Professional Documents
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02 Csm_marpol and Other Legal Requirements_ Master Engineer 2024
02 Csm_marpol and Other Legal Requirements_ Master Engineer 2024
and
other legal requirements
for the
protection of the environment
© 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 This presentation should be considered as the
understanding and the knowledge of the vehicle for all the facilitators and participants to
environmental requirements and relevant regulations lead and participate receptively to an interactive
through presenting useful information, solving and interesting training session
exercises, answering questions and creating
discussions, in order to refresh the already acquired
knowledge relative to the protection of the
environment
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 2
MARPOL
and
other legal requirements
for the
protection of the environment
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 3
What is ECT?
Environmental Compliance Training - Initial
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 5
Section 1
MARPOL ANNEX I
Prevention of Pollution by Oil
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 6
MARPOL ANNEX I
Handling of Oil and Oily Mixtures
from Machinery Spaces
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 7
Definition of Oily Bilge Water - Oil Residue (Sludge)
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 8
Oil Pollution Prevention - Definitions
Oily Bilge Water
The 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
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 9
Tank Identification in IOPP Supplement
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 10
Sample of Tank Identification in IOPP Supplement
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 11
Handling of Oil and Oily Mixtures
Oily Bilge Water Oil Residues (sludge)
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 13
Oily Water Separator (OWS)
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 14
Oily Water Separator (OWS)
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 15
Discussion
Who are allowed to operate the OWS as
per MSOPR-11.2 ?
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 16
Discussion How can we ensure that there is no method to discharge bilges overboard by
by-passing the OWS?
By using Environmental Seals in:
Piping connections, fittings, the OCM, and other control equipment of the OWS
System crossover and connection valves where bilge systems tie into ballast, general
service and other pumping or ejector systems, and systems capable of bilge removal
without the use of the OWS
Every blank or potentially removable flange associated with any piping leading
overboard, such as but not limited to the following piping: bilge, sewage, grey water,
boiler blow down, cooling water, etc.
Any overboard valves connected to ejectors situated in compartments such as but not
limited to steering gear, bow/stern thrusters, and compartments such as the Bosun
store forward, pump rooms etc.
Sludge and dirty oil tanks manholes in engine room spaces and all attached level,
temperature and other removable accessories fitted to them as far as practically
possible
Portable pumps and flexible hoses
By allowing specific personnel to discharge bilges and supervise them
By enforcing the company’s environmental policy
By familiarizing the personnel with the consequences of the violations of MARPOL Annex I
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 17
Oil Content Monitor (OCM)
The OCM must be calibrated at intervals not exceeding 5 years after its
commissioning, or as specified in the manufacturer's instructions, whichever
is shorter as required by MEPC.285 (70) and Company’s instructions
Calibration certificates are issued every 5 years by an approved contractor
ashore and must be:
maintained on board
maintained ashore by the Technical Department
When a new calibrated and certified Measuring cell for the OCM is installed
on board by the vessels C/E or Service Engineers, details along with
the name of service engineer must be recorded in the ORB (Part-I, Code I) &
PMS (Refer to MSOPR-11.3)
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 19
Example of how an OWS with absorber works
1. Rough separation: An eccentric spiral pump
draws the mixture out of the bilge
2. Fine separation: A very open porous coalescer
causes, due to its oleophilic surface, fine
separation of even the smallest oil drops
3. The OCM takes samples and controls the use of
the absorber
4. Absorber bypass: If the OCM detects less than
14ppm the operation is done without the
absorber and cleaned water is guided outboards
5. Operation with absorber: If the OCM detects
more than 14ppm the water passes through the
absorber
• if after the extra cleaning the new
measurement < 15ppm, the cleaned water is
guided outboards
• if the OCM shows > 15ppm, the cleaned water
is guided back to the bilge water tank
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 20
Certificates Required On Board
IOPP (International Oil Pollution Prevention) Certificate and Supplement
Validity for 5 years after the completion of the specific initial
inspection
Intermediate inspection between 2nd and 3rd anniversary date* of the
certificate
Endorsed annually by the Classification Society of the vessel (with a
window of ±3 months from anniversary date* of the certificate)
Calibration of Oil Content Monitor (15 ppm Bilge Alarm): performed by
Manufacturer or service engineer authorised by the Manufacturer
Certificate of Type Approval for Oily Water Separator: Issued once by a
Recognised Organisation (RO) on behalf of the flag administration
Certificate of Type Approval for Oil Content Monitor (15 ppm Bilge
Alarm): Issued once by RO on behalf of the flag administration
*OWS and OCM approved by the administration are accepted by USCG and no separate USCG certification is required.
*Anniversary date means the day and month of each year which will correspond to the date of expiry of the certificate.
