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ENVIRONMENTAL COMPLIANCE TRAINING

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 1
Course Objectives
Objective and Approach

The objective of this course is to ensure the proper understanding The approach towards this presentation should be as the
and knowledge of the environmental requirements, to initiate vehicle for all the facilitators and participants to lead and
discussion, to facilitate the exchange of ideas and experiences and participate receptively to an interactive and interesting training
to conclude to a common ground, belief and attitude from all the session that includes valuable information exchange and
participants regarding the Environmental Compliance. personal development and improvement.

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 2
Environmental Compliance
Training (ECT)
For Masters and all Engine Officers

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 3
What is ECT?
Environmental Compliance Training - Initial

A systematic and controlled way for ensuring that all seafarers


meet or exceed the minimum requirements of the Company’s
Environmental Management System (EMS) requirements.

It consists of 3 different basic modules:


 Environmental Compliance
 MARPOL and legal environmental requirements
 Handling of E/R Waste – ORB entries

This is module 1: Environmental Compliance Presentation

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 4
Training Agenda
1. Introduction
2. ‘I CARE’ and ECT
3. Background/History
4. Personal Conduct & Behavior
5. Communication Channels & Open
Reporting System
6. Engineering Requirements
7. Conclusion & Personal Commitment

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 5
1. Introduction

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 6
Why do we do this
training?
How do you think that this training would benefit you?
Why do we all devote time to it?
Why is it important for the Company and why for you?

To avoid similar cases in the future

To remember our values

To see where we stand

To discuss incidents and cases

To learn from past experience

To ensure continual improvement

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 7
Our mission
To keep our customers fully satisfied by managing and operating their
ships to the HIGHEST LEVELS OF QUALITY, SAFETY, ENVIRONMENTAL
FRIENDLINESS, ENERGY EFFICIENCY AND ECONOMY, in accordance
with their needs and expectations and in full compliance with
international and national legislation, as well as other industry
standards and guidelines, FULLY COMMITTED TO ZERO ACCIDENTS,
ZERO LOSSES, NO HARM TO THE ENVIRONMENT AND REDUCTION IN
PERMITTED EMISSIONS, and fully recognising the vital importance of
all our employees, ashore and onboard, in achieving this Mission.

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 8
EMS teams The EMS teams meet quarterly, under the leadership of the
Environmental & Energy Management Representative to:
• Discuss significant environmental aspects and areas of energy
use, relevant objectives, as well as the Environmental & Energy
An Environmental & Energy Management System (EMS) Team for the office Performance
and one for the fleet: • Monitor the results of the environmental programs and propose
corrective action if the targets are not achieved
 established and approved by the Top Management
• Evaluate of regulatory, customer or supplier feedback
 consist of representatives from various departments nominated by their • Assess new technologies available
Line Manager • Benchmark the environmental and energy performance across
 are led by the Environmental & Energy Management Representative the fleet and against the oil/marine industry as a whole (if
possible)
• Assess responsibilities and deadlines
The Company’s Environmental Compliance Manager is a permanent
member of both teams.
The EMS Teams will meet annually to review:
T a r g e t • Revision of the Environmental Aspects and Impacts due to a
change in the:
The EMS-Teams are making sure all significant environmental aspects as
• Activities, products or services provided;
well as the significant areas of energy use are taken into account when • Legal and other requirements.
establishing, implementing and maintaining the Environmental & Energy • Evaluation of the program results to determine whether to:
Management System (EMS). • Continue with the program;
• Propose corrective action if the targets are not being
met;
M i n u t e s
• Discontinue the program.
Minutes of these meetings and relevant presentations are circulated to all • Proposal of changes to the system to Management as
Company employees and have to be discussed during QIC Meetings necessary.
ashore, respectively HSE Meetings onboard.
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 9
ECM
TOP Environmental Compliance Manager

He shall have primary responsibility and authority for:


MANAGEMENT • Ensuring that the procedures and measures required by the EMS are established,
implemented and maintained
The Top Management of the Company is • Monitoring the environmental compliance and pollution prevention aspects of the
appointing and authorizing a Senior operation of each ship
Officer as the Environmental Compliance • Reporting to the Top Management on the implementation of the EMS, including
Manager (ECM), who irrespective of recommendations for improvement
other responsibilities is authorized to • Liaising with those onboard ships and any external parties on matters relating to the
ensure full implementation of the protection of the environment
Environmental Management System and • Ensuring that adequate training is provided to the employees ashore and onboard with
to report directly to the Top regards to the proper implementation of the EMS
Management. • Ensuring the promotion of awareness for the marine environmental protection
requirements throughout the Company
• Maintaining an Open Reporting System (ORS) and ensuring that crew members are
informed of the availability of such ORS prior to each term of employment.
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 10
Values
What are your personal values?

