, ISM, etc.);

• Classification Societies;
• Flag Administrations;
• Local and Port State Authorities;
• USA Federal and all applicable laws and regulations of all
States upon whose waters the Company’s vessels operate;
• ISO 14001; ISO 9001 and
• Company’s Procedures which have been developed or
upgraded in order to comply with the ECP.
ECP Applicability
The ECP applies to all Company’s personnel ashore and
onboard, including contractors providing services on
behalf of the Company, visitors & non-crew members
The Company shall advise its personnel of its

commitment to environmental protection
A notice shall be posted at the gangway of each

vessel while in port, informing visitors, vendors and
non-crewmembers on CSM environmental
commitment and general waste disposal procedures
Duties of Environmental Compliance Manager (ECM)

• Ensure the implementation of an upgraded • Communicate CSM ‘non retaliation’ policy
EMS to comply with the ECP
• Ensure the establishment of the
• Ensure the full implementation of the Environmental Tag System and maintaining
Engineering Requirements of the ECP a master tracking document
• Review, investigate and document in a timely • Ensure the development and maintenance
fashion all reports for Environmental of a system to track and report each
Compliance vessel’s machinery space waste quantities
• Ensure that the TPA audits are properly and capacities
performed • Develop a comprehensive annual budget
• Ensure that any TPA, CAM or other ECP • Ensure all Company employees are fully
observations and recommendations are familiar with the Company’s Policies
documented, tracked and resolved
• Ensure that development and provision
• Develop a tracking mechanism to ensure requirements for the employee training
corrective action on recommendations made programs, as specified in the ECP, are met
by the TPA, within a time frame of 30-60 days
• Take all necessary steps to ensure the full
• Establish and oversee the Company’s Open cooperation of all employees during all
Reporting System activities required by the ECP and the EMS
Duties of Master
• Ensure that prompt reports are made to the USCG
• Ensure crewmembers’ compliance with the International
regulations, ECP and Company’s environmental standards
• Maintain on board all required records
• Ensure that every crewmember has received appropriate
training
• Maintain replacement Environmental Tags, used Env. Tags
as well as an inventory of the unused Environmental Tags
• Ensure the use of, and personally review, handover notes
for himself, Chief Officer, Chief Engineer and 2nd Engineer
Duties of Chief Engineer

• Ensure compliance with the • His handover notes must include an
Engineering Requirements of the ECP environmental component and
• Measure, monitor and properly description of the current status of
manage machinery space generated the environmental related equipment
wastes and the condition of any • All E/R records, soundings and tank
equipment having oil-to-sea interfaces
on a daily basis measurements must be accurate and
recorded truthfully
• Timely resolve E/R, machinery space
or pump room related environmental • Report all instances where
concerns, such as inoperative or inadequate CSM response associated
ineffective pollution prevention with spare parts delivery,
equipment, waste handling or maintenance and repair or other
monitoring equipment and leakages factors, caused conditions leading to
• Ensure that all E/R personnel have excessive production in shipboard
appropriate training waste streams
Framework of ECP Requirements

REFERENCES
ENVIRONMENTAL TAG SYSTEM (ETS) ECP, Section VIII, § B., COPR-2.3, GOPR-7.3, MSOPR-11.8
ADDITIONAL OWS / OCM ECP, Section VIII, § H., MOSPR-11.1 -11.2 – 11.3 – 11.4 –
REQUIREMENTS 11.5 -11.6
BILGE SAMPLING & OWS ECP, Section VIII, § F., MSOPR-11.16
PERFORMANCE ANALYSIS
OIL RECORD BOOK – RECORD KEEPING MIN 09 ‘ORB Part 1 & 2’
ADDITIONAL OIL RECORD BOOK ENTRIES MIN 09 ‘ORB Part 1 & 2’
GARBAGE MANAGEMENT SYSTEM ECP, Section VII, § D, 2 l, Garbage Management Plan
TANK SOUNDING RECORD BOOK ECP, Section VIII, § K., MSOPR-11.14
LEAKAGE LOG ECP, Section VII, § D, 2 b & c, MSOPR-11.15
SEWAGE TREATMENT ECP, Attachment 4, MSOPR-12.1

REFERENCES
INCINERATOR MSOPR-11.10
FUEL OIL/LUBE OIL PURIFIER SETTINGS ECP, SECTION VIII, § L., MSOPR-9.3 -9.4 -10.1
AND LINE BREAKS
OIL TO SEA INTERFACES ECP, SECTION VIII, § M., MSOPR-10.4
SHIP SOURCE POLLUTION RESEARCH & ECP, SECTION VIII, § G.
DEVELOPMENT PROJECT
ODME REQUIREMENTS ECP, SECTION VIII, § N., GOPR-7.3
SPECIFIC OPERATING PROCEDURES ECP, ATTACHMENT 2
OPEN REPORTING SYSTEM ECP, SECTION II, § C., GOPR-1.9, COPR-2.2
ENVIRONMENTAL COMMUNICATION ECP, SECTION VII, § D, 2 S
TPA AUDITS GOPR-18.4, COPR-15.6
Environmental Tag System (ETS)
Environmental Tag System (ETS)

In order to prevent unauthorized by-passing of the
OWS or other equipment, the “Environmental Seals
Handling and Tracking” is a system of using non re-
usable and uniquely numbered seals in various
positions in the Engine Room & Shore Connections
Each seal and its installation date & time shall be

recorded in the
Environmental Seal Logbook
ETS - Where should the Seals be placed?

• Discharge piping systems that • OWS fresh water line
are or may be connected to the
• Remotely operated valves
oily bilge system
• Blank flanges connected to any piping leading
• Main Cross Connections
overboard (sea water, M/E water cooling etc.)
• Emergency Bilge Suctions
• Flanges from bilge pump to waste oil tank, bilge
• Main Bilge Suctions tank, waste oil incinerator tank
• Bilge Shore Connections • Forecastle space bilge overboard valve, bilge
(transfer system & valves) eductor driving valve, bow thruster well eductor
• Sludge Shore Connections driving valve
(transfer system & valves) • Valve connected to general service and bilge
• Sewage Shore Connections pumps in case such pumps are intended for de-
(transfer system & valves) ballasting and/or incase E/R bilges are connected
to ballast piping system
• Sewage shipside valves
(if port requirements require) • MARPOL Annex I and II overboard discharge lines
• OWS piping system and • Entire piping system including flanges and valves
overboard valve connected up to the ODME
ETS - Responsibilities
MASTER:
• Maintains replacement seals in a secure location
• Verifies that seals do not have duplicate numbers
• Maintains the Environmental Seal Register
• The new seals, handed over each time, must be crossed
out on the Environmental Seals - Vessel Tracking Document
(ES-VTD)
• Receives the worn or damaged seals, makes a relevant
entry in the Used Seals Log (USL, form GOF-7.3) and places
them in a dedicated secured place
• Ensures proper handover of the used and unused seals,
the Environmental Seal Register (ESR) and the ES-VTD to
the new Master
CHIEF ENGINEER:
• Receives the seals from the Master and places them in
identified places without delay
• Maintains the C/E Environmental Seal Log Book (CE-ESLB),
properly recording the date, time, seal numbers and
persons involved in placing or removing seals
• Gives numbers to all flanges with seals starting from
discharge of pump or equipment and ending at overboard
valves
• Maintains ship’s piping plans with location of seals
• Keeps ORB records
• Hands over to the Master any worn or damaged seals and reports if any
cannot be retrieved
• Ensures that relevant records are retained on board for at least 3 years
CHIEF OFFICER:
• Receives the seals from the Master and places them in
identified places without delay
• Maintains the C/O Environmental Seal Log Book (CO-
ESLB), properly recording the date, time, seal numbers
and persons involved in placing or removing seals
• Identifies valves and flanges that need to be sealed
and gives seal numbers
• Hands over to the Master any worn or damaged seals
and reports if any cannot be retrieved
• Ensures that relevant records are retained on board for
at least 3 years from the date of the last entry
ETS - Implementation
Acceptable reasons for breaking a seal:
• Routine Maintenance Works

• Repair Works
• Normal Discharge or Testing of the OWS
• Class / PSC Survey Requirements
• ECP Auditing Process
• Emergencies
Bilge/sludge shore connection blank flanges fitted with Seals
ETS - Marking of the crossover valves

Use of cross connections from E/R bilge mains to the
suction piping of larger pumps is prohibited!!!
ETS - Marking of the crossover valves

• Bilge Cross Connection Valve international orange
bodies and associated hand and sealed
wheels
• Deck plates above or near these bright colour
cross connections
• “Bilge System Piping Crossover – international orange
Emergency Use Only” sign shall with 7.62 cm (3 inch)
be permanently fixed nearby letters
• In the case of remotely operated valves from the Engine Control

Room, their push buttons must be fitted with environmental seals
and be accompanied by a suitable sign
ETS - Emergency Bilge Suction Valve