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 21
Discharge of Oil and Oily Mixtures
Name the conditions that must be satisfied to discharge of oily bilge water to sea:
MARPOL Annex 1 – Regulation 15
The ship is en route
The oil content is ≤ 15ppm
The oily mixture is processed through OWS, with alarm arrangements
and automatic stopping device when discharge in Special Areas
(Please refer to the IOPP Supplement item 2.2.2 to check if the
equipment can be used in Special Areas)
The oily mixture does not originate from cargo pump-room
bilges on oil tankers
The oily mixture in case of oil tankers, is not mixed with oil cargo residues
MARPOL does not set the limit on the distance to the shore for normal
operation of the OWS.
Local regulations must be observed in waters under jurisdiction of a coastal
State.
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 22
Discharge of Oil and Oily Mixtures
There are no differences, if the previous conditions are satisfied, with the
exemption of the Antarctic Sea and Arctic waters where any discharge of oily
mixtures is prohibited
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 23
Special Areas under MARPOL Annex I
Name as many Special Areas you can
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 24
Posting
General Practice for Documents Required to be Posted in the Vicinity of OWS:
Bilge Piping Diagram
Operation Instructions of the specific model of OWS
Emergency shut down procedure of the specific model of OWS
Areas where discharge is allowed/not allowed
CFR Poster – for vessels calling US ports
Calibration of Oil Content Monitor
Certificate of Type Approval for OWS
Certificate of Type Approval for OCM
Poster MSOPOST-11.1
It is the Best Practice to prepare affix a board to clearly and neatly post all required documents.
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 25
Discussion
What should you do in the case that the bilge water tanks are full
and the OWS is not working?
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 26
Discussion- possible reactions
Inform TSI and ECM in the first instance
Carry out Risk Assessment and Management of Change
Request for Flag Administration Dispensation Letter
Transfer the bilges to other tank(s), approved by the Class, for later disposal or
delivery to shore facilities
Transfer the bilges to Sludge Tank for later delivery to shore facilities
Transfer the bilges to deck/cargo tank for later disposal (in case of tankers)
Transfer to any non-IOPP tanks are not allowed without permission from the
Flag Administration
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 27
MARPOL ANNEX I
Handling of Oil and Oily Mixtures
from Cargo Spaces - Slops
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 28
Discharge of Slops
ODME and control system is operational and in use and slop tank
arrangement is available
En route
Distance from the nearest land ≥ 50 nm
NOT in a special area (as per MARPOL Annex I)
Instantaneous discharge rate of oil content does not exceed 30 liters per
nautical mile
Total quantity of oil discharge into the sea < 1/30.000 of the total
quantity of the particular cargo of which the residue formed a part
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 29
Bilge - Sludge - Slop
Management Record Keeping
Company’s Policy
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 30
Violation Consequences
What do you think that the violations of MARPOL Annex I may result in ?
heavy fines
and / or
imprisonment
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 31
Discussion
Why do you think that we must not pollute the marine environment?
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 32
Discussion – Possible answers
Because:
We destroy the environment
It is against Company’s Environmental Policy and values
It may result in heavy fines and / or imprisonment
We have been committed not to do so, when we signed the EC Declaration and in
case of non-compliance we may face disciplinary action, including termination of
employment, liability for criminal, civil and administrative penalties
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 33
Section 2
MARPOL ANNEX II
Prevention of Pollution by Noxious Liquid
Substances in Bulk
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 34
Noxious Liquid Substances - NLS
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 35
NLS Discharge Standards
What are the discharge standards of NLS ?
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 36
Certificates & Manuals on Board
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 37
Procedures & Arrangements (P&A) Manual
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 38
Noxious Liquid Substances – Category X
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 39
Noxious Liquid Substances – Categories Y and Z Substances
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 40
Noxious Liquid Substances – Persistent Floaters
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 41
Noxious Liquid Substances – Persistent Floaters
The requirements are only applicable when the port of unloading is located inside certain
regional areas, according to new regulation 13.7.1.4 in MARPOL Annex II.
For all ships Prewash procedures for persistent floaters to which regulation 13.7.1.4 of Annex II of MARPOL
applies…shall be treated as solidifying or high viscosity substances for the purposes of the prewash.
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 42
Handling of Chemical Cargoes
Whenever a nominated cargo is a chemical cargo, the Master should verify whether it is included
in the list of substances that the vessel is certified to carry.
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 43
Section 3
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 44
Application
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 45
Section 4
MARPOL ANNEX IV
Prevention of Pollution by Sewage
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 46
Sewage Pollution Prevention - Definition
Sewage refers to:
Drainage and other wastes from any What is considered as “Grey Water”?
form of toilets and urinals
Drainage from dishwater,
Drainage from medical premises shower, laundry, bath and
(dispensary, sick bay, etc.) via wash washbasin drains
basins, wash tubs and scuppers
located in such premises
What is considered as “Black Water”?
