EMERGENCY RESPONSE PROCEDURES

POLLUTION

NOTES BY:
CAPT. PARVINDER SINGH
BHATIA

UPDATED: 20 APRIL 2021

 NOTES FOR REFERENCE
• Carrying groups I through V Petroleum oil:
• All oils increase in viscosity when the temperature decreases and vice versa.
• All lubricants consist of a base oil and normally lubricants consist of 90% base oil
and 10% additives. 
• The American Petroleum Institute’s (API) has categorized base oils into five groups
which are specified by the saturate level, sulfur level, and viscosity index. 
• Group I, II, and III are derived from crude oil (mineral oil).
• Group IV is a fully synthetic oil.
• Group V is for all base oils that are not included in one of the other groups. 
• API gravity:
• The API gravity or American Petroleum Institute gravity is a measure of how heavy
or light a petroleum liquid is compared to water.
• If its API gravity is greater than 10, it is lighter and floats on water. If less than 10, it
is heavier and sinks.
• The formula for API gravity is:
• API = 141.5/Specific gravity – 131.5.
• For API to be negative, the Specific Gravity should be more than 1.07.
 POLLUTION - INTRODUCTION
• Oil pollution incidents means an occurrence or series of occurrences having
the same origin, which results or may result in a discharge of oil and which
poses or may pose a threat to the marine environment, or to the coastline or
related interests of one or more states, and which requires emergency action
or other immediate response.
• Ship board emergencies reference Oil Pollution:
• 1. Cargo Tank overflow.
• 2. Pipeline/Hose leakage.
• 3. Bunker tank overflow.
• 4. Inter-tank Leakage.
• 5. Spills caused by Equipment in Machinery Spaces (Oily-water separating
equipment, Valves in pipes connecting ballast/ bilge systems, Cooling pipes in
oil cooler systems, Gearing of bow thrusters, Stern tubes, etc.
• 6. Spills Resulting From Casualties (Ship grounded / stranded, Fire/ Explosion,
Collision (with fixed or moving object), Hull Failure/Containment Failure, Ship
foundered/wrecked, etc).
• 7. Excessive List (during discharging/ loading operations, or bunkering).
 INTERNATIONAL CONVENTION REQUIREMENTS

• 1. Shipboard Oil Pollution Emergency Plan (SOPEP):

• 1. Regulation 37 of MARPOL Annex I requires that Oil Tankers of 150 gross tonnage
and above and all ships of 400 gross tonnage and above carry an approved
Shipboard Oil Pollution Emergency Plan (SOPEP).
• 2. Article 3 of the International Convention on Oil Pollution Preparedness, Response
and Co-operation, 1990 (OPRC 1990), also requires such a plan for certain ships.
• 2. Shipboard Marine Pollution Emergency Plan (SMPEP):
• 1. Regulation 17 of MARPOL Annex II makes similar stipulations that all ships of 150
gross tonnage and above carrying noxious liquid substances in bulk, carry an
approved Shipboard Marine Pollution Emergency Plan for noxious liquid substances.
• 2. Article 3 of the Protocol on Preparedness, Response and Co-operation to pollution
Incidents by Hazardous and Noxious Substances, 2000 (OPRC-HNS Protocol) Protocol
also requires such a plan.
• The latter may be combined with a SOPEP, since most of their contents are the same
and one combined plan on board is more practical than two separate ones in case of
an emergency.
• To make it clear that the plan is a combined one, it should be referred to as a
Shipboard Marine Pollution Emergency Plan (SMPEP).
 INTERNATIONAL CONVENTION REQUIREMENTS

• 3. Vessel Response Plan (VRP):

