MARPOL Part I
Overview and Annex I - Oil
MARPOL (the International Convention for the Prevention of Pollution from Ships), like SOLAS, is an IMO convention. The convention mostly consists of regulations aimed at preventing ships from polluting the marine environment through operational or accidental causes, and six technical annexes. It also includes requirements for international co-operation, and for flag states to provide suitable reception facilities.
Relevant documents and M-notices: MARPOL convention, MGN 631, MGN 231, MGN 381, MGN 386, MGN 400, MGN 507
How is MARPOL made into UK law?
MARPOL is an international convention from the IMO and is made into UK law under various Statutory Instruments e.g.
The Merchant Shipping (Prevention of Oil Pollution) Regulations 2019
Merchant Shipping (Prevention of Air Pollution from Ships) Regulations 2008
Merchant Shipping (Prevention of Pollution from Noxious Liquid Substances in Bulk) Regulations 2018
Who does it apply to?
The UK legislation enacting MARPOL applies to UK ships regardless of where they may be, and non-UK vessels while in UK waters. The legislation does not apply to warships, naval auxiliary ships, or ships owned or operated by a State and engaged only on governmental non-commercial service.
What does the convention require of the flag state?
The convention requires that the flag state:
Establish sanctions for any violation of the convention
Bring proceedings against any vessel violating the convention
Create penalties in law adequate to discourage violations of the convention. These have to equally severe regardless of where the violation occurs
How is it controlled?
MARPOL falls under the remit of both flag state and port state control.
How does a ship comply with MARPOL?
Certification
We’ve covered the certificates required under MARPOL in another article, but we’ll briefly mention the certificates in this and other MARPOL articles.
To avoid getting sidetracked learning about the schedules for issue and inspections etc, leave that article for later and just learn the details given under the Annex titles below, and in other articles in this series. At OOW level the information in these article should suffice.
Inspections
These are carried out in order to maintain our certification. For Annexes I and II these fall under the Harmonised System of Survey and Certification.
Records
The records required under each Annex will be given in that Annex’s section in this and other articles.
Reporting obligations
From MARPOL:
The master or other person having charge of any ship involved in an incident referred to in article II of this Protocol shall report the particulars of such incident without delay and to the fullest extent possible…
These reports should be made as soon as possible, using a telecommunication channel (not email), to the nearest coastal state. The IMO publishes a list of designated contact points, failing that the Master should contact the nearest coastal radio station, designated ship movement reporting station or rescue coordination centre. If the ship is lost this duty falls to the operator or owner.
The incidents referred to in article II are:
A discharge, or probable discharge, above the permitted level, quantity or instantaneous rate for oil and noxious substances for any reason
A discharge or probable discharge of harmful substances in packaged form. This includes from lorries onboard, containers etc.
Damage, failure or breakdown of any ship over 15m in length which affects the safety of the ship or results in impairment of navigation.
Such reports should consist of:
Identity of the ships involved
Time, type and location of incident
Quantity and type of harmful substance involved
Assistance and salvage measures
What are the six annexes?
This is one list you definitely want to know by heart. Fortunately, it’s easy to remember (mnemonics in parentheses)
Annex I - Oil (Oil is the number 1 pollutant)
Annex II - Noxious liquids in bulk (I’m feeling 2 sick)
Annex III - Harmful substances in packaged form (3 presents under the tree)
Annex IV - Sewage (Two number 2’s)
Annex V - Garbage (5 is the (garb)age you start school)
Annex VI - Air pollution (The skater gets 6ft of air)
A useful mnemonic is Oh No, Here Steve Goes Again. Picture Steve throwing some rubbish into the sea to help this stick in your head.
Are all the annexes obligatory?
No. Flag states can declare that they don’t accept any or all of Annexes III, IV and V.
The Annexes consist of regulations. These regulations cover:
Definitions of terms
Application of the Annex
Applying for and maintaining any certification required under the Annex
Discharge criteria (when applicable)
Special areas
Exceptions to the Annex
Reception facilities required to be provided by ports
General technical requirements for ships
annexes to the Annex (!) giving details of forms etc.
