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Prevention of Pollution By A selection of articles previously Prevention of published by Gard AS pollution by oil 2 © Gard AS, December 2013 3 Contents Introduction 5 Shipping industry guidance on the use of Oily Water Separators Ensuring compliance with MARPOL 6 Clearing of shore pipelines following cargo operations at terminals 8 US Pollution - California Certificates of Financial Responsibility (COFR) Requirements 10 Australian Pollution Law – Oil Pollution Indemnity Clause for Penalties and Fines 11 Limitation of liability for pollution clean-up costs in China 13 The silent sentinels – Increased use of remote marine pollution sensors 15 New Greek marine pollution legislation 17 New wine from old wineskins? - Current efforts to retrieve oil from sunken vessels 19 Australia toughens pollution laws 21 New Pollution Regulations in China - FAQs II 22 Charterers’ pollution liability in Brazil 24 Perfecting pollution prevention? - The State of Washington enacts a new statute 26 The state of environmental crime enforcement in the US 27 US law – Criminal prosecutions of MARPOL violations 32 ICS/ISF guidance on environmental compliance 34 Oil and water don’t mix 35 Environmental Crime – Myths and Reality 36 Oily water separation and discharge: Risk of oil pollution versus vessel’s safety 37 The finer points of oil pollution 40 US Coast Guard formal policy on voluntary disclosure of MARPOL violations 43 Oily water separator bypass in the US - The tables are turned 44 US law - MARPOL violations in the US 45 Environmental crime - Oily water discharge off the East Coast of Canada 46 Pollution - The hard line taken by the French criminal courts on oil discharge from ships 47 Disclaimer The information contained in this publication is compiled from material previously published by Gard AS and is provided for general information purposes only. Whilst we have taken every care to ensure the accuracy and quality of the information provided at the time of original publication, Gard AS can accept no responsibility in respect of any loss or damage of any kind whatsoever which may arise from reliance on information contained in this publication regardless of whether such information originates from Gard AS, its shareholders, correspondents or other contributors. © Gard AS, December 2013 4 © Gard AS, December 2013 5 Introduction This booklet contains a collection of etc., are deliberate in the sense amount of oil spilled in the event of loss prevention material relating to the that the discharge is intended (and an accident (e.g. segregated ballast prevention of pollution by oil, which permitted by the relevant legislation), tanks, protected location of fuel tanks over the years has been published by however, because the amount of and double hull). Although the greater Gard. pollutant contained in the discharged volume of the oil spilled can be linked liquid exceeds the permitted amount, to tanker incidents, commercial vessels Discharges of oil from shipping, this results in the discharge being other than tankers also contribute to offshore extraction of oil, and transport performed negligently. Such discharges oil pollution and MARPOL Annex I of oil in pipelines is the result of either can be avoided. contains the required safety measures accidents or “normal”, deliberate to prevent and minimise also this type operational discharges. Accidental The most important regulations of discharges (e.g. specific requirements discharges (oil spills) may occur when governing the prevention of pollution for discharge of oil residue (sludge) and vessels collide, are in some sort of by oil from ships are contained in bilge water form machinery spaces). distress at sea (engine breakdown, the International Convention for fire, explosion), run aground, or when the Prevention of Pollution from Although all aspects related to the there is a blowout of an offshore oil Ships (MARPOL) Annex I and cover prevention of pollution by oil are not well, or when a pipeline breaks. Much prevention of pollution by oil from covered in this compilation, and local can be done to avoid accidents, operational measures as well as from authorities may have additional, and but there will always be unfortunate accidental discharges. With seaborne sometimes stricter, requirements than circumstances and situations that give oil trade growing steadily since 1970, those contained in MARPOL Annex rise to accidents. Operational (i.e. non- apart from a fall in the early 1980s I, this compilation will hopefully be a casualty-related) discharges often arise during the worldwide economic useful aid in providing guidance, some during routine bunkering operations recession, the aim of many of the safety answers, or at the very least a pointer and are usually caused by negligence/ measures included in MARPOL Annex in the right direction when it comes to lack of care. Other operational I is to ensure that the majority of oil prevention of pollution by oil. discharges, e.g. discharge of bilge tankers are safely built and operated, water, fuel oil sludge, tank washings and are constructed to reduce the © Gard AS, December 2013 6 Shipping industry guidance on the use of Oily Water Separators Ensuring compliance with MARPOL The global shipping industry is Ensuring compliance with MARPOL • Implementing the periodic testing committed to a zero tolerance Shipping companies should: of the oil discharge monitoring approach to any non-compliance with • Ensure that the ISM Safety equipment the International Convention for the Management System* is used to Prevention of Pollution from Ships good effect • The use of cleaning agents (MARPOL). In particular, the industry consistent with equipment is committed to strict adherence to • Conduct internal and external capability. International Maritime Organization audits on environmental (IMO) requirements concerning the compliance and act upon the Control devices use of Oily Water Separators and the findings, in full compliance with the Shipping companies should consider: monitoring and discharge of oil into the ISM Code • Fitting uniquely numbered sea. environmental tags on flanges to • Require accountability on prevent unauthorised by-passing National maritime authorities with environmental compliance issues responsibility for the environmental within the shore-side and shipboard • Using seals on overboard valves protection of their coastlines quite management team and cross-connections properly adopt a similarly strict approach to the enforcement of MARPOL. • Minimise waste leakage through • Installing strategically placed good housekeeping and placards concerning compliance Companies and seafarers need to maintenance with MARPOL on board ship understand that even the most minor • Make the best use of the available violations of MARPOL will be detected technology • Fitting surveillance cameras by the authorities. In addition to large fi nes amounting to literally millions of • Establish a realistic operating • Using tamper resistant recording dollars, both company management budget for environmental systems, alarms and printouts and seafarers can be liable to criminal compliance to verify equipment operation, prosecution and imprisonment for valve position, flow, OWS ppm, any deliberate violation of MARPOL • Provide meaningful and targeted incineration, ship’s position etc. requirements or falsifi cation of records. training in environmental awareness and MARPOL compliance • Installing locked boxes or cages The following industry guidelines over monitoring equipment are intended to highlight some of • Provide specific and targeted the issues concerning the use of oily training in oily water separator • Fitting interlocks to prevent water separators (OWS) and to remind (OWS) operation falsification of monitoring company management, and shipboard equipment inputs personnel, how they can act to prevent • Recognise the value of open MARPOL infringements. communication with the crew • Using meters to record equipment running time for all engine room Ship operators have ultimate • Verify compliance through pumps. responsibility for establishing a appropriate physical inspection, compliance culture within their operational tests and document Management approaches companies, and it is important that every analysis Role of shore management effort is made to ensure that seafarers Shipping companies should: do not engage in any illegal conduct in • Reward compliance and address • Assign environmental responsibility the mistaken belief that it will benefit potential non-compliance. to senior management and ship their employer. Every seafarer should superintendents, Masters and Chief be made fully aware of the severe legal Technical approaches Engineers on board ships consequences, both for the company and General the seafarers themselves, of even minor Shipping companies should consider: • Ensure adequacy of internal audits non-compliance with environmental rules. • Installing the latest equipment, or and implementation of corrective an upgrade in capability, if existing actions At first glance, the following advice equipment does not perform to may appear to contain nothing new; requirements • Review maintenance records for the vast majority of shipping and procedures, log entries and companies, these are issues which • Upgrading related equipment to handover notes should already be fully addressed by minimise the production of waste their Safety Management Systems, as • Monitor workloads imposed by the required by the International Safety • The advantages of the pre- operation and maintenance
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