Drainage from spaces containing
living animals Drainage from toilets, urinals,
hospitals and animal spaces
Other waste waters when mixed with
the drainages defined above
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Sewage Discharge
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 48
Sewage Discharge
According to some National Requirements, the discharge of treated sewage is not allowed when the
ship is in their ports or within their territorial waters
In this case, National and Local regulations shall be followed, superseding MARPOL Annex IV restrictions
For example, in the United States, specific waters are designated as "no
discharge zones" where treated and untreated sewage discharges are
prohibited in these areas and vessel discharges are regulated through
the Environmental Protection Agency's Clean Water Act (CWA) National
Pollutant Discharge Elimination System (NPDES) Program
For example, China issued the “Discharge standard for water pollutants
from ships” that controls the requirements for the discharge of treated
sewage
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 49
STP Operation and Maintenance
STP is considered critical equipment High level alarm sensor of STP is considered
Sufficient spares are to be carried on board critical equipment
as …………………………….
Testing of clean effluent to be carried out At least 1 spare sensor must be on board
weekly
…………..
weekly
High level alarm must be tested ………….
Sewage spills into bilge tanks must be prevented
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 51
Collecting Treated Sewage and Grey Water on board
Occasionally, capacity of holding tank listed in the ISPPC section 1.3 is insufficient
for longer ship’s stay in the area where discharge overboard is not allowed.
On number of CSM vessels Class approved arrangements are fitted to allow
collection of treated sewage and grey water in a designated ballast or other tanks.
Approved arrangement is shown on the ISPPC and can be utilized according to the
approved ship specific procedure.
• Vessels not having an approved arrangement should communicate the necessity
to utilize an available tank to the Technical Superintendent in advance.
• Permission from the Flag Administration for storing treated sewage and grey
water in assigned tank has to be obtained prior to any transfer.
• Procedure provided by the Flag Administration has to be followed until the tank is
emptied and restored to its previous condition.
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 52
Section 5
MARPOL ANNEX V
Prevention of Pollution by Garbage
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 53
Garbage Pollution Prevention - Definition
All kinds of food wastes, domestic wastes and operational wastes, all
plastics, cargo residues, incinerator ashes, cooking oil, fishing gear, and
animal carcasses generated during the normal operation of the ship
Garbage does not include fresh fish and parts thereof generated as a
result of fishing activities undertaken during the voyage
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 54
Garbage Management Plans & Garbage Record Keeping
As per MARPOL Annex V Regulation 10
Recyclable garbage
“Plastics” (Yellow)
o Plastics (including Styrofoam or similar plastic
material)
Hazardous wastes “Hazardous Waste” (Red)
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 56
Garbage Categories
A. Plastics
B. Food Waste
C. Domestic waste
D. Cooking Oil
E. Incinerator ashes
F. Operational waste
G. Animal carcasses
H. Fishing gear
I. E-Waste
J. Cargo residues (non-HME)
K. Cargo residues (HME)
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 57
Garbage Categories
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Garbage Categories
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 59
Garbage Record Book
Garbage Record Book is divided in 2 parts
GRB - PART I
All ships
For all garbage except cargo residues
New Category I: e-Waste
GRB - PART II
Ships that carry solid bulk cargoes
For all cargo residues
Category J: Cargo residues (non-HME)
Category K: Cargo residues (HME)
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 60
Special Areas under Annex V: Garbage
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 61
Waste Receptacles Outside the Accommodation:
Metal Containers
Leak Proof
Protected against sea water
Located away from ship’s side
With lid and plastic seals
Inside the Accommodation, Engine Room and Galley: No hazard to adjacent spaces
Non-combustible materials Not to block access to safety equipment
Without openings Not stored in cofferdams.
Water-proof
Washable for wet waste;
Safely stored
Segregated waste
Marked with the garbage category
Warnings on dangers of particular types of waste;
Suitable fire protection devices in closed vicinity;
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 62
Discussion
What actions should you take if you notice a crewmember not to comply with
the Company’s Garbage Management Plan policy ?
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 63
Discussion – Possible actions
Stop the crewmember in case an environmental breach is imminent
Inform the crewmember about the Company’s Garbage Management Plan Requirements
Inform the Garbage Management Officer or the Master
Report the incident through the Open Reporting System
Inform the crewmember about the consequences of the violations of MARPOL Annex V
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 64
Section 6
MARPOL ANNEX VI
Prevention of Air Pollution
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 65
NOx Emissions
Which vessels have to comply with the NOx regulation ?
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
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.)