• Written exam - Q & A: Describe briefly about Vessel Response System as required under
OPA 90?
• Shortly after Exxon Valdez, spilled over 11 million gallons of Alaskan crude into the water of
Prince William Sound, in March 1989, the Congress voted to pass the Oil Pollution Act (OPA).
• In force since August 1990, OPA amended the Federal Water Pollution Control Act and
outlined how companies are required to prevent, respond to and pay for oil spills.
• It created a comprehensive prevention, response, liability, and compensation regime to deal
with vessel- and facility-caused oil pollution to U.S. navigable waters. A Vessel Response Plan
(VRP) is a document that outlines what the vessel will do in the case of an offshore spill.
• Not all vessels are required to have a VRP, but regardless of requirements, it’s a useful
document to have on board in the chance a spill occurs.
• The United States Coast Guard identifies ships that need VRP’s as Tank Vessels on which that
are “carrying groups I through IV petroleum oil as a primary cargo,” and Non-Tank Vessels
that are “carrying groups I through IV petroleum oil as fuel or cargo”.
• The VRP includes information about the vessel, (such as its name, country of registry, call
sign, and more), contact information for the vessel’s owner or operator, a list of zones that
the vessel intends to operate in, and the clear identification of the incident management
team – the people or group who is to be notified in the event of a spill.
• The Coast Guard has to review and approve your VRP before you can legally operate.
 INTERNATIONAL CONVENTION REQUIREMENTS

• The identification contact will include the identity of who is to be notified, how to
most efficiently reach them, and secondary communication effort instructions that
should be used if the first contact is unreachable.
• Additionally, the VRP will contain information about the vessel’s chosen Insurance
Company. VRPs are not limited to oil spills. “It is important to understand that
although hazardous conditions, such as an engine casualty, grounding, fire, or
flooding, may not directly result in a discharge, plan activation is still required
because, if left unresolved, they could result in a discharge.”
• GENERAL ACTION IN EVENT OF OIL SPILL:
• The Master’s accurate situation assessment and the importance of reaction time is
critical to initiating an effective response. The quicker you can contact those who will
help in the cleanup and claims-handling process, the faster you can mobilize necessary
resources helping both the environment and the vessel’s potential damage liability.
• Once it’s been established that everyone on board is safe and accounted for and out
of the unknown hot zone, then follow up with the established VRP and adhere to it as
closely as possible.
• Refer to your vessel response plan to find out who is to be notified in the event of a
spill — which agencies, both federal and local, insurance companies, etc and do so
immediately.
 Shipboard Oil Pollution Emergency Plan (SOPEP)-Details

• The Plan serves to promote a practiced response when ship’s personnel is faced
with an oil spill and must therefore be available in the working language used by
Master and ship’s Crew.
• Objectives: Plan’s primary purpose is to set in motion the needed actions to quickly
stop or minimize oil pollution. An effective plan ensures that “necessary actions are
taken in a structured, logical, safe and timely manner.
• The Primary objectives of the Plan are to:
• 1. Prevent oil pollution.
• 2. Stop or minimize oil outflow when a damage to the ship or its requirements occurs.
• 3. Stop or minimize oil outflow when a operational spill occurs.
• Sections and Appendices:
• 1. The action plan with duty of each crew member at the time of spill, including
emergency muster and actions.
• 2. General information about the ship and the owner of the ship.
• 3. Steps and procedure to contain the discharge of oil into the sea using SOPEP
equipments, in case of: operational spills, spills resulting from casualties, priority
actions, mitigating activities, transfer of bunker/lightening, damage stability and hull
stress calculation, general responsibilities of the Master and designated Officers or
Crew members.
 Shipboard Oil Pollution Emergency Plan (SOPEP)-Details

• 4. On board Reporting procedure and requirement in case of oil spill is described,

including: when to report actual or probable discharge, information required, who
to contact, including ship interest contacts (owners, ship managers, charterer,
insurance, P&I club etc).
• 5. Authorities ( Port state control, oil clean up team) to contact and reporting
requirements in case of oil spill are listed in SOPEP:
• a. Coastal state contacts, Port contacts and ship interest contacts.
• b. Oil Spill Response Organization (OSRO) Contract – Contract or document
evidencing an agreement between the Plan holder and the OSRO(s) for the types
spill response coverage needed in the Geographic Regions where the ship may
operate.
• c. Vessel Emergency Services / Salvage Contract – Contract or document
evidencing an agreement with a vessel emergency services provider or other
means for rendering all services to save the vessel and cargo from any marine peril
that could reasonably be expected to cause a discharge of oil into the marine
waters, and including actions necessary to control or stabilize the vessel or cargo.
• 6. General arrangement of ship is also listed in SOPEP, which includes location of
all the oil tanks with size, capacity, content, types of oil for each tank etc.
 Shipboard Oil Pollution Emergency Plan (SOPEP)-Details