Commitment Trustworthiness Patience


Respect Solidarity Accountability
Integrity Altruism Sustainability
Honesty Generosity Family
Consciousness Consistency Diversity
Compassion Transparency Team working
Authenticity Equality Social Responsibility
Determination Excellence Passion
Loyalty Competence

Do these values drive your work also?

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 11
Discussion
• Are your personal values implemented on your work?

• Would you support your personal values even if your


choice isn’t popular and it puts you in the minority?

• Do you feel that if you did that you would endanger


your employment or be put in minority?

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 12
What are the Company values?

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 13
CSM values

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 14
Discussion
How do you feel about these values?

Can you remember examples where these values


apply?

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 15
‘I CARE’ & ECT

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 16
Does the ‘I CARE’ philosophy
relate to ECT?
What is the relevance of this philosophy to
environmental violations?

What are the values of the ‘I Care’ that


apply to the environmental Compliance?

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 17
COMMITMENT
I CARE PHILOSOPHY

How can commitment coincide with the


Environmental Compliance?

Are there ways to show your commitment to the


Environmental Compliance Requirements?

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 18
APPRECIATION
I CARE PHILOSOPHY

Can you think of personal actions that demonstrate


appreciation that can also be combined with the
Environmental Compliance Requirements?

Are these actions only addressed towards you or the


Company?

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 19
RESPONSIBILITY
I CARE PHILOSOPHY

Do you feel responsible regarding the Environmental


Compliance implementation?

How do you think you could demonstrate your feeling of


responsibility?

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 20
EVIDENCE
I CARE PHILOSOPHY

Do you think evidence is required when it comes to


the Environmental Compliance?

If yes, by what means and to whom should evidence


be addressed?

Is your personal attitude and actions part of the


evidence?

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 21
Personal Attitude

What is your personal attitude to the Environmental


Compliance?

Please discuss examples and cases that describe an


attitude experienced or witnessed that demonstrate
the previously discussed values.

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 22
Background / History

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 23
History
2012 2012 2013 2013 2014
‘10

KING EMERALD Incident CAPE MAAS Incident CAPE TAFT Incident ECP CAPE TROY Incident
NORDIC PASSAT Incident Probation 4 years

2017 2018 2024


‘10

End of probation I CARE Revised EC Training


period
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 24
History
Illegal discharges were made from KING EMERALD, CAPE
MAAS, NORDIC PASSAT, CAPE TAFT and CAPE TROY and Oil
Record book on the vessels were falsified in order to
conceal the illegal conduct

Several Chief Engineers and Engineering Officers and Engine


Ratings were involved in making intentional and illegal
discharges and deliberately falsifying the Oil Record Book

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 25
KING EMERALD
• Government’s investigation was initiated as a result

2012
of ship inspection on 7 May 2012.

• “Tricking” – The OCM sensor on the OWS was


“tricked” by flushing the sensor with fresh water.

• “Bypassing” – A “magic pipe” was fabricated and


utilised for bypassing the OWS and discharging oily
waste directly overboard.

• General Service and Fire Pumps were used for


discharging overboard oily bilge waters.

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 26
CAPE MAAS
• Government’s investigation was initiated as a result of ship

2012
inspection on 22 October 2012.

• OWS was operated with sampling line removed.

• “Tricking” – The OCM sensor on the OWS was “tricked” with fresh
water during overboard discharges.

• Oil Record Book contained numerous false entries.

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 27
NORDIC PASSAT
• Government’s investigation was initiated as a result of ship
inspection on 22 October 2012.

2012
• Portable pump was used for delivering oily bilge water from holding
tank to soot water system where from it was discharged overboard
via sewage system discharge piping.

• Oil Record Book entries of soundings in the Bilge Holding Tank were
false and fictitious.