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 66
NOx Emission Control Areas
Name as many NOx Emission Control Areas you can:
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 67
Reduction of NOx emissions
Engine Certification and Survey Requirements
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 68
Reduction of NOx emissions
What do the Class surveyors check, to ensure engine’s compliance with NOx regulation ?
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 69
Reduction of NOx emissions
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 70
Maintaining the engines according to NOx regulations
What should the C/E do to ensure that the engines are maintained according to the NOx regulations ?
Check that the operational parameters are logged and are within the maker’s specified limits
Use suitable components and their ID numbers are recorded in the “Record Book of Engine
Parameters’’, whenever a replacement of components is carried out
Make sure that whenever adjustments are carried out to engine settings, these are within the
specified range and recorded in the “Record Book of Engine Parameters”
The engine’s Technical File and the EIAPP must always be onboard and maintained in an
excellent condition
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SOx Emission Control Areas
Name as many SOx Emission Control Areas you can:
The North Sea Area
0.50 All grades Global limit (since 01/01/2020) Revised MARPOL Annex VI adopted by Res. MEPC. 176(58)
For MGO supplied in EU territory and waters Directive 1999/32/EC as amended by Regulation 1882/2003 and Directive
0.10 MGO
(since 01/01/2008) 2005/33
CARB Marine Notice (mandatory use of either MGO or MDO with the set
MGO (DMA) California waters and 24 NM of the California
0.10 maximum sulphur limit to main propulsion diesel engines, auxiliary diesel
MDO (DMB) baseline (since 01/01/2014)
engines and boilers. HFO is not allowed to be used)
Vessels using scrubbers may use fuel with higher percentage of Sulphur, however specific local requirements should be considered.
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 73
Reduction of SOx emissions
Ensure that vessels operations will fully comply with the
MARPOL Annex VI requirements regarding SOx emissions,
both inside and outside SOx Emission Control Areas (ECAs)
The fuel oil received and consumed must satisfy the Annex VI
maximum Sulphur content limit
In the situation that the BDN shows compliant fuel, but test
results of the “commercial sample” indicates non-compliance,
the TSI has to be notified immediately.
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Fuel oil samples under MARPOL
There are three defined fuel oil samples under MARPOL, each provided with a set of IMO
guidelines:
MARPOL delivered sample – the traditional sample taken during bunkering, accompanying
the Bunker Delivery Note (BDN) which represents the fuel oil delivered on board.
On board sample – represents the fuel oil intended to be used or carried for use on board
the ship.
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 75
General Practice for Change-over Procedures – (MSOPR-02.2)
What is the General Practice for Change-over Procedures ?
Calculate the required time for safe change over of fuels
Start at calculated time prior to entering the ECA, to ensure that upon crossing the ECA
border the fuel oil system of the M/E and/or D/G has been fully flushed with the low
sulphur fuel
The less the segregation of the 2 fuel oil systems between the tanks the greater will be the
time interval required for the change over
The time required for fully flushing the fuel system depends upon several parameters, which
are mentioned below:
The existence of separate service and settling tanks
The volume of the service and settling tank, in case these are common for the two fuel
types
The existence of separate purifiers, heaters, etc. for the two fuel types
Requirements for gradual adjustments of the F.O. temperature and viscosity, if applicable
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 76
Change-over procedure calculation
What tool is available on board to calculate the Fuel Oil Change – Over procedure ?
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 77
Exhaust Gas Cleaning System (EGCS) - Scrubber
Marine scrubbers generally use sea water to remove sulphur oxides and particulate matter from the
exhaust gas.
EGCS can be used both inside and outside of ECAs.
Vessels fitted with EGCS are permitted to carry fuel oil with sulphur content exceeding that required by
MARPOL Annex VI Regulation 14.
Discharges of EGCS wash water to sea must be continuously monitored.
Several ports and regions limit or ban discharging of wash water into their waters.
Some coastal states (i.e. Australia and USA) require analytical monitoring of wash water.
Residues generated by EGCS should not be incinerated or discharged into the sea but delivered to
adequate shore reception facilities.
EGCS Malfunction
In case of EGCS malfunction (e.g. an alarm is triggered), immediate action should be taken to identify
and rectify the fault.
In case of EGCS breakdown, if the EGCS cannot be put back into a compliant condition within one hour
the vessel should switch over to compliant fuel.
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 78
Control of Volatile Organic Compounds (VOCs)
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
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 79
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
Residues of the Exhaust Gas Cleaning System (EGCS).
Special rules on incineration under domestic law may apply in some ports and in
some special areas prohibiting the use of incinerators (Ref GMP section 03.1)
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 80
Ozone Depleting Substances
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 81
Control of Shipboard Refrigerants Emissions
What measures are taken onboard the ship to control refrigerants emissions ?