• 7. SOPEP includes:
• a. Technical drawings of various fuel lines, along with other oil lines on board vessel with positioning
of vents, save all trays etc.
• b. Vessel diagrams indicating the general arrangement and location of each fuel and lube oil storage
tank and other features pertinent to an emergency response. The size, storage capacity, and type of
oil carried must be specified for each tank. Diagrams must be in a scale that is clearly legible for
review. A plan will not be approved without an adequate diagram. A single diagram may be submitted
for sister ships.
• 8. The location of the SOPEP locker and contents of the locker with a list of inventory (Oil Spill
dispersant, Sawdust, Rags, Absorbent pads, Oil kit bags, Scoops, Shovels, Brooms & brushes, Buckets,
Drums, Rubber suits/Boots/Gloves, Wilden pump with hoses, etc).
• 9. Each plan shall identify a Spill Management Team. If the plan holder contracts for this service,
documentation that the Spill Management Team acknowledges this capacity shall be included in the
plan.
• 10. Each plan shall identify a Qualified Individual, and any alternates, for the purpose of
implementing the plan. If the plan holder contracts for this service, documentation that the Qualified
Individual or company, and any identified alternates, acknowledge this capacity shall be included in
the plan.
• 11. Each plan shall provide the name, physical address and mail address, telephone number, email
addresses, and facsimile number of an Agent for service of process designated to receive legal
documents on behalf of the plan holder.
• 12. Each SOPEP must be considered in regard to ship’s variable: type and size of the ship, cargo, and
cargo’s properties. An effective plan that complies with MARPOL Convention must be prepared taking
into consideration ship’s particularities.
 Reporting and Action to control discharge

• In order to stop or minimize the discharge of oil and consequent effects, based
on the IMO guidelines (IMO, 2000), there are two types of steps of action
that shipboard personnel should follow in case of oil pollution emergency.
• 1. Action to control discharge.
• 2. Reporting.
• The first step after a probable or actual discharge of oil is the assessment of
the nature of incident. All the crew members are alerted, and the spill source
is identified and monitored. Top priority shall in all cases of casualty be put on
the safety of the persons onboard and to take actions to prevent escalation of
the incident. Immediate consideration should be given to protective measures
against fire, explosions and personnel exposure to toxic vapour.
• When the ship is involved in an incident which results in the discharge or
probable discharge of oil, the Master is obliged under the terms of MARPOL
73/ 78 to report details of the incident, without delay, to the nearest Coastal
State by means of the fastest telecommunication channels available. Coastal
States have to be informed, without delay, of any incident giving rise to oil
pollution, or threat of oil pollution, of the marine environment, as well as of
assistance and salvage measures, so that appropriate action may be taken.
 PROCEDURES/FOLLOW UP ACTIONS ON OIL SPILL

• GENERAL: Master to follow the company SMS procedures, often

described in a stand-alone document called the “Emergency
Procedures Manual”.
• 1. Sound the emergency alarm.
• 2. Initiate emergency shutdown, stop all transfer and bunkering
operations, close all valves and inform the barge or terminal.
• 3. Initiate the emergency response procedures.
• 4. Contact Harbour Authorities (on VHF if possible), ship’s agent, P & I
club correspondent, Owners/Managers, etc.,
• 5. If pollution of water occurs, then reporting, actions to control
discharge, steps to initiate external response must be followed
contained within the SOPEP/SMPEP/VRP.
• 6. Identify the source of spill or leak and initiate measures to stop or
minimize the overflow.
• 7. Drain or transfer the oil from affected area of the pipeline into empty
tanks taking into account stress and stability of the vessel at all times.
 PROCEDURES/FOLLOW UP ACTIONS ON OIL SPILL