Bilge suction valves not connected to bilge
main, and independent emergency suctions to
E/R bilges, like those which may be connected
to sea water pumps, must be painted brightly
(signal red) and labelled “Emergency Bilge
Suction – Emergency Use Only”
Valves / wheels to be sealed

– use of seals to be logged
OWS overboard valve fitted with seals, marking and padlock

Sequence of entries in the ORB for discharging

through the OWS:
• Test of OWS and OCM for 30 minutes via recirculation

• Unsealing of the OWS Overboard valve
• OWS normal operation
• Sealing of the OWS Overboard valve
The discharge of bilge water through the OWS is preferable to

be conducted during day light
ETS - OWS Sample/Flush Line

The OWS and OCM must be made tamper proof to ensure that no
bilge water is discharged overboard deliberately or inadvertently.
The sample line from the OWS
discharge connection to the sample
/flush line control valve must be
painted red to distinguish it from
other tubing and piping.
The end nearest to sample/flush
line control valve and any tubing in
between the control valve and
OCM must be protected to
prevent any disassembly of the
sensing system.
MARPOL (IMO) line - Seals at the discharge lines of the OWS
Installation of seals at the connections

of the bilge sample line from the OWS
to OCM
Proper installation of seal
Installation of a seal at a bolt of a flange

Installation of seals at the flanges of a piping system
ETS - Environmental Seal Register
ETS - Vessel Tracking Document
ETS - Used Seals Log
ETS - Seal Logbooks (C/E & C/O)
Oil Pollution Prevention

(MARPOL Annex I)
OWS / OCM Testing

• Annual operational test of the OWS &
OCM for at least 1 hour of continuous • OCM sensor replacement every 5 years
operation by the C/E and any involved • Both tests must be carried out without
E/R personnel, in the presence of a any dilution of the contents of the bilge
Technical Superintendent (TSI) or the TPA tank or the sample line
• Monthly operational tests of OWS &
OCM under actual operational conditions • Relevant report regarding the test to be
(if possible) for 30 minutes continuous sent to ECM
processing of the contents of the Bilge • If the testing reveals that the OWS is not
Holding Tank adequate then an immediate report
• Records of the tests shall be kept in the shall be made to the ECM and
ORB responsible TSI
• A copy or a photograph of the E/R alarm • Soundings of the Bilge Tank to be taken
printout to be retained and appended in before and after the test
the ORB page documenting the test
(Ref.: MSOPR 11.3, 11.4, 11.5)
Portable Pumps
• The pump to be secured with a chain lock
and key to be kept by the Chief Engineer
• The chain lock to be fitted with a seal and
relevant entry to be made in the Chief
Engineer’s Environmental Seals Log Book
• The pump may only be used with the
express permission of the Chief Engineer
• Date, time and person who performed task
to be recorded in the Engine Room Logbook
and in the Oil Record Book (if applicable)
• Take photographs of the pump when in
service, for objective evidence of its use.
Photos to be retained by the Chief Engineer
• Ref. MSOPR-11.9
Sounding Log
The quantities of all bilge tanks, bilge wells and all oil residues and
sludge tanks shall be recorded in the “Engine Room Bilge, Oil
Residue and Sludge Tank Sounding Log” (Ref. MSOPR-11.14)
• SL shall be maintained in the ECR
• SL shall be completed and signed by the

officer or rating who takes the soundings
• Soundings shall be taken twice per day at

08.00 and 17.00 hour
Ensure that rough notes are dated, even if managed on scrap

paper, and maintained for at least 3 years
Sounding Log
Leakage Monitoring
A systematic and controlled way to monitor and record leakages, inside
and outside of machinery spaces, and arrange for relevant repairs.
If, at any time, a line or component on a fuel, lube or waste oil system
fails, including high pressure lines on diesel engines, then:
• Leakages shall be reported to C/E and rectified as soon as possible
• An entry shall be made in the Leakage Log with a notation as to the
quantity released and an explanation on how the unintended
released fluid was handled
• Unintended releases of abnormal quantities of water (sea, fresh,
condensate or cooling) shall be recorded
(Ref. MSOPR-11.15)
Leakage Monitoring
Oil to Sea Interface System

Oil-to-sea interfaces include any mechanical or other equipment where
seals or surfaces may release small quantities of oil into the sea, i.e.:
• oil lubricated stern tubes
• bow or stern thrusters
• stabilizers
• hydraulically operated controllable pitch propellers, etc.
Same requirements are also in place through the VGP
Oil to Sea Interface Log

When known, an explanation of the loss shall be provided, along with the dates and time the loss
occurred and the signature of the Engineer that identified the loss.
• Any replenishment of oil into the head tanks, operating systems reservoirs or other receivers
associated with this equipment shall be logged, regardless of the quantity involved
• Any ingress of water or drainage of water into or from these systems must also be logged
• Stern tube lube oil loss must be logged and reported immediately on each occasion
• Oil to Sea Interface Log must be sent monthly to ECM and responsible TSI
(Ref. MSOPR-10.4)
Attention
If any C/E fails to promptly and accurately report
such conditions, he will face appropriate
disciplinary action, even leading to termination
of his employment
Oil to Sea Interface Log
Fuel Oil and Lube Oil Management Log

System for monitoring FO & LO management, including the
operation of FO & LO purifiers and line or piping failures
• Recording the operation of all purifiers on a monthly basis
• Installation of hour meters on purifiers motor controllers
• Records for incidents involving poor quality fuels
• Any extraordinary operations (such as frequent draining of FO
service and settling tanks, draining engine LO sump tanks of
excessive water, waxing, compatibility, stratification or
contamination, etc.) shall be recorded in the ORB Part I
• Explanations to be provided for the handling of unburned oil
residues (sludge), oils, oily wastes and used filters
(Ref. MSOPR-9.3 -9.4 -10.1)
Fuel Oil and Lube Oil Management Log
ODME requirements
• Installation of tamper proof connections and fittings
• Installation of numbered seals on supply lines, leading from
the discharge sample line to the monitoring cell of ODME
• Seals to be placed on strainer covers
• Prevent any connection to clean water sources or deter
other methods that may be employed to trick the ODME
• Operators to be properly trained
(Ref. GOPR-7.3)
Critical Spare Parts

All critical spares of OWS, OCM, STP, ODME, Incinerator, Bilge
Pump and Sludge Pump shall be retained onboard in
accordance with the List of Critical Spares (Form FR11.20)
Sewage Pollution Prevention

(MARPOL Annex IV)
Sewage Discharge
Sewage status From an approved Comminuted and Not comminuted or
STP disinfected from a disinfected from a
holding tank holding tank
Distance from No restrictions 3 miles 12 miles
land
Ship’s speed No restrictions ≥ 4 knots ≥ 4 knots
Comments The effluent shall Sewage stored in Sewage stored in
not produce visible holding tanks shall holding tanks shall not
floating solids nor not be discharged be discharged
cause discoloration instantaneously but instantaneously but at a
of the surrounding at moderate rate moderate rate when
water when ship is en route the ship is en route
(Ref. MSOPR-12.1)
Sewage Discharge
Minimum Requirements
 C/E: ensure sewage overboard valves(s) are positively locked
in closed position if the vessel operates in a prohibited area
to avoid accidental discharge of sewage
 C/E: ensure employees, assigned with duties relevant to
sewage processing equipment, handling and disposal of
sewage, are familiarized and trained
(Ref. MSOPR-12.1)
© 2015 | COLUMBIA Shipmanagement | Prepared by: Alpha Marine Consulting Ltd. 61 of 96 | Revision C | September
| Revision 2015
| date issued
Sewage Discharge
Minimum Requirements
 On vessels fitted with a sewage holding tank and before the
vessel enters a prohibited area, the Engineer on duty shall
ensure that sewage is directed into the sewage holding tank
and that the sewage overboard valve(s) are closed
 The Sewage Treatment Plant (STP) is considered as critical
equipment and therefore sufficient spares are to be carried in
accordance with manufacturers’ recommendations
(Ref. MSOPR-12.1)
© 2015 | COLUMBIA Shipmanagement | Prepared by: Alpha Marine Consulting Ltd. 62 of 96 | Revision C | September
| Revision 2015
| date issued
Garbage Pollution Prevention

(MARPOL Annex V)
Garbage Segregation Categories

Segregation Categories Marking and Stenciling the containers
Plastics “Plastic” (Yellow)

Incinerator Ashes “Incinerator Ashes” (Black)
Food Waste “Food Waste” (Green)
Cooking Oil Labelled only
Rags Labelled only
Recyclable Garbage
• Glass “Glass” (Blue)
• Aluminium cans Aluminium cans (Grey)
• Paper, cardboard, corrugated board Labelled only
• Wood “Wood” (Brown)
• Metal “Metal” (Grey)
Hazardous Waste “Red”
Garbage collection drums