Recover and reuse refrigerants by using a recovery unit, together with an empty gas
bottle which is supplied to all vessels
Maintain recovery units in good working order at all times
Order required spares via the Technical Superintendent
Register any detected loss of gas in the Refrigerant Record Book
Repair any leaks and record the loss of gas
Plan and execute the maintenance of the Air Conditioning and refrigerating plants in
accordance with the manufacturer’s instructions and as described in the PMS
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 82
Section 7
SEEMP
Ship Energy Efficiency Management Plan
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 83
SEEMP Part I – Applicability
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 84
SEEMP Part I
Name as many best practices for fuel-efficient operation of ships as you can
mentioned in Resolution MEPC.282(70)
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 85
SEEMP Part II - Applicability
SEEMP Part II – (Ship Fuel Oil Consumption Data Collection Plan) shall include a
description of the methodology that will be used to collect the data required by
regulation 22A.1 of Annex VI and the processes that will be used to report the data to
the ship’s Administration”.
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SEEMP Part II - Approval
SEEMP Part II to be reviewed and approved by the Verifier.
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 87
SEEMP Part II - Content
Introduction;
Ship Particulars;
Flag, IMO Number, Homeport, Ship type, Deadweight, Gross/Net Tonnage, EEDI.
Company information (Ship owner/ISM Manager), Name, IMO Number, Address.
Emission Sources and Fuel Types Used;
Main Engine, Aux. Engines, Aux. Boilers, IG Generators, Hydraulic Pump units.
MDO/MGO, LFO, ULFO, HFO, LPG, LNG, Methanol.
Emission Factors;
MGO=3.206, LFO=3.151, HFO=3.114, LPG=3.030, LNG=2.75 (in t-CO₂/t-fuel).
Method to measure Fuel Oil Consumption;
Bunker Delivery Notes;
Periodic stocktakes of fuel tanks during bunkering and at departure and arrival ports.
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SEEMP Part II - Content
Method to measure Distance Travelled;
Distance over ground (via GPS);
Reported based on the voyage distance, calculated from berth to berth.
Method to measure Hours Under Way;
Steaming time as in Deck Logbook;
Actual time at sea from previous noon report.
Procedure for reporting data to Administration;
Vessel reports to the office the fuel consumption through noon report (InfoPath);
Data received is imported automatically in the database;
Final report of the year is produced in the office by retrieving all noon reports available in the
database;
Final report is reviewed/validated in the office and sent to the Verifier.
Data Quality
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Energy Efficiency Design Index
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Energy Efficiency Operational Indicator (EEOI)
The EEOI is an approach to assess the efficiency of a ship with respect to CO2 emissions
In its most simple form the Energy Efficiency Operational Indicator is defined as the ratio of
mass of CO2 emitted per unit of transport work
EEOI = Environmental Cost ÷ Benefit to Society
Energy Efficiency Operational Indicator = M CO2 / (transport work)
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Energy Efficiency Index for Existing Ship (EEXI)
Applicable for ships over 400 gross tonnage (GT) in line with the Energy Efficiency Design Index (EEDI)
Entry into force January 1, 2023, on first annual, intermediate or renewal International Air Pollution
Prevention (IAPP) survey or the initial International Energy Efficiency Certificate (IEE) survey
A review shall be completed by 1 January 2026 by the Organization to assess the effectiveness of the
regulation in reducing the carbon intensity of international shipping
Attained EEXI ≤ Required EEXI = (1 − y /100) • EEDI reference line value
where y is the reduction factor specified in Reg. 25 of MARPOL Annex VI.
Ship type d1 d2 d3 d4
Bulk Carrier 0.86 0.94 1.06 1.18
DWT ≥ 0.81 0.91 1.12 1.44
Gas Carrier 65,000
DWT <
65,000 0.85 0.95 1.06 1.25
Tanker 0.82 0.93 1.08 1.28
Container ship 0.83 0.94 1.07 1.19
General cargo ship 0.83 0.94 1.06 1.19
Refrigerated cargo carrier 0.78 0.91 1.07 1.20
Combination carrier 0.87 0.96 1.06 1.14
DWT≥ 0.89 0.98 1.06 1.13
100,000
LNG Carrier DWT <
0.78 0.92 1.10 1.37
100000
Ro-ro cargo ship (VC) 0.86 0.94 1.06 1.16
Vectors and rating bands Ro-ro cargo ship 0.66 0.9 1.11 1.37
Vectors d1, d2, d3 & d4 show the deviation from the required CII Ro-ro passenger ship 0.72 0.90 1.12 1.41
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Carbon Intensity Indicator (CII)
SEEMP Part III, CoC
31st December
End of DCS
Data Collection
30th
November 31st March
Deadline to
Deadline to submit DCS for
Audit the review
Company
31st May:
DCS
Deadline to Verification
issue SoC
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SEEMP Part III - Approval
SEEMP Part III to be reviewed & approved by the Administration or a Recognised Organisation
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SEEMP Part III - Content
Introduction;
Required CII over the next 3 years, attained CII & rating over 3 consecutive years;
Name, IMO Number, Flag, Ship type, Deadweight, Gross Tonnage, Applicable CII.