• “Tricking” – The OCM sensor on the OWS was deliberately “tricked”


with fresh water during overboard discharges.

• Engine Room sludge was transferred to a Cargo Tank and this


transfer was not reported in Oil Record Books.
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 28
CAPE TAFT
• Internal investigation held on January 2013 revealed that the ship’s
Oily Water Separator had been used improperly.

2013
• Sample of overboard discharge was flushed with fresh water by the
crew and ship’s oil record book revealed 16 instances of falsified
information.

• CSM disclosed this violation to US authorities and this case was also
considered when decision regarding penalty and ECP was taken.

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 29
CAPE TROY
• OWS intermediate sensor was tampered on 18 November 2014.

2014 • OWS discharge sample was diluted during overboard discharge on


25 November 2014.

• Bilge water was transferred to Grey Water Tank on 1 December


2014.

• The environmental breach was not registered as an incident in the


US records.

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 30
Root Cause
The root cause of the incidents was the engineers’ willful
acts of misconduct in violation of Company policies as a
result of a combination of technical and operational
problems that were encountered prior to the incidents.

A failure of the ship command to manage those problems


in accordance with company procedures and regulations
appears to have contributed to the engineers’ decision to
attempt improper means of dealing with the problems.

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 31
Consequences
In order to avoid costly and endless trials with the United
States Government, a Plea Agreement was accepted by
the company

As a result, a 4-year probation, fines according to


Company’s financial capacity and implementation of an
Environmental Compliance Plan (ECP) to the whole
company, office and vessels were imposed

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 32
Personal Conduct
& Behaviour

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 33
Who drove over the speed
limit this weekend/today? Speed limit
%

Who texted or talked on the


phone while driving this Cell phone
%
weekend/today?

Who picked up a weight with


the wrong posture? Weight
%

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 34
Personal conduct
Do you think that your personal conduct
plays a role?

How can your behavior affect others?

Does it affect the Company?

There are two ways to influence human behavior:


You can manipulate it or you can inspire it
Simon Sinek (writer)

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 35
What would you do
in case…
A supplier offers you an expensive present

A superior officer asks you to violate


MARPOL

Someone asks you to share a Company’s


confidential information against a present
or a favour?

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 36
What would you
do with regard to…
Environmental Protection

Compliance with Regulations

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 37
Communication Channels & Open
Reporting System

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 38
Discussion
Do you think there are means to report any concern?

What are these means?

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 39
Communication Channels

Open Reporting Call, e-mail or SMS to the Third Party Hot Line
DPA or ECM or the Top
Report freely and even anonymously to the Company Raise the concern with the appointed
Management (TM)
any occurrences that are forming a violation of Third Party by sending an e-mail or
International and National Rules and Regulations, as calling the Hot Line
well as the Company’s Policy
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 40
Other Communication Channels

Safety Observation Near Miss Report HSE Meeting

"Unsafe Act or Unsafe Condition" and "Good or Safe Report unsafe acts and conditions Discuss issues relevant to Health, Safety,

Practice" may be completed anonymously and that form part of a Near Miss. Hygiene, Environment & Energy and Quality

placed into an easily identifiable collection box. and initiate actions for improvement

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 41
Other Communication Channels

Inform the Master Inform Head of Vessel Debrief


Department or
Discuss issues that occurred on the vessel
Superintendent
during your contract

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 42
ORS Familiarization

01 03 05
Crew members and shore Publications and Any concerns submitted will
staff are informed about organization-wide be investigated and prompt
ORS prior to each term of announcements issued on steps are to be taken to
employment at least a quarterly basis resolve them

02 04
Notices for the ORS are
Concerns can be submitted
posted in lounge spaces,
via free mail or toll-free
Bridge, ECR, common areas,
phone
etc.

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 43
Open Reporting
System

Through the ORS, any shore side and vessel employee may
report any concerns or issues of non-compliance with the EC,
MARPOL rules, any other regulations or the Company’s
Policies.

Freely & Anonymously

Hot Line: +800-19293949

E-mail: open-reporting@open-reporting.com

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 44
Direct Reporting to Top
Management
openreporting@csm-d.com
Send e-mail

DPA or ECM Contact Details


Call, e-mail or SMS-texting

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 45
Open Reporting Rules

Failure to notify grounds for disciplinary action, which may


lead to dismissal and/or criminal charges, subject to
applicable labour laws.