• Garbage must be kept in metal
containers
• The use of 205 litre steel barrels, with
purpose made lids, which completely
cover the top of the container and have a
lip of at least 2 to 3 centimetres, are
considered to be ideal
• The lid must also have the facility to
allow it to be effectively sealed when
closed with plastic seals being available
for this purpose
Open Reporting System
Open Reporting System (ORS)

• Through the ORS, any shore side and vessel employee may report freely and even
anonymously any concerns or issues of non-compliance with the ECP, MARPOL
rules, any other regulations or the CSM Policies
• Crew members are informed about ORS prior to each term of
employment
• Notices for the ORS are posted in lounge spaces, Bridge, ECR,
common areas, etc.
• Inform everybody through publications and organization-wide
announcements issued on at least a quarterly basis
• Concerns must be submitted via free mail or toll-free phone
• Any concerns submitted will be investigated and prompt steps are
to be taken to resolve them
Failure to notify grounds for disciplinary action, which may lead to dismissal
and/or criminal charges, subject to applicable labour laws.
(Ref. GOPR-1.9, COPR-2.2)

Open Reporting System

• CSM prohibits retaliation against those who report non-
compliances
• The ECM shall be informed of each such Open Report, and
shall provide a copy of any report to the CAM
• CSM shall publish reports to the fleet on a quarterly basis
concerning the Open Reporting System, to demonstrate that
the system is working
(Ref. GOPR-1.9, COPR-2.2)

Record Keeping
10
Records must be kept on board for a period of 3 years

after the last entry
• Sounding Records
• Logs
• Engine Room Alarm Printouts
• Circulars / Bulletins
• Training Records
Bilge, Sludge and Slop management record keeping

Bilge alarm E/R bilge alarms weekly tests for manned E/R operation &
Test records DAILY when operating in UMS mode
Bilge & sludge

receipts Whenever bilges & sludges are delivered to shore facilities
OCM/ODME Records of calibration / Calibration Certificates or Records

Calibration – for OCM’s cell renewal
or renewal records
• Extraordinary operations related to the bunker and E/R

FO & LO tanks
Engine logbook
• Unintended/accidental release of water, FO & LO from
E/R machinery
Weekly records of E/R waste oil, sludge & bilge tank

Tank Sounding Log retained quantities in ORB - enhanced by twice per day
measurements and record keeping as per CSM procedures
Employee Training Program
11
Crewmembers Training Program

ECP Initial Training ECP Computer ECP Refresher
Based Training Training
(CBT)
• provided ashore • to be used onboard within • a shorter

prior signing-on by 7 days after signing-on, in module as
qualified instructors case the ECP training was refresh training
not provided prior joining
• as a refresher training
• for Masters and Engine Officers:

MARPOL, ECP and ORB modules (duration 2 days) • Masters and Engine
• for Deck Officers: Officers: 8 hrs
MARPOL and ECP modules (duration 1.5 days) • Deck Officers: 6hrs
• for Ratings: • Ratings: 4hrs
MARPOL and ECP modules (duration 1 day)
The successful participation is demonstrated

through an examination with passing rate ≥ 70%.
The TPA shall conduct:

• A review of the training courses at a minimum of 1 training
establishment per year, provided that courses at all training
establishments are reviewed at least once during the first 3
years of the probation
• In the 4th year, a review of training courses offered at the

location with the highest number of students is required
Common Deficiencies
12
Common deficiencies related to Flexible Hoses
Common deficiencies related to Sewage Management
• Not appropriate tablets for the

STP
• No chlorine test equipment on
board, no tests being
performed. CSM!
• Crew did not have any
information on testing and
Chlorine dosing of the STP. CSM!
The capacity of the Sewage Holding Tank, as stated on the

CSM!
International Sewage Pollution Prevention Certificate, not
in accordance with the vessel’s Capacity Plan.

• STP by-passed while in port, inlet valve seized
• STP dosing system replaced by alternative means; no chemicals onboard
• STP not in use while in port
• STP components missing
• STP electrical wiring tampered with to indicate “ON”, while off
• STP corroded and holed
• STP malfunctioning e.g. due to clogged return line
• Sewage tank with holes
• Sewage discharge pipe leaking
• Sight glasses, inspection windows and tubes deteriorated, not clear
and/or painted
• The hoses for adjusting air flow

for the sludge sewage return, on
top of the STP, which allow
observing its normal operation,
were not transparent CSM!
• Defective STP CSM!
• Leading raw untreated / partially
treated sewage into the Bilge
Holding Tank CSM!
• Leading bilges to the STP CSM!
Common deficiencies related to Incinerator

• Operation procedures, including proper and normal shut-down,
emergency shut-down and procedures for loading garbage, not
posted at the Incinerator’s control panel
• Operator not properly trained
• Missing Type Approval
• Wrong rate is recorded
• Defective Incinerator
• Vessel lacking of an inventory of the expired medications
which were disposed off in the Incinerator CSM!
Common deficiencies related to ETS

• The Environmental Seals – Vessel Tracking
Document missing / not updated
• The history of seals could not be ascertained
• Unused & Broken seals found to be maintained by
other crew members and not only by the Master
• Inconsistencies between other Logs (i.e. sludge
discharge receipts) and the Seals Log
• Seals not fitted to OCM fresh water/flush line, if
required
• Shore connections not fitted with seals
• Seals installed in such a way that piping is not
tamperproof
Common deficiencies related to Bilge-main Cross

Connections
• Cross Connections not properly labeled
“Bilge System Piping Crossover – Emergency Use Only” CSM!
• Deck Plates, Valve Bodies or Hand Wheels not properly painted
• Crossover valves not fitted with seals
Common deficiencies related to Blank Flanges

• Blank Flanges at systems (e.g. sea water service, M/E water
cooling) leading overboard not sealed or permanently secured
or removed CSM!
Common deficiencies related to OWS / OCM

• OCM allowed the OWS to function
normally without sample flow, while
valves from the OWS discharge to sample
line control valve, were not removed or
sealed CSM!
• Wrong type of OWS in Form B of the IOPP CSM!
• Missing Type Approval
• Wrong rate is recorded
• Operators not trained
Sample line of the OCM not red painted. CSM!

Posters not in position. CSM!
Common deficiencies related to ORB entries

• Evaporation of sludge not recorded • Wrong codification
• Wrong entries for the transfer of bilge • Calibration (exchange) of CSM!
water OCM not properly recorded
• Weekly ORB entries for sludge not • Operation of Incinerator
performed CSM! not properly recorded
• Missing entries for transfer of the • Wrong entries of OWS /
contents of Tanks which are overflowed. Incinerator rates
• Scratches and overwriting in the ORB • IOPP tanks description not
• Maintenance (& filter replacement) of as per IOPP Supplement
the OWS not properly recorded CSM!
• Malfunction of the OWS/OCM not Attention: the OWS and
the OCM are two (2)
properly recorded different items working
• Operational tests of the OWS and OCM together!!!
not properly recorded
Common deficiencies related to Bilge Tank cleaning

(every 6 months)
• No records maintained for the Bilge Tank cleaning

• Enclosed space entry permit for the Bilge Tank
cleaning not available
• Disposal of the contents of Bilge Tanks not
documented
• OWS source tanks not cleaned at least once every
6 months CSM!
• Missing entries in the ORB for Bilge Tank cleaning CSM!
Common deficiencies related to E/R Bilge & Oil

Residues (sludge) Tank Sounding Log
• Inconsistencies with the ORB

• Uncontrolled Logs, pages not numbered
• Missing / wrong entries, etc.
• Not signed
Common Deficiencies related to Garbage Management
• Garbage drums combustible,

not rust protected and not
color coded in agreement with
the requirements of the
Garbage Management Plan
(GMP)
• Mixed garbage
• Garbage wrongly categorized
as Category (E) instead of
Category (F) CSM!
Common CSM Deficiencies Related to EMS

• No proper usage of numbered seals
• Not all required documentation and reference material were available on board (Tank
tables, System schematics, Critical Spare Parts List, List of Regulated Wastes, etc.)
• Not proper Oil Record Book Entries
• OWS / OCM requirements not being followed properly
• Sounding Records and Logs (including draft records or forms used when taking soundings)
were not maintained on board for a period of 3 years from the date of the final entry
• E/R Alarm printouts and records were not maintained on board for a period of 3 years
from the date of generation
• Tank measurements were not found accurate or truthfully recorded
• Indications/brightly colored signs were not posted near the Bilge-Main Cross Connections
• Handover Notes for Master, C/O, C/E and 2nd Engineer did not include descriptive entries
of current status of operation, maintenance and repair for all pollution prevention
equipment
Common CSM Deficiencies Related to EMS

• Crewmember training from Master and C/E on pollution prevention requirements not
documented
• Blank Flanges not permanently secured or not fitted with numbered ETS tags
• The Ballast Water Management Manual did not contain a section on “detailed
Sediment Removal Procedures” as required by the Ballast Water regulation at 33 CFR
151.2050(g)(3)
• The standard “DPA Contact” list was replaced by signs referring to “Environmental
Compliance Manager” instead of having both sings available in common areas
• The Bow Thruster was not listed at the log sheet that is provided as part of MSORP10.4
• Vessel carrying R134a for reefer containers was not added to the ODS list and the loss
and replenishment of R134a had not been recorded accordingly CSM!
• The ODME calibration certificate was missing
Guidelines
13
HOW SHOULD YOU PREPARE FOR PSC INSPECTIONS?