CII starting point and records of 3 consecutive years.
Calculation Methodology;
The attained CII is calculated as per the Guidelines on operational CIIs and the calculation methods
(CII Guidelines, G1).
Required data for calculation of attained CII;
Ship’s Carrying Capacity (DWT/GT), distance travelled and fuel oil consumption for each type of fuel.
Method for obtaining data for calculation of attained CII;
Data will be obtained as per SEEMP Part II;
Correction factors and voyage adjustment;
The available corrections and adjustments depend on the ship type;
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SEEMP Part III - Content
Self-evaluation and improvement;
List of measures to be considered and implemented including responsible
company personnel
Speed Optimization
Impediment and contingency measures
Calculation showing the combined effect of the measures and that the required
operational CII will be achieved
Plan of Corrective actions (if applicable)
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Section 8
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 98
EU MRV
When to report?
Annually for the previous year, latest by 31st March;
First reporting for the year 2018;
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MRV Monitoring Plan - Content
Part A: Purpose and Scope;
Part B: Basic Data
• Ship identification
Flag, IMO Number, Homeport, Ship type, Deadweight, Gross Tonnage.
• Company information (DOC Holder)
Name, IMO Number, Address, Contact Person.
• Emission Sources
Main Engine, Aux. Engines, Aux. Boilers, IG Generators, Hydraulic Pump units.
• Fuel Types
MDO/MGO, LFO, ULFO, HFO, LPG, LNG, Methanol.
• Emission factors
MGO=3.206, LFO=3.151, HFO=3.114, LPG=3.030, LNG=2.75 (in t-CO₂/t-fuel).
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MRV Monitoring Plan - Content
Part C: Activity Data;
• Fuel Consumption (method of monitoring)
Method A: Bunker Delivery Notes and periodic stocktakes of fuel tanks;
Method B: Bunker fuel tank monitoring onboard; Selected for the CSM Fleet.
Method C: Flowmeters for applicable combustion processes;
Method D: Direct CO₂ emission measurement.
CO₂ emitted = Fuel consumption x Emission factor
• Time spent at see
Hours from port of departure to port of arrival, excluding anchoring.
• List of Voyages
Into, out of, between EU ports.
Example 1: Load in Busan, load/unload & bunkering in Singapore, discharge in Rotterdam
=> Voyage: Singapore – Rotterdam.
Example 2: Load in Busan, bunkering in Singapore, discharge in Rotterdam
=> Voyage: Busan – Rotterdam.
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MRV Monitoring Plan - Content
Part C: Activity Data; (Continued)
• Cargo Carried
Tonnes for cargo ships;
Tonnes of deadweight for general cargo ships;
Cubic meters for LNG carriers;
Number of passengers for passenger vessels.
• Distance Travelled
From berth of port of departure to berth of port of arrival in Nautical miles.
Transport Work = Cargo carried x Distance travelled
Part D: Data Gaps
Methods to treat data gaps for fuel consumption, distance travelled, cargo carried and
time spent at sea.
Part E: Management
Regular checks and control activities (reviews, validations, corrections, etc.).
Part F: Further Information
Definitions, abbreviations, other information.
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MRV Monitoring Plan
Monitoring Plan to be
reviewed and accepted by the
Verifier
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EU MRV – Reporting
Annual Reporting
• Amount for each type of fuel consumed;
• Total aggregated CO₂ emitted;
From all voyages between, departed from and to EU ports.
CO₂ emissions occurred within EU ports at berth.
• Total distance travelled;
• Total time spent at sea;
• Total transport work.
• CO₂ Emissions:
Total Annual CO₂ Emissions / Total Distance Travelled
Total Annual CO₂ Emissions / Total Transport Work
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EU MRV – Verification
Verification
• Verifier: Legal entity accredited to carry out verification.
• Verification: Activities carried out to assess the conformity of the documents submitted.
Assessment of Monitoring Plan;
Verifications of Emission Report;
Issuance of Document of Compliance (latest 30 June);
Inform the EC and Flag State of DOC issue.
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IMO DCS
When to report?
Annually for the previous year, latest by 31st March;
First reporting for the year 2019;
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IMO DCS – Reporting and Verification
Annual Reporting
• Amount for each type of fuel consumed;
• Total aggregated CO₂ emitted;
• Total distance travelled;
• Total time spent at sea.