CSM prohibits retaliation against those who report non-


compliances

The DPA and the ECM shall be informed of each such Open
Report

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 46
Illegal Discharge of Fuel Oil
to Shore
• A few days before the occurrence, upon Chief Engineer order, the

2023 fitter fabricated a pipe connection of unconventional design. The


connection looked suspicious to him and he shared his suspicion
with some other ratings.

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 47
Illegal Discharge of Fuel Oil to Shore
Upon Chief Engineer Shortly after the vessel
order, the fitter fabricated was berthed, two tank
a pipe connection of trucks arrived and parked
unconventional design. close by the ship’s Consequences of the Incident:
The connection looked gangway. • An unidentified quantity of fuel oil was
suspicious to him and he illegally discharged from the ship to a
shared his suspicion with shore;
other crew members.
• Significant monetary losses for the
Charterers.
A hose was arranged On the ship, the hose was Potential Outcome:
from the top of the tank connected to the
truck running over the • Cancellation of the charter and
unconventional pipe
ship’s gangway and connection (fabricated by commercial losses;
upward to cross deck Fitter) that was bolted on • Damage to the Company's
No.4 (in way of bunker the top flange of the reputation;
manifold) to pass through bunker line filter unit • Withdrawal of a vessel(s) from the
the apparatus room after the original filter Company management;
manhole. cover was removed. • Criminal charges against the
The Chief Engineer and offenders.
Second Engineer jointly The Company has Zero tolerance for any forms of bribery or
with the shore personnel
controlled the discharge
corruption.
of fuel oil from the ship to
two trucks. Any violations or illegal activities will lead to administrative
measures and potential prosecution against the violators.

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 48
Matters which may be raised under
the ORS

A crime is being, or has been, Dishonesty, either verbally, written


committed, is suspected, or is or through intentionally Miscarriage of justice
likely to be committed maintaining official log books or
records inaccurately

Non-compliance with legislation Malpractice or unethical conduct


and/or Company procedures,
particularly in relation to health &
safety at work, protection of the
environment and energy efficiency

The environment has been, or is A breach, or likely breach, of any


likely to be, damaged legal obligation or regulatory
requirement

The deliberate concealment of


any of the above

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 49
Environmental regulations to be taken into consideration
 MARPOL ANNEX I - Prevention of Pollution by Oil
 MARPOL ANNEX II - Prevention of Pollution by Noxious Liquid Substances
 MARPOL ANNEX III - Prevention of Pollution by Harmful Substances
 MARPOL ANNEX IV - Prevention of Pollution by Sewage from Ships
 MARPOL ANNEX V - Prevention of Pollution by Garbage from Ships
 MARPOL ANNEX VI - Prevention of Air Pollution from Ships
 SEEMP – Ship Energy Efficiency Management System
 EU MRV – IMO DCS
 EEXI - CII
 VGP – Vessel General Permit
 BWM – Ballast Water Management
 BFMP – Biofouling Management Plan
 IHM – Inventory of Hazardous Materials, Hong Kong Convention, EU - SRR
 Other Port and Country environmental regulations
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 50
Notify - Report
If at any time, you know of, or suspect, any of the occurrences listed before, you must report the matter immediately to
the Company, so that actions can be applied to deal with it appropriately.

Failure to notify in these circumstances grounds for disciplinary action, which may lead to dismissal and/or criminal
charges, subject to applicable labour laws.

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 51
EC Declaration

Why do you think crew members must sign the


“Environmental Compliance Declaration” before joining
the vessel and upon completion of their contract?

What may be the consequences of failing to comply


with the policies and procedures mentioned in the
“Environmental Compliance Declaration” ?