• 8. If there is a possibility of release of flammable vapors or its entry to the

accommodation, engine room or cargo holds, ventilations to these areas must be shut
off.
• 9. Clean up operations must be started using the equipment available onboard.
• 10. All spilled oil that is collected must be carefully stored onboard till it can safely be
disposed off.
• 11. No chemical or dispersant to be used if there is a possibility of them going into the
water unless prior permission has been obtained from the Port Authority.
• 12. Oil gone overboard should be contained so that it will not spread and oil
dispersants to be used after getting permission from local authorities.
• 13. After the spill has been completely brought under control, oil spilled overboard and
onboard ship has been removed and the cause of spill ascertained and corrective
actions taken, the vessel can resume operations.
• 14. The chances of recurrences must be completely eliminated before starting
operations.
• 15. Before resuming operations, permission from Port or Local Authorities must be
taken.
• 16. All incidents and corresponding actions to be recorded as it is required for further
litigation purposes.
 EMERGENCY PROCEDURES- BUNKERING
• Immediate actions:
• 1. Sound the emergency alarm.
• 2. Initiate emergency shutdown, stop all transfer and bunkering operations, close all valves
and inform the barge or terminal.
• 3. Inform the Master and initiate the emergency response procedures.
• 4. Contact Harbour Authorities (on VHF if possible), ship’s agent, P & I club correspondent,
Owners/Managers, etc.,
• 5. If pollution of water occurs, then reporting, actions to control discharge, steps to initiate
external response must be followed contained within the SOPEP/SMPEP/VRP.
• Follow up Actions:
• 1. Identify the source of spill or leak and initiate measures to stop or minimize the overflow.
• 2. Drain or transfer the oil from affected area of the pipeline into empty tanks taking into
account stress and stability of the vessel at all times.
• 3. If there is a possibility of release of flammable vapors or its entry to the accommodation,
engine room or cargo holds, ventilations to these areas must be shut off.
• 4. Stop any hot work on board, nearby vessels and quays.
• 5. Clean up operations must be started using the equipment available onboard.
• 6. Minimize the spread of the oil, taking all possible action to contain the spillage until shore
assistance arrives, but without using any dispersants for which approval had not previously
been obtained.
 EMERGENCY PROCEDURES- BUNKERING
• 7. Together with officers and crew, work closely with the local authorities in
the clean-up operation.
• 8. Oil gone overboard should be contained so that it will not spread and oil
dispersants to be used after getting permission from local authorities.
• 9. Attempt to establish the quantity of oil spilled.
• 10. Obtain samples of the oil from which the spillage came.
• 11. All spilled oil that is collected must be carefully stored onboard till it can
safely be disposed off.
• 12. All incidents and corresponding actions to be recorded as it is required
for further litigation purposes.
• 13. Establish the facts and (before investigators arrive, if possible), write a
full report of the occurrence, stating all efforts taken by the ships crew to
deal with the spillage.
• 14.After the spill has been completely brought under control, oil spilled
overboard and onboard ship has been removed and the cause of spill
ascertained and corrective actions taken, the vessel can resume bunkering
operation after permission from Port or Local authorities.
 ORALS- BUNKERING

• Q. What is Bunker convention?

• The Bunker Convention ensures adequate, prompt, and effective compensation for
damage caused by spills of oil, when carried as fuel in ships’ bunkers. The territorial
jurisdiction for damage compensation extends to territorial sea and exclusive
economic zones.
• Q. When did the Bunkers Convention 2001 (BC) enter into force?
• A. 21st November 2008.
• Is Bunker Convention ratified by India?
• The convention covers all Indian vessels regardless of their location and any foreign
vessels in Indian waters.
• Q. Who is required to obtain a BC certificate of insurance?
• A. The registered owner of a ship.
• Q. Who is liable under BC for pollution damage?
• A. Ship owner (including the registered owner, bareboat charterer, manager and
operator).
• Q. Which ships are required to have BC certificate of insurance (BC certificate)?
• A. All ships over 1000 gt registered in a State party or entering or leaving a port in the
territory of a State party.
 ORALS- BUNKERING

• Do tankers with CLC Certificates also need Bunkers Certificates?