Verification
• Verifier: Legal entity accredited to carry out verification.
• Verification: Activities carried out to assess the conformity
of the documents submitted.
Assessment/Approval of SEEMP Part II;
Verifications of Emission Report;
Issuance of Statement of Compliance (latest 31 May);
Report to flag and flag reports to IMO database.
• Results remain confidential
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EU MRV and IMO DSC
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EU MRV and IMO DSC – Annual Reports
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What is coming next?
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EU Emission Trading System (EU ETS)
EU ETS is a Cap-and-Trade system market-based-measure (MBM) to reduce GHG
emission.
It is entered into force on 5.6.2023
It will be implemented from 01.01.2024 for cargo & passenger ships of GRT ≥ 5000 and
from 01.01.2027 for offshore ships of GRT ≥ 5000.
From 2025 an emission report should be submitted to the independent verifier followed
by submittal of the verified report to the administration authority by end of March.
The responsible entity for reporting is the shipowner or any other firm that has assumed
the responsibility on behalf of the shipowner.
EU Emission Allowances (EUAs) can be bought in the open market by anybody. Charterers
can buy issued or future EUAs via EEX/brokers and via bilateral relationships. Only
shipping company will have access to the auction.
The cap is the threshold specifying the total amount of GHG that could be emitted by the
operators. This value is reduced annually at fixed intervals.
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EU Emission Trading System (EU ETS)
The ETS emissions are monitored and reported through the EU MRV reporting system.
Under EU ETS, the relevant emission factors are Tank-to-Wake.
Taxable emissions are those originating from a voyage between two port of calls, where a
ship stops to load or unload cargo or to embark or disembark passengers, or the port
where an offshore ship stops to relieve the crew.
Stops for dry-dock or making repairs to the ship and/or its equipment are not considered
a port of call.
The reporting period is from 1 January until 31 December of the calendar year. The part
of the voyage which falls in 2023 is subject to the 2023 reporting, while the part in 2024
will is subject to 2024 reporting and emission taxes.
Under EU MRV, there are two methods to calculate N2O and CH4 emissions, the
calculation approach and the measurement approach. Under the measurement
approach, direct GHG emissions measurements are used. For the calculation approach
there are three different methods:
1- Method A: BDN;
2- Method B: Bunker fuel tank monitoring;
3- Method C: Flow meters.
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IMO Measures on Reducing CO2 Emissions
1st Policy Package, MARPOL Annex VI Amendments
(Entered
Operational Measure, SEEMP I into force on 1 Jan 2013)
Technical Measure, EEDI
SEEMP for all vessels >400 GT (no approval required) CO2 emission standards for new-buildings
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Section 9
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 115
VGP Application
VGP Applies to all Columbia vessels:
All vessels subject to NPDES except those less than 24 meters in length and
recreational crafts
Non-recreational vessels less than 79 feet
Vessels greater than 79 feet in length
Non military vessels greater than 79 feet
Commercial fishing vessels
The permit is applicable to US inland waters and the 3 nautical miles territorial sea
All navigable waters of the Great Lakes under the US jurisdiction are also included
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Discharges - subject to VGP
Name as many discharge types eligible for coverage under the VGP
Deck washdown and runoff and above Gas Turbine Wash Water
waterline hull cleaning Graywater
Bilgewater Motor Gasoline and Compensating Discharge
Ballast Water Non Oily Machinery Wastewater
Anti-Fouling Hull Coatings/Hull Coating Refrigeration and Air Conditioning Condensate
Leachate Seawater Cooling Overboard Discharge
Aqueous Film Forming Foam Seawater Piping Biofouling Prevention
Boiler Economizer Blowdown Boat Engine Wet Exhaust
Cathodic Protection Sonar Dome Discharge
Chain Locker Effluent Underwater Ship Husbandry and Hull Fouling
Oil to Sea Interfaces Coatings
Distillation and Reverse Osmosis Brine Well Deck Discharges
Elevator Pit Effluent Graywater mixed with Sewage
Firemain Systems Exhaust Gas Scrubber Washwater Discharge
Freshwater Layup Fish Hold Effluent
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Deadlines for submitting a NOI
Discharge Authorization
Category of vessels NOI Deadline
date
New vessel For e-NOIs: For e-NOIs:
…… days prior discharging ….. days after submission
7 Paper NOIs:
For 7
For Paper NOIs:
…… days prior discharging ….. days after submission
New owner or operator By 30date of transfer of 30 of transfer or date EPA
Date
of a vessel – transfer of ownership or operation receives the NOI whichever
ownership and/or is later
operation of a vessel
whose discharges are
authorized under the
permit
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Inspections
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Section 10
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BALLAST WATER MANGAEMENT
Any system which processes ballast water to kill, render harmless or remove
organisms. The BWMS includes all ballast water treatment equipment and all
associated control and monitoring equipment
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Dealing with ballast water
Regulation D-1 : Exchange Standard
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Ballast Water Exchange Requirements
Alternative to the distance and depth requirement, the
exchange may take place in designated exchange areas.