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 52
Engineering Requirements

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 53
Environmental Seals – Tamper Securing
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 E/R & Shore Connections

the C/E Environmental Seal the C/O Environmental Seal


Log Book (CE-ESLB) for the OR Log Book (CO-ESLB) for the
Engine Department Deck Department

The seals that the Master hands over


must be crossed out on the
Environmental Seals - Vessel Tracking
Document (ES-VTD)

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 54
Seal Types

Old Type New Type

Plastic seal Sticker Steel

Is the primary type and intended for To be used where fitting of plastic seals is To be used on piping flanges with
impossible, such as:
general use of sealing piping flanges, • sealing pipe couplings of small diameter high temperature, where a plastic
that cannot have rings welded on
blank flanges, valve wheels, etc. •
seal would melt (e.g. the boiler blow
to seal closed the OCM and other electric
equipment down pipe)

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 55
Seals location
Where should the Seals be placed

Any overboard valves connected to


Piping connections, fittings, the ejectors situated in compartments such
OCM, and other control equipment as but not limited to steering gear,
of the OWS bow/stern thrusters, and compartments
such as the Bosun store forward, pump
System crossover and connection rooms etc.
valves where bilge systems tie into
ballast, general service and other
pumping or ejector systems, and Sludge and dirty oil tanks manholes in
systems capable of bilge removal engine room spaces and all attached
without the use of the OWS level, temperature and other removable
accessories fitted to them as far as
practically possible
Every blank or potentially removable
flange associated with any piping
leading overboard
On Tankers:
Blank flanges on the bilge, sludge and sewage transfer • MARPOL Annex I and II overboard discharge lines
system manifolds for transfer to shore reception to be • Entire piping system including flanges and valves
blanked and fully bolted when not is use. connected up to the ODME.

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 56
OWS & OCM
Tamper Securing
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.

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 57
Instructions of Seals use
Flange connections and blank flanges should be
A assigned a number based on the piping diagram.
This number should be entered in column ‘SEAL
POSITION’ of the CE-ESLB
A Number blank flanges

Affix seals so that the seal will be broken if bolt


B removed or if valve operated B Affix

Used Environmental Seals (all types), which have


been removed (or broken/damaged) must be C Used seals
C handed over to the Master by the C/E and the C/O
and be registered in the Used Seals Log.

D Worn seals
Worn seals which are lost in tanks or bilges and
D cannot be retrieved, must be reported to the Master
by the C/E and the C/O, and he will register relevant
comments in the Used Seals Log.

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 58
Breaking the seals

What are the reasons and


circumstances that allow
the breaking of seals?

Routine Maintenance Class / PSC Survey Requirements

Repair Works EC Auditing Process

Normal Discharge Emergencies

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 59
Master
Responsibilities
Maintains replacement seals in a secure location

Verifies that seals do not have duplicate numbers

Maintains the Environmental Seal Register (ESR)

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 ESR
and the ES-VTD to the new Master

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 60
Master Responsibilities
Environmental Seal
Register (ESR)

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 61
Master Responsibilities
Environmental Seals -
Vessel Tracking
Document (ES-VTD)

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 62
Master Responsibilities
Used Seals Log

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 63
Chief Engineer
Responsibilities
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

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 64
Chief Engineer Responsibilities
C/E Environmental Seal Log
Book (CE-ESLB)

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 65
Chief Officer
Responsibilities
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

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 66
Chief Officer Responsibilities
C/O Environmental Seal Log
Book (CE-ESLB)

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 67
Emergency Bilge
Suction Valve
• Bilge suction valves not connected to bilge
main & 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”

• Valve wheel to be sealed with


Environmental Seal, capable of breaking, in
case of emergency, testing or maintenance
– Use of seals to be logged

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 68
Cross Connection
Valve Marking
Use of cross connections and any
other system capable of pumping out
the bilge water and wastes, for any
reason other than emergency, is
prohibited!!!

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 69
OWS / OCM Testing
03

Pre-operational Test, for at least 15 Annual Test


minutes, via recirculation is required
prior any normal operation
02

Monthly operational tests of OWS & Monthly Test


OCM under actual operational
conditions (if possible) for 15 minutes
continuous processing of the
contents of the Bilge Holding Tank 01

Pre-operational Test

Annual operational test of the OWS & OCM for


at least 1 hour of continuous operation by the
C/E and any involved E/R personnel, in the
presence of a Technical Superintendent (TSI) or
a Third Party Auditor (TPA)