If any of the following “red flags” are discovered during a PSC inspection without a
bona-fide explanation for the same, a criminal investigation will be triggered:
• Flange nuts and bolts around the OWS or overboard discharge valve that show
recent use
• Freshly painted piping flanges, nuts or bolts in the vicinity of OWS or overboard
discharge valve
• Flexible hoses in and around the OWS or overboard discharge valve
• Oil on valve stems of the discharge side of the OWS
• Excessive oil in the overboard discharge valve
• An inoperable or malfunctioning OWS or Incinerator
• Improper or missing entries in the ORB or the GRB
• Entries in the ORB that exceed the capacity of the machinery or tanks
• Bilge soundings that do not conform to the ORB entries
• Existing piping/valve arrangement does not match original piping diagrams
Items to consider Alpha Marine Consulting Ltd.
Inconsistencies between logs

(OCM, ORB and other Logs)
Pre-Arrival Checklist
The Officers and Crew should ensure that the following steps are taken to
avoid any suspicion that the vessel is violating MARPOL or U.S. law:
1. All flexible hoses and any other material that could be utilized to bypass
the OWS should be removed from the vicinity of the OWS and stored in
their designated area
2. The OWS and Incinerator should be tested to ensure
that they are fully operational
4. If the OWS or Incinerator is not operational, there should be an
explanation in the appropriate Log book for why the machinery is not
operating and what steps have been taken (i.e. ordering spares,
scheduling technical support, etc.)
Pre-Arrival Checklist
5. Maintenance records for OWS and Incinerator should be up-to-date and
complete
6. There should be sufficient spares on board for the OWS and Incinerator
7. Crewmembers that are responsible for operating the OWS and Incinerator
should review the necessary procedures to operate the machinery in
accordance with maker's instructions
8. Crewmembers should be familiar with the vessel's environmental policies
& procedures
9. The Bilge Holding Tank should be sounded to ensure that the ORB is
accurate
10. The ORB and GRB should be reviewed to ensure that all entries are
truthful and in compliance with MARPOL requirements
Environmental Compliance Plan

- ECP -
Thank you for your attention…
An Overview of MARPOL and

other Legal Requirements for the
Protection of the Environment
© 2015 | COLUMBIA Shipmanagement | Prepared by: Alpha Marine Consulting Ltd. | Revision C | September 2015.
Sections
1 • Introduction
2 • MARPOL ANNEX I - Prevention of Pollution by Oil
3 • MARPOL ANNEX II - Prevention of Pollution by Noxious Liquid Substances
4 • MARPOL ANNEX IV - Prevention of Pollution by Sewage from Ships
5 • MARPOL ANNEX V - Prevention of Pollution by Garbage from Ships
6 • MARPOL ANNEX VI - Prevention of Air Pollution from Ships
7 • Ballast Water Management
8 • Bio-Fouling Management
© 2015 | COLUMBIA Shipmanagement | Prepared by: Alpha Marine Consulting Ltd. | Revision C | September 2015.
Introduction
© 2015 | COLUMBIA Shipmanagement | Prepared by: Alpha Marine Consulting Ltd. 3 of 74 | Revision C | September 2015.
Some History About MARPOL Implementation
Accident of Torrey Canyon 1967

• 1959 US built, 60,000 dwt
• Jumboized to 120,000 dwt
• Cargo 120,000 ts of BP oil for Milford
Haven
• Navigational error caused grounding
ripping open 6 tanks
• 31,000,000 gallons (about 118,000 cubic
meters) of oil leaked
• Oil spread along the sea between
England and France
Some History About MARPOL Implementation
Accident of Amoco Cadiz 1978

• 1974 built, carrying 227,000 tonnes of
crude oil
• Ran aground off the coast of Brittany,
France on March 16, 1978
• The whole cargo spilled out as the
breakers spilt the vessel in two,
progressively polluting 360 km of
shoreline
• At the time this was the largest oil spill
by tanker ever registered.
MARPOL Implementation Phases
Adoption of Environmental Regulations Adoption of MARPOL Convention

1954 OILPOL Convention
• Annex I and II - 1983
• Operational Requirements • Annex III – 1992
• Discharge zones (50nm and • Annex V – 1988
100ppm) • Annex IV – 2003
• Reception facilities • Annex VI - 2005
Jut for Oil… Not Just for Oil…

Just for Oil…
General
• The scope of the present training session is to provide
a proactive approach to environmental management
that includes identification of sources of marine &
atmospheric pollution and measures for the reduction
of their impacts.
• CSM is voluntarily committed in continually improving

its environmental performance by adopting an
Jut for Oil…
Environmental Management System (EMS) by which all
environmental aspects of its activities are identified,
addressed, monitored and controlled.
MARPOL ANNEX I
Prevention of Pollution by Oil
2
MARPOL ANNEX I
Prevention of Pollution by Oil
2
This section describes
• The arrangements and procedures for handling

oily bilge water in the E/R and in cargo space areas
(including slops).
• The arrangements and procedures for handling oil
residues (sludge).
• The requirements for discharge within and outside
of special areas, as per Annex I of MARPOL.
Oil Pollution Prevention - Definitions

Oily Bilge Water: water which may be contaminated by oil resulting from leakage or
maintenance work in machinery spaces. Any liquid entering the bilge system including
bilge wells, bilge piping, tank top or bilge holding tanks is considered oily bilge water.
Oily Bilge Water Holding Tank: tank collecting oily bilge water prior to its discharge,
transfer or disposal.
Oil Residue (Sludge): the residual waste oil products generated during the normal
operation of ship such as those resulting from the purification of FO or LO for
machineries, waste oil from oil filtering equipment, waste hydraulic and lubricating oil
etc.
Oil Residue (Sludge) Tank: tank which holds oil residue (sludge) from which sludge
may be disposed ashore through the standard discharge connection or any other
approved means for disposal.
Handling of Oil and Oily Mixtures
Any discharge overboard of bilge water Any discharging of oil residue

shall be in accordance with MARPOL (sludge) to reception facilities
Annex I. Bilge water from E/R bilges ashore, must be done directly from
must be transferred to the bilge the oil residue (sludge) tank(s),
holding tank and thereafter can be through the standard discharge
discharged overboard via the OWS. connection.
Oil residue (sludge) shall be transferred

to the oil residue (sludge) tank for later Piping to and from oil residue
disposal, either through discharging to (sludge) tanks shall have no direct
reception facilities or by burning in the connection overboard, other than
Incinerator the standard discharge connection.
© 2015 | COLUMBIA Shipmanagement | Prepared by: Alpha Marine Consulting Ltd. 11 of 74

Oily Water Separator

The OWS is of vital importance for the oil pollution prevention.
Persons responsible for its use must be trained and shall ensure that
the oily water mixtures and all residues are separated effectively
and any discharge is within the limits set by MARPOL Annex I.
Oil Content Meter

• The quality of the effluent after its filtration in the Oil
Water Separator is checked by the Oil Content Meter
• The OCM is a separate instrument installed downstream
of the Oil Water Separator in order to monitor the
concentration of the oil in the filtered effluent
• The OCM must be Class approved
• The OCM shall be maintained and calibrated in
accordance with the manufacturer’s instructions.
Discharge of Oil and Oily Mixtures

Discharge of oily bilge water to sea through the OWS is allowed when:
• The ship is proceeding en route; this broadly means the vessel to proceed to its
intended destination (next port), self-propelled and at a minimum speed capable in
producing wake.
• Discharge is taking place during day time only and under the supervision of the C/E.
• The oil content of the undiluted effluent does not exceed 15ppm.
• The oily bilge water is processed through the OWS, provided with alarm and a
stoppage device to ensure that the discharge automatically stops when the oil
content exceeds 15ppm.
The oily bilge water to be discharged via the OWS must not
originate from cargo pump-room bilges (applicable for tankers)
The oily bilge water to be discharged via the OWS must not be
mixed with oil cargo residues (applicable for tankers)
Discharge of Oil and Oily Mixtures
In the Antarctic Sea, any discharge into the sea of

oil or oily mixtures from any ship is prohibited.
Any discharge may also be prohibited and in other
areas worldwide, depending on local regulations
It is prohibited:
• Uncontrolled discharge of oil and oil residues to
the sea
• Discharge of oil, oil residues and oily water
through bypassing of the OWS / OCM / ODME
equipment (as applicable)
Procedures for discharge of oil and oily

mixtures into the sea
Characteristic photos of illegal discharges:
Bilge main cross connections
The following are strictly prohibited:

• The use of active cross connections between the
bilge suction piping from E/R bilge wells/bilge tanks
and the suction of E/R pumps, other than the
dedicated bilge pump.
• Connection of the bilge suction piping to the fire,
general service, sea water cooling and ballast
pumps via existing permanent piping and valves or
via temporary hose connections.
Slop Handling
Slops which result from any Discharging of slops at sea to be carried when:
ballast or cargo operation, tank • ODME and control system is operational
cleaning, line washing or flushing and in use, and slop tank arrangement is
etc., must not be directly available
discharged to the sea, but
retained in the slop tanks for at • Vessel is NOT in a special area, as per
least the required settling period. MARPOL Annex I
• Vessel is ≥ 50 nm from the nearest land /
baseline as defined by MARPOL
• Vessel is en route
Settled water to be discharged • The instantaneous rate of discharge of oil
via the ODME, while manually content does NOT exceed 30 liters per
controlling the slop tank content nm.
using the Oily Interface Meter.
• Total quantity of oil discharge into the sea
must NOT exceed 1/30000 of the total
quantity of the particular cargo of which
the residue formed a part
Slop Handling
Special Areas under MARPOL Annex I

Date of Entry into
Special Areas Adopted In Effect From
Force
Mediterranean Sea 2 Nov 1973 2 Oct 1983 2 Oct 1983
Baltic Sea 2 Nov 1973 2 Oct 1983 2 Oct 1983
Black Sea 2 Nov 1973 2 Oct 1983 2 Oct 1983
Red Sea 2 Nov 1973 2 Oct 1983 -
"Gulfs" area 2 Nov 1973 2 Oct 1983 1 Aug 2008
Gulf of Aden 1 Dec 1987 1 Apr 1989 -
Antarctic area 16 Nov 1990 17 Mar 1992 17 Mar 1992
North West European
25 Sept 1997 1 Feb 1999 1 Aug 1999
Waters
Oman area of the Arabian
15 Oct 2004 1 Jan 2007 -
Sea
Southern South African
13 Oct 2006 1 Mar 2008 1 Aug 2008
waters
Oil Record Book

ORB: A valuable means of providing proof that the vessel fully complies
with MARPOL Annex I
Signed by the Officer

All entries must always be
responsible for the operation
written by ink pen
and countersigned by the C/E
Each completed page signed Any errors must be ruled out

by the Master by a single line
“Read carefully before Corrective fluid, double

you sign anything” writing is prohibited
Copies of the ORB pages should be sent at the Office upon request
Oil Record Book

Special attention should be paid :
• to the recorded quantities of bilge water managed through the OWS,
the duration of operation and the OWS capacity according to the
manufacturer’s specification.
• to the recorded quantities of sludge managed through the
Incinerator, the duration of operation and the Incinerator’s capacity
as per makers’ specification
• to make an ORB entry of bunkering upon completion of the
operation. Quantity of bunkers or lubricants should be entered in
metric tons.
Falsifications of entries in the Oil Record Book are a violation of law.

Bilge alarm E/R bilge alarms weekly tests for manned E/R operation &
Test records DAILY when operating in UMS mode
Bilge & sludge

receipts Whenever bilges & sludges are delivered to shore facilities
OCM/ODME Records of calibration / Calibration Certificates or Records

Calibration – for OCM’s cell renewal
or renewal records
• Extraordinary operations related to the bunker and E/R

FO & LO tanks
Engine logbook
• Unintended/accidental release of water, FO & LO from
E/R machinery
Weekly records of E/R waste oil, sludge & bilge tank

Tank Sounding Log retained quantities in ORB - enhanced by twice per day
measurements and record keeping as per CSM procedures
Details of all bunker / LO loading

ORB (part I) and E/R handling operations of oil
and oily mixtures
Details of cargo, ballast, STS operations,

ORB (part II)
tank cleaning, E/R bilge transfer to
slop/cargo tank operations, slop handling
and discharging
Management of Bilge
Applicable Regulations:
Bilge Water
- MARPOL, Annex I
- Vessel General Permit (VGP) – In the USA no
discharge of treated water shall be made within
Collect bilge water in bilge tank 12 nm from shore.
- Any local stricter regulations shall supersede
the provisions of this flowchart (e.g. no
discharge of treated or untreated bilge water in
Antarctic)
Is the vessel Treatment of bilge water by

NO YES
- No discharges of treated water at sea outside port the Oily Water Separator /
- The bilge water retained at the bilge limits and Oil Content Meter
tank en-route?
Deliver to shore
facility
Are the parts

per million
(ppm) reading Bilge water re-directed
YES of the Oil to the bilge tank
NO
Content Meter
Discharge of treated water less than 15?
at sea (less than 15 ppm)
Management of Sludge
Sludge (Fuel Oil Sludge, Lube Oil Applicable Regulations

- MARPOL, Annex VI
Sludge, Used Lube Oil, Cooking - Incinerators installed after 01/01/2000
Oil, etc.) must be type approved and certified to
meet prescribed standards
- Sludge may be incinerated, when the ship
Collect Sludge in Waste Oil is not within port limits, harbours or
estuaries (MARPOL Annex VI)
(Sludge) Tank
- Any local stricter regulations shall
supersede the provisions of this flowchart
− Sludge burned in the Incinerator

− Remaining quantity of sludge Is the vessel
− Incinerator is not used
retained in the Waste Oil NO within port YES
− Sludge retained in the Waste Oil
(Sludge) tank or the Waste Oil limits, or
(Sludge) tank, or Waste Oil
Incinerator tank harbours?
Incinerator tank
− Oily Waste burned in the
Incinerator
Deliver to a shore facility
Oily Waste that can be burned In the

Incinerator (e.g. Oily Rags, etc.)
MARPOL ANNEX II
Prevention of Pollution by Noxious
Liquid Substances
3
Noxious Liquid Substances - NLS

If discharged into the
sea from tank cleaning • Major hazard to marine resources and
Category X
or de-ballasting human health
• Hazard to marine resources and human
Category Y
health
• Minor hazard to marine resources and
Category Z
human health
Other • No harm to marine resources or human
Substances health
• Before any prewash or discharge procedure, relevant tank shall be emptied to the
maximum extent (according to applicable stripping requirements).
• The carriage of substances, which have not been categorized and are contained in
residues, shall be prohibited along with any consequential discharge of such
substances into the sea.
NLS - Discharge provisions

• The ship is en route at a speed ≥ 7 kn (for self-
propelled ships)
• The discharge is made at a distance ≥ 12 nm
For ships constructed
from the nearest land / baseline, as defined by before 1/1/2007 the
MARPOL, and in a depth ≥ 25m discharge into the sea
of residues of
• Discharge is made below the waterline through substances in Category
the underwater discharge outlet(s) Z below the waterline
is not mandatory.
• In Antarctic Sea, as well as in other areas as per
local regulations, any discharge into the sea of
noxious liquid substances or mixtures containing
such substances is prohibited
De-ballasting from a cargo tank which is used for NLS

cargo is also subject to above provisions
Procedures & Arrangements (P&A) Manual

 Each ship is provided with a ship-specific PROCEDURES & ARRANGEMENTS
Manual (P&A) describing all physical arrangements and operational procedures
related to ship’s cargo operations with respect to cargo handling, tank cleaning,
slops handling, residue discharging, ballasting and de-ballasting, which must
be followed in order to comply with the requirements of MARPOL Annex II.
 P&A Manual, together with the following documents:

• Cargo Record Book;
• Noxious Liquid Substances Certificate (as per MARPOL) OR International Certificate
of Fitness (as per IBC Code), as applicable, depending on the cargo category;
will be used in order to ensure compliance with the requirements of MARPOL
Annex II.
Approval of the P&A Manual by the

Flag or Class is mandatory
Points to remember from Annex II Reg.13:
Category X Substances:
 After the unloading of a Category X substance, the relevant tank shall be

prewashed before the ship leaves the port of unloading. The resulting
residues shall be discharged to a reception facility until the concentration
of the substance in the effluent to such facility is at or below 0.1% by
weight. When the required concentration level has been achieved,
remaining tank washings shall continue to be discharged to the reception
facility until the tank is empty.
 Any water subsequently introduced into the tank may be discharged into
the sea in accordance with the discharge standards mentioned before
Categories Y and Z Substances:
 With respect to the residue discharge procedures for substances in

Category Y or Z the discharge standards, previously displayed shall apply
(prewash is not always necessary)
 Especially for High-Viscosity or Solidifying Substances in Category Y the

following shall also apply:
• The residue/water mixture generated during the prewash shall be

discharged to a reception facility until the tank is empty; and
• Any water subsequently introduced into the tank may be discharged
into the sea in accordance with the above mentioned discharge
standards