If the requirements on the distance from the nearest land and
water depth are not met throughout the journey and an
exchange area does not exist, an exchange is not required.
The flag state should be informed and the circumstance must
be documented in the Ballast Water Record Book.
Individual tanks should always be exchanged completely.
Under no circumstances should a partial exchange take place
within a tank.
As many complete tanks should be exchanged as the time
allows without delaying the journey.
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Requirements for Ballast Water Treatment (IMO)
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Ballast Water Treatment Systems
Physical Disinfection
Residual
Solid-Liquid Control:
Chemical Treatment:
Separation - Chlorination
- Chemical Reduction
( Sulphite /
- Electro-chlorination Bisulphite )
Treatment:
(or Electrolysis)
- Hydrocyclone Physical
- Surface Filteration enhancement
- Ultrasonic
treatment
Chemical
Enhancement: Physical:
- Coagulation / - UV irradiation
Flocculation
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Ballast Water Management Plan
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What kind of records is required to be kept regarding the Ballast Water Management Plan ?
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US Ballast Water Management Requirements
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BWTS Failure
In case BWTS becomes inoperative
During operation in port, BW intake:
• Uptake of BW must be suspended
• BWMP Contingency measures to be activated
• Port State to be informed of the BWTS failure and its consent to be obtained for bypassing BWTS
• Flag State to be notified of the BWTS failure
• BWTS failure to be recorded under code 3.6 in the BWRB
During operation in port, BW discharge or en-route to a port of intended BW discharge, in addition to actions listed above:
• Port State to be notified of the BWTS failure and approached for permission to activate contingency measures per the
ship’s BWMP
• Port State instructions on handling untreated/non-neutralised BW to be obtained and followed
• BWTS failure to be recorded under code 3.6 in the BWRB
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Comparison Between IMO & USCG
Ballast Water Treatment Type Approval Procedures
IMO USCG
BWM Convention requires a Type Approval USCG requires a Type Approval certificate, issued by
certificate by the Administration or that the USCG in accordance with 46 CFR 162.060
particular flag State acknowledge another
BWTS with IMO Type Approval certificate can after a
Administration’s Type Approval certificate in
review process by USCG be listed as Alternate
writing (ref Reg. D-3 and G8 6.3-6.5)
Management System
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Section 11
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What is the Biofouling Management Plan ?
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Information in BFMP
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The Biofouling Management Officer
Who is the Biofouling Management Officer and what are his responsibilities ?
He is responsible for:
Ensuring implementation of the Biofouling Management Plan
Maintaining the Biofouling Record Book
Conducting of training for Biofouling Management and Treatment
Procedures
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Types of Anti-fouling coatings
How many types of Anti- fouling coatings exist and how do they work ?
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 135
Name as many niche areas on the ship that may accumulate biofouling
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In-water inspection, cleaning and maintenance
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Information required in Biofouling Record Book
Details of the anti-fouling systems and operational practices used, where and
when installed, areas of the ship coated, its maintenance and its operation
Dates and location of dry-dockings / slippings and any measures taken to
remove biofouling or to renew or repair the anti-fouling system
The date and location of in-water inspections, the results of that inspection
and any corrective action taken to deal with observed biofouling
The dates and details of inspection and maintenance of internal seawater
cooling systems, the results of these inspections, and any corrective action
taken to deal with observed biofouling and any reported blockages
Details of when the ship has been operating outside its normal operating
profile including any details of when the ship was laid-up or inactive for
extended periods of time
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Information required in Biofouling Record Book
Cases that require to be recorded in the Biofouling Record Book include:
Every dry-docking
When the hull area, fittings, niches and voids below the waterline have been
cleaned by divers
When the internal seawater cooling systems have been inspected / cleaned or
treated
For ships with a Marine Growth Prevention System (MGPS) fitted, Record of
operation and maintenance and any instances when the system was not operating
in accordance with the BFMP
Periods of time when the ship was laid up / inactive for an extended period of time
Periods of time when ship operating outside its normal operating profile
Details of official inspection or review of ship biofouling risk
Any additional observations and general remarks
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Record of Biofouling Management Actions
SAMPLE OF BIOFOULING RECORD BOOK ENTRIES
HULL INSPECTION
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 140
Thank you for your
attention
Any questions?
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