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 70
OWS / OCM Testing

Sequence of entries in the ORB


During operation or testing, set points of for testing prior discharging
any alarms related to oil content or through the OWS:
sample flow MUST NOT be modified
Code I: Test of OWS and OCM for 15 minutes via recirculation
WITHOUT COMPANY’S EXPRESS
Code I: Unsealing of the OWS Overboard valve
WRITTEN PERMISSION
Code D 13, 14, 15.1: OWS normal operation
Code I: Sealing of the OWS Overboard valve
Records of the tests shall be kept in the
ORB Code I: Above overboard discharge via OWS carried out as
monthly (annual) OWS test
A copy or a photograph of the E/R alarm
printout to be retained and appended in Entries must be made in the CE-ESLB and the used
the ORB page documenting the test seals must be handed over to the Master

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 71
Criteria of satisfactory OWS/OCM test

1. Absence of alarms (Long run alarm, Motor overload alarm, Oil


alarm, etc.)
2. Effluent and sample flow are continuous remain within
normal operational limits set by equipment manufacturers
3. System components function and operate within the
parameters and without abnormalities
4. Sample reading remains within the range and inconstant

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 72
Portable Pumps
 The pump to be secured with a chain lock and key to be
kept by the C/E
 The chain lock to be fitted with a seal and relevant entry
to be made in the C/E’s Environmental Seals Log Book
 The pump may only be used with the express
permission of the C/E
 Date, time and person who performed task to be
recorded in the E/R Logbook and in the ORB (if
applicable)
 Take photographs of the pump when in service, for
objective evidence of its use. Photos to be retained by
the C/E

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 73
Logs
What are the log that you should keep?

E/R Bilge & Sludge Tank


Sounding Log
• Maintained in the ECR for at least three (3) years
• Completed and signed by the officer or rating
who takes the soundings
• Twice per day at 08.00 and 17.00 hour

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 74
Logs
What are the log that you should keep?

Leakage Log MSOF-11.5

• Any time, a line or component on a fuel, lube or


waste oil system fails, including high pressure
lines on diesel engines
• A notation as to the quantity released and an
explanation on how the unintended released fluid
was handled
• Unintended releases of salt or fresh water,
condensate or cooling fluid shall be recorded

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 75
Logs
What are the log that you should keep?

Oil to Sea Interface Log


MSOF-10.4

• 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
• Log to be sent to ECM and TSI at the end of each month (even
if no entry is made)
• Accidental oil loss or water ingress must immediately be
reported to the ECM and TSI

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 76
Logs
What are the log that you should keep?

Fuel Oil and Lube Oil


Management Log MSOF-9.4

• The operation of all purifiers on a monthly basis


• Installation of hour meters on purifiers motor controllers
• Records for incidents involving poor quality fuels
• 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 for the handling of unburned oil residues
(sludge), oils, oily wastes and used filters

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 77
Environmental Compliance Assessment
When?
• On taking delivery of a new vessel under management
• jointly with attending TSI and/or MSI
• One month after embarking the vessel
• Prior arrival to any US port
• Latest four months after the previous assessment
• EC Assessments are also performed during TSI visits on board

Who performs the assessment?


• The Chief Engineer in his role as Environmental & Energy Officer

Who supports the Chief Engineer?


• Master
• Chief Officer
• Second Engineer

Whom to send the assessment (GOF-7.8)?


• TSI
• DPA
• ECM

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 78
Environmental Compliance Assessment; Guidance
• Complete and submit the Assessment using updated version of GOF-
07.8 in word format
• Refrain from trying to format or edit the content of the form.

• Do not try to remove the password protection

• Ensure that all items are answered truthfully and accurately


reflecting the actual status of the assessed subject
• Make sure that the “clarification field” for applicable items, shall not
be left blank

For every item marked “NO” ;


• Insert a comment in the relevant section

• Enter the respective requisition number required to be supplied

• Specify a target date for item requiring a rectification, in agreement


with the responsible TSI. Avoid using uncertain time in the future
such as “unknown”, “nearest future”, “next convenient port”

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 79
Personal Commitment

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 80
Personal
commitment
What is your personal commitment?

Please write down the action that you will be


committed to after this training (anonymously)

Try to include the reason why

Place the cards into the box/onto the desk

Each card will be then read out loud

At the end you will vote/clap for the most sincere


or ‘touching’ one

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 81
Personal
commitment
The best personal commitment note said:

…………………………………………………………………………………..

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 82
It is not about following blindly orders!
It is about believing in the true values!
It is about….
Personal Commitment

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 83
Thank you for your
attention

Any questions?

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 84

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