Whenever a nominated cargo is a chemical
Handling of Chemical Cargoes cargo, the Master should verify whether it
is included in the list of substances that the
vessel is certified to carry.
Information regarding the Chemical Cargoes to be carried should be available

on board and include a cargo stowage plan indicating all cargoes on board,
including for each dangerous chemical to be carried:
• A full description of the physical and chemical properties, including
reactivity, necessary for the safe containment of the cargo
• Action to be taken in the event of oil spill
• Countermeasures against accidental personal contact
• Fire fighting procedures and fire fighting media
• Procedures for cargo transfer, tank cleaning, gas freeing and ballasting
MARPOL ANNEX IV
Prevention of Pollution by Sewage
Sewage Discharge
Sewage refers to
Drainage and other wastes from

Requirements for sewage
any form of toilets and urinals
discharge
Drainage from medical premises According to some National

(dispensary, sick bay, etc.) via requirements, the discharge of
wash basins, wash tubs and sewage is not allowed when
scuppers located in such premises
the ship is in their ports or
within their territorial waters.
Drainage from spaces containing In this case, National and Local
living animals regulations shall be followed,
superseding MARPOL Annex
Other waste waters when mixed IV restrictions.
with the drainages defined above
Sewage Discharge
Sewage status From an approved Comminuted and Not comminuted or
STP disinfected from a disinfected from a
holding tank holding tank
Distance from No restrictions 3 miles 12 miles
land
Ship’s speed No restrictions ≥ 4 knots ≥ 4 knots
Comments The effluent shall Sewage stored in Sewage stored in
not produce visible holding tanks shall holding tanks shall not
floating solids nor not be discharged be discharged
cause discoloration instantaneously but instantaneously but at a
of the surrounding at moderate rate moderate rate when
water when ship is en route the ship is en route
Sewage Discharge Rate

The maximum permissible discharge rate of untreated sewage is 1/200,000
(or one 200,000th part) of swept volume, calculated as follows:
where:
DRmax = 0.00926VDB
DRmax is the maximum permissible discharge rate (m3/h)
V is the ship’s average speed (knots) over the period
D is Draft (m)
B is Breadth (m)
SPEED (kt) 4 6 8 10 12
DRAFT (m)
5 4.63 6.94 9.26 11.57 13.89
6 5.56 8.33 11.11 13.89 16.67
7 6.48 9.72 12.96 16.20 19.45
8 7.41 11.11 14.82 18.52 22.22
9 8.33 12.50 16.67 20.83 25.00
Sewage Treatment Plant (STP) operation and

maintenance
 The STP must be operated and maintained according to maker’s instructions.

Records of maintenance/repair are to be maintained.
 In case the vessel is equipped with a sewage holding tank in lieu of the STP,
the former must be of sufficient capacity to hold the generated black and grey
water for the maximum time the vessel is normally expected to sail within the
limits where discharge is prohibited. The holding tank must have means to
indicate visually the amount of its contents.
 The holding tank must be equipped with a high level alarm and flushing line
or other equipment according to the requirements of the vessel’s Flag State.
Black Water (Sewage)

- MARPOL Annex IV
Deliver to shore facility, if no other means Sewage (black water) from - Any stricter local rules shall supersede
of processing or discharging is feasible toilets, urines and hospital the provisions of this flowchart
drains
YES
Is the vessel Has the vessel an
YES NO
within 12 nm approved Sewage
Vessels without Sewage Treatment
from nearest Treatment Plant
Plant must have a holding tank of
shore, or at according to
appropriate capacity
port, or at a regulations 9 and
Special Area, 10 of Annex IV of
or PSSA? MARPOL ?
NO
YES Is the vessel
within 12 nm
from the
Discharge of sewage nearest shore,
through the operating - Direct discharge of sewage (by-pass or at port, or at
Sewage Treatment Plant Sewage Treatment Plant) at the • No discharge of sewage. a Special Area?
approved discharge rate, and vessel • Use of the holding tank
speed of 4 knots or more
NO
- Recommended to continue using
Chain with lock at any direct
the Sewage Treatment Plant (for
sewage overboard discharge Chain with lock at the sewage Discharge of sewage at the
increased environmental protection,
valve, which by-passes overboard discharge valve approved discharge rate, and
and because interruption affects its
Sewage Treatment Plant vessel speed of 4 knots or more
readiness)
Grey Water
- Vessel General Permit (VGP)
Waste water from sinks, showers, laundry and - Port Regulations
galley (except used cooking oils) - Any local stricter rules shall
supersede the provisions of this
flowchart
Is the vessel Is the grey

NO within 1 nm NO water treated YES
from nearest through the Requirements for
Requirements for sewage
sewage
USA shore or at Sewage (black water)
(black water) apply
apply
any port, or Treatment
within a PSSA? Plant?
No restriction at the
discharge of grey water YES
Has the
vessel a grey YES Grey water held at the holding tank
water and discharged when outside 1 nm
holding tank from USA shore, or any port or PSSA
of
Good practice is to use appropriate
non-toxic detergents capacity?
Vessel personnel Discharge

Discharge
instructed to minimize Non-toxic detergents overboard reduced
overboard reduced
consumption of grey to be used grey water
grey water quantity
quantity
NO
water
MARPOL ANNEX V
Prevention of Pollution by Garbage
5
Garbage Pollution Prevention - Definition
Garbage means all kinds of victual, domestic and operational

waste, excluding fresh fish and parts thereof, generated during
the normal operation of the ship, and liable to be disposed of
continuously or periodically, except those substances which are
defined as per below restrictions.
General
100 GT and Above

Shall carry a Garbage
All ships
Certified to carry 15 Management Plan
or more persons
400 GT and Above

Shall carry a Garbage
All ships Record Book
Certified to carry 15
or more persons
Must permanently post a

12 meters or more in length overall
Placard for discharging
All ships Garbage and the Penalties
for failure to comply
Garbage discharge restrictions – 01/01/2013

Ships outside special Ships within special
Type of garbage
areas areas
Discharge permitted Discharge permitted
Food waste comminuted or ≥3 nm from the nearest ≥12 nm from the nearest
ground land, en route and as far land, en route and as far
as practicable as practicable
Discharge permitted
Food waste not comminuted or ≥12 nm from the nearest
Discharge prohibited
ground land, en route and as far
as practicable
Cargo residues not contained
in wash water
Discharge permitted
Discharge permitted
≥12 nm from the nearest
≥12 nm from the nearest
Cargo residues contained in land, en route and as far
land, en route, as far as
wash water as practicable
practicable and subject to
additional conditions

Ships outside special Ships within special
Type of garbage
areas areas
Discharge permitted
Cleaning agents and ≥12 nm from the nearest
additives contained in cargo land, en route, as far as
hold wash water practicable and subject
Discharge permitted to additional conditions
Cleaning agents and

additives in deck and
Discharge permitted
external surfaces wash
water
Carcasses of animals Discharge permitted
carried on board as cargo as far from the nearest
and which died during the land as possible and en
voyage route

Ships outside special
Type of garbage Ships within special areas
areas
All other garbage including

plastics, synthetic ropes,
fishing gear, plastic garbage
bags, incinerator ashes,
clinkers, cooking oil, floating Discharge prohibited Discharge prohibited
dunnage, lining and packing
materials, paper, rags, glass,
metal, bottles, crockery and
similar refuse
When garbage is mixed with or contaminated by other
substances prohibited from discharge or having different
Mixed garbage
discharge requirements, the more stringent requirements
shall apply
Special Areas under Annex V: Garbage

Date of Entry into
Special Areas Adopted # In Effect From
Force
Mediterranean Sea 2 Nov 1973 31 Dec 1988 1 May 2009
Baltic Sea 2 Nov 1973 31 Dec 1988 1 Oct 1989

Black Sea 2 Nov 1973 31 Dec 1988 -
Red Sea 2 Nov 1973 31 Dec 1988 -
"Gulfs" area 2 Nov 1973 31 Dec 1988 1 Aug 2008
North Sea 17 Oct 1989 18 Feb 1991 18 Feb 1991
Antarctic area (south of latitude

16 Nov 1990 17 Mar 1992 17 Mar 1992
60 degrees south)
Wider Caribbean region

including the Gulf of Mexico 4 Jul 1991 4 Apr 1993 1 May 2011
and the Caribbean Sea
Segregation Categories of Garbage

Segregation Categories Marking and Stenciling the containers
Plastics “Plastic” (Yellow)

Incinerator Ashes “Incinerator Ashes” (Black)
Food Waste “Food Waste” (Green)
Cooking Oil Labelled only
Rags Labelled only
Recyclable Garbage
• Glass “Glass” (Blue)
• Aluminium cans Aluminium cans (Grey)
• Paper, cardboard, corrugated board Labelled only
• Wood “Wood” (Brown)
• Metal “Metal” (Grey)
Hazardous Waste “Red”
Garbage collection drums