• Yes.
• Do non self-propelled vessels such as barges and pontoons need Certificates?
• Yes if they have any hydrocarbon mineral oil on board.
• Q. What is the difference between a “BC blue card” and a “BC certificate”? 
• A. "BC blue card" is issued by an insurer evidencing that there is in place
insurance meeting the liability requirements of the Bunkers Convention. "BC
certificate" is issued by a State party attesting that such insurance is in force. A
ship over 1000 gt must have on board a "BC certificate" when flying the flag of a
State party or trade to a State party. Without a "BC blue card", States will not
issue a "BC certificate“.
• Q. Who is required to obtain a BC certificate of insurance?
• A. The registered owner of a ship.
• Q. If BC/CLC certificates are both required, which one will be used in an oil
spill? 
• A. This refers to tankers. It is believed that the BC certificate will only be used in
the extremely rare situation when the CLC does not apply, namely when the
tanker is unladen and with no residue of persistent oil cargo on board.
 ORALS- BUNKERING
• Q: If your vessel was on a time charter for 6 months, which party would be
responsible for purchasing bunker fuel ?
• A: The time Charterer.
• Q: What precautions would you take where the time charterer is buying
bunkers?
• A: I would check that he was ordering fuel of the correct specification. The
specification should have been agreed between the owners and charterers
and should be listed in the C/P.
• Q: What are the possible consequences of not having proper procedures
for bunkering operation?
•  A: 1. Harbour pollution.
• 2. Fine on the owners/operators.
• 3. Fine on Master.
• 4. Detention of ship.
• 5. An adverse effect on owner’s deductibles and standing with their P & I
club.
• 6. Loss of ISM certification.
 ORALS- BUNKERING
• Q: What precautions would you take when ordering bunkers to protect
the owners’ interests as far as bunker quality was concerned?
• A: In consultation with Chief Engineer, I would check the engine operation
manuals, and if on time charter, the bunker clause.
• I would order the bunkers specifying an approval fuel standard, e.g. ‘BSMA
100’ rather then specifying only a type and viscosity, e.g. ‘IFO 180’.
• I would have the C/E check that bunkers presented for loading match the
ship’s requirements and specification ordered.
• I would have the C/E make accurate tank sounding before commencing
bunkering in order to verify the amount delivered.
• I would have the C/E make a compatibility test to confirm that bunker
presented are compatible with fuel already on board and see that bunker
are loaded into empty tanks if possible and kept separate from the other
bunkers until any analysis had been completed.
• I would also see that the vessel is, so far as possible, maintained upright and
on even keel throughout the bunkering operation, and that samples of oil
loaded were taken at regular intervals at the manifold.
 ORALS- BUNKERING
• Q: What arrangements would you expect the Chief Engineer to make for taking
bunker sample?
• A: I would expect the C/E to take at least two samples during the bunkering.
• If the vessel carries onboard fuel test kit, the C/E should carry out an analysis and if
this indicate the fuel is unsuitable, a full analysis should be carried out at an
approved shore laboratory before the bunker are used.
• In any event, one sample should be retained on board until all bunkers loaded have
been burn without problem, while other should forwarded to an independent fuel
analysis service.
• Sample of oil loaded during bunkering should be sealed, dated and signed by the
Chief Engineer and supplier.
• Q: a. Which section in the ORB is specifically for recording bunkering operation?
• b. Where must Master’s signature appear in the ORB?
• c. For how long must an ORB be kept on board? 
• a. ORB Part-1, Section-H.
• b. At the end of each page.
• c. 3 years from last entry made.
 Evidence to be collected
• Description of the Incident:
• Date and exact time of pollution recorded on the bridge and in the engine room, vessel’s
local time and UTC.
• Type of pollution.
• Operation during which pollution occurred, e.g. bunkering, collision.
• Pollutant.
• Approximate amount spilled (in case of oil or chemical pollution).
• Vessel’s position/location.
• Courses (chart course, steered course, gyro and magnetic compass) at the time of the spill
– if pollution occurred at sea.
• Speed, propeller revolutions or propeller pitch of the vessel at the time of the spill – if
pollution occurred at sea.
• Any compass and/or radar bearings and distances to the coastline taken and recorded – if
pollution occurred at sea.
• Prevailing weather conditions (particularly wind direction and force) at the time of spill
(keep any weather records).
• Tide and current at the time of the spill.
• Draught of the vessel at the time of the spill.
 Evidence to be collected
• Other companies involved in the pollution – Bunker and other Suppliers:
• Name and contact details of the company.
• Names and contact details of the company’s personnel involved in the operation.
• Duties of the personnel involved in the operation.
• Name of bunker vessels/bunker barges.
• If the pollution was caused during bunkering:
• – whether any procedures had been agreed, e.g. commencement, rate of flow,
interruptions.
• – how communications were effected.
• Were there any difficulties in communicating, e.g. language, noise.
• Were there any difficulties as such with the operation.
• Property damaged by pollution:
• Description.
• Location.
• Extent of pollution.
 ORALS

