The Oily Water Separator (OWS) sits ‘unloved’ in the bottom of the Engine Room. It performs its task well, filtering off the oil so that clean water can be legally discharged overboard in the correct sea areas. But the OWS might have a nasty surprise for unsuspecting Chief Engineers and Masters! Breaches of MARPOL regulations for the correct use and operation of the OWS have recently resulted in prison sentences in the USA for Masters, Chief Engineers and crew members. Fines in excess of many millions of USD levied on the ship owner or management company and so called ‘compliance programmes’ inflict unbearable costs and make it impossible to trade to the United States. Making a false entry in the oil record book resulted in a f ine of US$5.5 million for one ship owner. In Europe, a fine of Euro 600,000 was recently imposed by the Spanish courts on a vessel found guilty of flushing oily sludge directly into the sea. So what can you do to ensure that your vessel is not breaching MARPOL regulations on the OWS?
Here are FIVE golden rules:
1. Check around! When you get on board, have a good check of the OWS and make sure it is working properly. Is it clean? Have the correct routine maintenance procedures such as internal cleaning and regular checks on the parts per million (ppm) alarm been made? Are there any unusual or unauthorized modifications to the OWS equipment or piping that are not in line with the approved drawings? Check underneath the OWS for unauthorized connections or f langes that should not be there. Check that there are no ‘magic pipes’, hoses or other connections in the Engine Room, in the store or in the bilges that could be used for illegal transfer. If found, they should be removed and destroyed and the matter raised immediately with your Technical Superintendent and the DPA. How is the crew training? Can everyone use the OWS and does everyone know how to test it? If it malfunctions, do they know the correct procedure for discharging sludge to barges or for burning in the incinerator? What has to be recorded in the Oil Record Book (ORB)?
2. Make sure the overboard discharge valve is marked and chained/padlocked. The overboard discharge valve should be clearly marked and have the necessary warning notices posted close to it. It should be chained and padlocked so it cannot be opened accidentally.
3. Check the piping and flanges Many Owners and Managers now insist that all the flanges on the OWS pipes are fitted with ’anti-tamper’ numbered seals so that it is immediately clear if a flange has been broken (for example to illegally bypass the OWS). If your company follows this policy, the seals should be installed under the Chief Engineer or Superintendent’s personal supervision and the number of the seal and the corresponding flange carefully recorded. If the flange has to be broken for any reason, then the Technical Superintendent must be informed in advance. Paint and colour code the OWS inlet/ outlet pipes in signal red/yellow bands to highlight that they are special pipes and must not be tampered with. Keep records on board of the flanges and the number of the seals and handover the same record to your relief.
4. OWS Approval Certificate Confirm that the OWS approval certificate is available on board.
5. Oil record book Make sure the Oil Record Book is carefully checked for accuracy of entries and that engine sludge generation matches the quantity of sludge on board in tanks.