• Garbage must be kept in metal
containers
• The use of 205 litre steel barrels,
with purpose made lids, which
completely cover the top of the
container and have a lip of at least
2 to 3 centimetres, are considered
to be ideal
• The lid must also have the facility
to allow it to be effectively sealed
when closed with plastic seals
being available for this purpose.
MARPOL ANNEX VI
Prevention of Air Pollution
6
General
The purpose of these procedures is to ensure that vessels’
operations fully comply with the MARPOL Annex VI
requirements for Sulphur Oxides (SOx) emissions, as
enhanced by local / regional requirements, both inside and
outside Emission Control Areas.
Responsibilities
The C/E is responsible for the proper maintenance of main

engines and auxiliary machineries to improve their
performance and reduce air pollution.
NOx Emissions
All vessels with diesel engines installed onboard on or after 1/1/2000 with
power output more than 130kw have to comply with the NOx regulation
This regulation applies also on older engines, installed onboard prior to

1/1/2000 but which undergo a conversion of engine systems &
components that affect the engines NOx emissions, or increase the engine
MCR more than 10% after this date
• Requirements do not apply to engines installed on board

and used solely in case of an emergency (i.e. emergency
generator, lifeboat engines, etc.)
• Ozone production from NOx pollutants: Oxygen atoms
freed from nitrogen dioxide by the action of sunlight
attack oxygen molecules to make ozone. Nitric oxide can
combine with ozone to reform nitrogen dioxide, and the
cycle repeats.
Reduction of NOx emissions

Engine Certification and survey requirements
Engine Technical File: Contains the identification of all

originally installed components and settings which affect NOx
emissions
Engine International Air Pollution Prevention Certificate: Is a

statement of compliance supplemented by the Engine
Technical File
Air Pollution Prevention Certificate: It remains valid only if the

Engine compliance with NOx regulation is validated at every
IAPP survey
Reduction of NOx emissions

Engine Certification and survey requirements
To ensure engine’s compliance with NOx regulation, an inspection method is employed by Class
surveyors, based on checking the following:
• The EIAPP certificate is available for each engine.
• The Engine NOx emission affecting components, as detailed in the Technical File, are maintained in
good condition.
• Components replacement complies with the Technical File requirements and is recorded in the
“Record Book of Engine Parameters’’.
• The engine settings affecting NOx emissions are maintained within the limits detailed in the
Technical File; any adjustments are recorded in the “Record Book of Engine Parameters’’.
• Inspection of engine components included in the Technical File as per the “Onboard Verification
Procedure’’ attached to the Technical File.
Since the “Engine Parameter Check’’ is an indirect method, the following additional documents should
become available to the surveyor:
• Engine logbook parameter records (mainly exhaust gas temperatures, but also fuel, lube oil, cooling
water and charge air temperatures and pressures).
• Records/diagrams of compression and combustion pressures.
Maintaining the engines according to NOx

regulations
The C/E must ensure that:
• Operational parameters logged at regular intervals are
within the maker’s specified limits.
• Suitable components are used and their ID numbers
recorded in the “Record Book of Engine Parameters’’,
whenever a replacement of components is carried out.
• Whenever adjustments are carried out to engine settings,
these are within the specified range and recorded in the
“Record Book of Engine Parameters”.
SOx Emission Control Areas

The North Sea Area
The North American Area
The Baltic Sea Area
The US Caribbean Sea Area
Any other sea, including any port area, designated by the IMO
Regional restrictions for SOx
California State Emission Control

From 01 January 2015
(Air Resources Board) European Union and
• North America ECA
California waters and 24NM of the Turkish Ports
• US Caribbean ECA
California baseline
• Baltic ECA
• North Sea ECA
• Mandatory use of either MGO or MDO with

Sulphur limits below 0.1% to main propulsion
engines, auxiliary engines and boilers. • Vessel’s berthed and using
• HFO is not allowed to be used. Mandatory use of fuel Engines and Boilers for power
• oil with sulphur contentand steam production (not for
A fuel oil change over procedure from normal
to low sulphur fuel oil burning must be below 0.1%. maneuvering) must consume fuel
commenced enough time prior to entering the oil (HFO/MGO/MDO) with
ECA, to ensure that upon crossing the ECA sulphur content below 0.1%.
border the fuel oil system of M/E and/or D/G
has been fully flushed with the low sulphur fuel.
Maximum Permitted Sulphur Content of Fuel

Sulphur
Enforcement
limit Grade Operating area Reference
date
(% m/m)
Global limit
3.50 All grades Revised MARPOL Annex VI adopted by Res. MEPC. 176(58)
(since 01/01/2012)
EC territory and waters
0.10 MGO Directive 1999/32/EC as amended.
(since 01/01/2008)
CARB (mandatory use of either MGO or MDO with the set

MGO (DMA) California waters and 24 NM of
0.10 maximum sulphur limit to main propulsion diesel engines, auxiliary
MDO (DMB) the California baseline
diesel engines and boilers. HFO is not allowed to be used)
Already in force
EC & Turkish inland waterways
0.10 All grades and when berthed at EC & Directive 1999/32/EC as amended & Turkish Maritime Regulations
Turkish ports
North America ECA, US
Caribbean ECA,
0.10 All grades MARPOL Annex VI adopted by Res. MEPC. 176(58)
Baltic ECA, North Sea ECA &
English Channel
When berthed at Hong Kong
0.50 All grades Hong Kong Legislative Council Rule
Port
1 January 2020 0.50 All grades Global limit Revised MARPOL Annex VI adopted by Res. MEPC. 176(58)
Control of Volatile Organic Compounds

Vessels carrying crude oil and trading in terminals at which VOCs’ emissions are to be
regulated must be provided with a Volatile Organic Compounds Management Plan.
Control of Vapour emissions

Vessels undergoing closed operations in terminals, at which vapour emissions are to be
controlled, must be provided with:
• A Vapour Emission Control System (VECS), approved by the Administration.
• A Vapour Emission Control Manual, which covers all necessary procedures, including
crew training requirements.
 All cargo discharge, COW and cargo tank ballasting operations must prevent
the emission of hydrocarbon vapours to atmosphere
 This can be effected by retaining onboard or sending to the shore facility the
displaced vapour
 The Master should request in writing that the terminals provide reception of
vapour facilities
Control of Vapour Emissions

Emergency: In the event of any problems arising from an emission free operation, then
all operations should be stopped and pressure released to atmosphere if required.
Gauging and Sampling: Availability of gauging and sampling points through vapour lock
enables these operations to be carried out without releasing the tank pressure.
Funnel Smoke: The discharge of black smoke from the funnel should be avoided
Inert Gas: The IG plant must be operated as per maker’s instructions
Crude Oil Washing: COW should generally be conducted during cargo discharge
operation
Control of Incineration Emissions

Incineration of the following substances is prohibited:
• Cargo residues of crude oil and oil like substance cargoes,
chemical cargoes included in Chapter 17 of the IBC Code.
• Polychlorinated biphenyls (PCBs), which are mainly liquid
substances used as coolants and lubricators in electrical
apparatus like transformers.
• Garbage when containing more than traces of heavy metal.
• Refined petroleum products containing halogen compounds.
• Polyvinyl Chlorides (PVCs) unless the Incinerator is IMO type
approved for burning these substances.
• Cargo residues of harmful substances (IMDG code) and NLS
Control of Shipboard Refrigerants Emissions

During installation, maintenance and final disposal of equipment
containing refrigerants, those containing Ozone Depleting Substances
(ODS) are controlled by MARPOL Annex VI; in this context, the deliberate
emission of the following substances to the air is strictly prohibited:
• Chlorofluorocarbons (CFC)
• Halon
• Carbon tetrachloride, Methyl chloroform
• Hydrobromofluorocarbons (HBFCs)
• Hydrochlorofluorocarbons (HCFCS) (R22, R141b)
• Methyl Bromide
• Bromochloromethane (BCM)

Refrigerants are categorized as follows with respect
to their contribution on Ozone Depletion:
Category 1 / Prohibited in new installations from

19/5/1995:
Halon, R11, R12, R13, R111, R112, R113, R114,
R115, R211, R212, R213, R214, R215, R216, R217.
Category 2 / Prohibited in new installations from

1/1/2020:
R21, R22, R31,R121 to R124, R131 to R133, R141
to R142
R151, R221 to R226, R231 to R235, R241 to R244,
R251 to R253, R261 to R262, R271 How an ODS, such as the CFCs,
destroys the Ozone
Category 3 / No restriction apply:
R290, R134a, R32, R404a, R407a, R407b, R407c,
R410a, R413, R417, R507, R600, R717, CO2.