• CLC BLUE CARD:

• The Owner of a Tanker registered in a Convention on Civil Liability for Oil Pollution Damage (CLC)
Contracting State (which carries more than 2,000 tonnes of persistent oil as cargo in bulk) is obliged
to maintain insurance to cover his CLC liabilities.
• This insurance is evidenced by a document known as a Blue Card.
• It is issued by the ship’s P&I insurer to the Flag State registry and they, in turn, issue a CLC
Certificate to the registered owner of the Tanker.
• CLC tankers must carry a CLC Certificate on board, attesting the insurance coverage.
• Effectively, this gives claimants a right of direct action against the insurer.
• Where a ship is registered in a State that is not party to the CLC Convention, the registered owner
can nominate a State that is party to the Convention to issue the certificate.
• Further, a “Blue Card” is issued by the P&I Club to provide evidence that there is insurance in
place that meets the liability requirements of a wide variety of conventions including:
the 1992 Civil Liability Convention, the Bunkers Convention and the Wreck Removal
Convention.
• SDR (Special Drawing Rights):
• SDRs are used by the IMF to make emergency loans and are used by developing nations to shore
up their currency reserves without the need to borrow at high-interest rates or run current account
surpluses at the detriment of economic growth.
• The value of the SDR is based on a basket of four currencies—the U.S. dollar, the euro, the
Japanese yen, and the British pound sterling.
 EMERGENCY CHECKLIST-POLLUTION
• (1) Stop Operations:
• Stop all cargo & bunkering operations.
• Stop all ballasting & de-ballasting operations.
• (2) Notify Everybody On Board:
• Notify Master.
• Making a post station announcement for Oil Spillage Decontamination.
• Notify everybody to prohibit using fire (smoking, fire in the galley, etc.)
• Muster Fire party.
• (3) Measures to Prevent Oil Overboard Discharge:
• Confirming complete closure of scuppers.
• Opening the emergency drain valve to cargo oil tanks (on Tankers).
• Use of materials for oil removal (oil absorbent, sawdust, etc.).
• (4) Initial Notification Report.
• (5) Confirming Conditions at the Scene:
• The source of oil spill. (If the oil flows out of damaged shell plates, the point of the damage.) 
• Type and quantity of oil outflow.
• The direction, speed and extent of the oil that has flowed outboard.
• Weather and sea conditions.
• Ship’s position, course and speed.
• The presence of casualties.
 EMERGENCY CHECKLIST-POLLUTION

• (6) Control the Discharge of Oil

• (7) Preparation of Necessary Documents: 
• A. Record in a time series.
• B. Take pictures of the process of oil removal.
• C. Weather, sea conditions, and tide (direction/speed).
• D. The source of oil spill.
• E. The direction, speed, extent and quantity of the oil that has flowed
outboard.
• F. Actions taken for oil removal and materials used for removal and their
quantity. 
• G. The addresses, reported items and reporting methods used.
• H. Name of oil spill disposal companies, time of arrival and details of their
work (including those of the terminal side).
• I. Matters instructed by National or Local authorities and details of the work
done according to such instruction.
• J. Ship’s position, course and speed.
• K. If possible, collect a sample of the oil to seal and keep it on board.