As per the CSM’s practice, all refrigerants, regardless the category they belong, are
always handled, as well as the containing equipment, as ODS.
• Care must be taken to recover and reuse refrigerants by using a recovery unit,
together with an empty gas bottle which is supplied to all vessels.
• Recovery units are to be maintained in good working order at all times.
• Required spares have to be ordered via the Technical Superintendent.
• During operation, any loss of gas detected must
be registered in the Refrigerant Record Book • recharge, full or partial, of equip
(Form MSOF-6.1). ment containing refrigerants
• repair or maintenance of equipm
• Leaks must be repaired soonest and the loss of ent containing refrigerants
gas recorded. Leak test units are supplied. • discharge of refrigerants
to atmosphere (deliberate and
• Maintenance of the Air Conditioning and non-deliberate)
refrigerating plants is to be done in accordance • discharge of refrigerants
to reception facilities
with the manufacturer’s instructions, as
described in the PMS.
(Ref.: MSOPR-6.1)
Leak Detection Procedure

When any refrigerants is being used:
• A leak detection system appropriate to the applicable refrigerant is to be provided
to monitor the spaces into which the refrigerant could leak.
• An alarm is to be given in a permanently manned location when the concentration
of the refrigerant in the space exceeds a predetermined limit (approx. 1st alarm
level at 250ppm and 2nd alarm level at 500ppm for CFCs).
• Independently to the above leak monitoring system, and to reduce the possibility
of leaks occurring, periodic leak detection should be undertaken.
The following recommendations are considered acceptable for the periodicity of leak detection:
Charge Example of System Type Periodicity
< 3 kg Bottle cooler, walk-in chambers, split A/C units Yearly
3 ≤ 30 kg Control room A/C, small provision chambers Quarterly
30 ≤ 300 kg Cargo ship accommodation A/C, provision rooms Monthly
300 kg & over Cargo refrigeration plants, passenger ship A/C Weekly *
* interval may be extended depending on the number of leaks being found
Systems are to be arranged with suitable means of isolation so that maintenance, servicing or
repair work, may be undertaken without releasing the refrigerant charge into the atmosphere
Pump – Down Procedure
Pump down means that refrigerant in the refrigeration

system is collected temporarily in the condenser. Pump
down is required when:
• The refrigerant circuit needs repair
• The unit cooler is stopped for a prolonged period or
• It is moved to minimize the risk due to refrigerant
leakage.
CO2 Emissions
Carbon Dioxide (CO2)
• An inevitable product when we get energy from burning the carbon in fuel.
• Responsible for global warming and climate change.
• Directly proportional to the amount of energy released and disproportional
to the energy conversion efficiency.
Increased Energy Less CO2 emissions

efficiency
EEDI Shipyard
IMO
MBMs SEEMP
Initiatives
Markets and Traders?
EEOI Ship owner/operator
EEDI and SEEMP mandatory from 1/1/2013

EEOI voluntary - MBMs are currently under discussion
CO2 emissions – EEDI – EEOI

Energy Efficiency Design Index (EEDI) Energy Efficiency Operation Index (EEOI):
Applicability:
• Vessels of > 400 GT • EEOI is an approach to assess the
• Building contract placed on/after 1 efficiency of a ship with respect to
CO2 emissions.
January 2013
• In the absence of contract, keel laid EEOI = Environmental Cost / Benefit to
after 1/7/2013 or the delivery of Society
which is on/after 1/7/2015; or in (measured as grams CO2 / tonnes x
cases of a major conversion of a new nautical mile)
or existing ship, on / after 1/1/2013
• NOT applicable to vessels sailing • EEOI = (Emitted CO2)/(Transport
entirely within flag state waters Work), i.e. the ratio of mass of CO2
(M) emitted per unit of transport
• NOT applicable to vessels with work.
Diesel-Electric, Turbine or Hybrid
Propulsion
CO2 Emissions – SEEMP

(Ship Energy Efficiency Management Plan)
SEEMP Applicability:
(according to Resolution MEPC.203(62))
• All vessels of > 400 GT

• Each vessel to be provided with a ship-
specific SEEMP not later than the first
intermediate or renewal survey
(whichever is first) on or after 1
January 2013.
• The attending Class surveyor will check
that the SEEMP is onboard and
subsequently issue the International
Energy Efficiency Certificate (IEEC).
Ballast Water Management
Ballast Water Management Plan

Every ship should be provided with a Ballast Water Management Plan
(BWMP) to assist in the minimization of transfer of harmful aquatic
organisms and pathogens.
BWMP should be ship-specific and approved by the Flag.
1. The uptake of ballast water should be minimized or,

• In darkness when bottom
where practicable, avoided in areas and situations
dwelling organisms may rise
such as: up in the water column;
2. Where practicable, routine cleaning of the ballast • In very shallow water; or
tank to remove sediments to be carried out in mid • Where propellers may stir
ocean or under controlled arrangements in port or up sediment
dry dock, in accordance with the ship's Ballast Water
Management Plan.
3. If it is necessary to take on and discharge ballast
water in the port to facilitate cargo operations, avoid
unnecessary discharge of ballast water that has been
taken up in another port.
Ballast Water Management Plan

Ships with Ballast Water Treatment Plant (BWTP)
In certain Ballast Water Exchange Areas (BWEA) and Ballast

Water Exchange Ports (BWEP) (USA, Arabian Gulf), vessels
The
fitted with a BWTP are not required to exchange their ballast
prior entry, since it is acceptable as a substitute for Ballast
Water Exchange.
However, the requirements for other BWEAs and BWEPs in the

event that the vessel has used the onboard BWTP are not clear
at the moment.
No BWE operation should
take place if the area/port
Therefore, Masters should verify the port’s position, via the
local agent of the port they are calling, well in advance, and accepts only ballast
take necessary actions. treated via BWTP.
Bio-fouling Management
Bio-Fouling Management Plan

BFMP provides effective procedures and practical guidance to the
vessel’s crew on bio-fouling management measures in order to minimize
the risk of transferring invasive aquatic species from ships' bio-fouling.
A Bio-fouling Record Book is maintained for each ship, in which the

details of all inspections and bio-fouling management measures
undertaken on the ships should be recorded .
The Bio-fouling record Book is to be informed in the following cases:

1. After each dry-docking
2. When the hull area, fittings, niches and voids below the waterline have been inspected by divers
3. When the hull area, fittings, niches and voids below the waterline have been cleaned by divers
4. When the internal seawater cooling systems have been inspected and cleaned or treated
5. For ships with a MGPS fitted
6. Periods of time when the ship was laid up / inactive for an extended period of time
7. Periods of time when the ship is operating outside its normal operating profile
8. Details of official inspection or review of ship bio-fouling risk (for ships trading internationally, if
applicable)
An overview of MARPOL and

other Legal requirements for
Thank you for your attention…
the Protection of the
Environment

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Alpha Marine Consulting Ltd.

Environmental Compliance Plan

Alpha Marine Consulting Ltd.

• Sewage Pollution Prevention • Guidelines

Alpha Marine Consulting Ltd.

Environmental Compliance Plan (ECP)

The purpose of the ECP is to introduce additional (over and above

Environmental Compliance Plan (ECP)

Alpha Marine Consulting Ltd.

Alpha Marine Consulting Ltd.

Alpha Marine Consulting Ltd.

Flexible hoses shall be stored in a secure location

ECP Audit Process

Alpha Marine Consulting Ltd.

Third Party Auditor (TPA)

As part of the ECP, the TPA, appointed by the US

Court Appointed Monitor (CAM)

TPA/CAM and auditing process

1st Year 2nd Year 3rd Year

TPA TPA TPA

Review by Review by Review by

Alpha Marine Consulting Ltd.

TPA and auditing process

The duties of the TPA

Vessel Audits, Office Audits and

• TPA reports are submitted to CSM, US Authorities and CAM

ECP Applicability and Duties

Alpha Marine Consulting Ltd.

CSM is committed to full compliance with the

• International Conventions (SOLAS, MARPOL, ISM, etc.);

The Company shall advise its personnel of its

A notice shall be posted at the gangway of each

Alpha Marine Consulting Ltd.

Duties of Environmental Compliance Manager (ECM)

Alpha Marine Consulting Ltd.

Duties of Chief Engineer

Framework of ECP Requirements

Alpha Marine Consulting Ltd.

Framework of ECP Requirements

Framework of ECP Requirements

Alpha Marine Consulting Ltd.

Environmental Tag System (ETS)

Environmental Tag System (ETS)

Each seal and its installation date & time shall be

Alpha Marine Consulting Ltd.

ETS - Where should the Seals be placed?

Alpha Marine Consulting Ltd.

Alpha Marine Consulting Ltd.

Acceptable reasons for breaking a seal:

• Routine Maintenance Works

Bilge/sludge shore connection blank flanges fitted with Seals

Alpha Marine Consulting Ltd.

ETS - Marking of the crossover valves

ETS - Marking of the crossover valves

• In the case of remotely operated valves from the Engine Control

Alpha Marine Consulting Ltd.

ETS - Emergency Bilge Suction Valve

Valves / wheels to be sealed

OWS overboard valve fitted with seals, marking and padlock