The Annexes
In this and other articles in the series we will give an overview of the mort important requirements from each Annex with regards to the day-to-day operation, compliance and record keeping of a ship. If pushed beyond this level in your exam, tell the examiner where you’d find the information; remember, the examiner knows that when you are at sea you have access to the ships documents, library and internet.
Annex I - Oil
Oil, for the purposes of this annex, is petroleum in any form. This doesn’t cover petrochemicals derived from oil; these are covered by Annex II. Oily mixture is any mix with any oil content, and oil fuel means any fuel that is used in connection with the machinery of the ship in which it is carrier.
International Oil Pollution Prevention Certificate
Every oil tanker of 150GT and above, and every other ship of 400GT and above, is subject to survey and the issue of an IOPPC. More details on this, including the process and schedule of inspections, are given in the Certification article linked above.
This certificate is accompanied by Form A for all vessels other than tankers and Form B for oil tankers.
Form A contains:
Particulars of ship
Machinery space discharge equipment
Means of holding (tanks)
Discharge connection specifications
Confirms existence of SOPEP
Exemptions and equivalents
Form B is the same as the above, plus:
Construction of segregated ballast tanks
Slop tank arrangements
Pumping and piping arrangements
Oil Record Book (Regulation 20)
A tanker of 150GT and above must carry an Oil record book part 1 (machinery spaces.
Any other ship of 400GT and above must carry an Oil record book part 2 (cargo/ballast operations)
Any oil tanker of 400GT and above must carry both.
There is a long list of every time an entry must be made in the Oil Record Book. In general it covers every time oil is discharged deliberately or otherwise, every time aoil is loaded or discharged, every time tanks are cleaned or ballasted and every time residues are disposed of. If asked where you would find this list; MARPOL, or there are guidance notes in the Oil Record Book itself. Each entry is signed by the Officer in charge, and each page is signed by the Master of the vessel.
When correcting an incorrect entry in the Oil Record Book, it is acceptable to strike through the incorrect entry, like so. The correct entry can then be added underneath.
The Oil Record Book must be retained for three years after the last entry is made.
SOPEP (Regulation 26)
A Shipboard Oil Pollution Emergency Plan must be carried by oil tankers of 150GT and above and other ships of 400GT and above. This plan must be approved by the administration (or by a Recognised Organisation (Class Society) in the case of vessels under the Alternative Compliance Scheme). This must contain:
Procedures for master and crew in event of oil pollution, with ranks and roles
List of authorities and persons to be informed (updated 3-monthly)
Details of immediate action to reduce or contain the spill
Procedures for contacting local and national authorities
General arrangement information
Tank plan
Fuel oil piping plan
Discharge
All discharge of oil into the water is prohibited unless the following requirements are met:
From the cargo residue of oil tankers:
the vessel must be outside a special area (more on these below)
the vessel must be more than 50 nautical miles from the nearest land
the vessel must be en route
the rate of discharge must not exceed 30 litres per nautical mile
the total quantity of oil discharged must not exceed 1/30,000 of the total quantity of the cargo of which the residue formed a part
the tanker has a working Oil Discharge Monitoring and Control System and a slop tank
Suitable entry made in Oil record book Part I
From a ship of 400GT and over other than an oil tanker, and from the machinery space bilges of an oil tanker:
The ship is outside a special area
The ship is proceeding en route
The oil content without dilution doesn’t exceed 15 parts per million (ppm)
The ship has in operation equipment as required by reg. 16 (see that)
A suitable entry is made in the Oil record book Part II
What does en route mean?
From MARPOL:
The term en route is taken to mean that the ship is under way at sea on a course, or courses, which so far as practicable for navigational purposes will cause any discharge to be spread over as great an area of the sea as is reasonably practicable.
This includes deviating from the shortest route. It does not include being at anchor, or in DP mode.
What are the special areas under Annex I?
Special areas are designated because of environmental fragility, intensity of ship traffic, or because they are enclosed.
The Mediterranean Sea area
The Baltic Sea area
The Black Sea area
The Red Sea area
The ‘Gulfs’ area
The Gulf of Aden area
The Antarctic area
North-West European waters
The Oman area of the Arabian sea
Southern South African waters
Note that, while the Arctic area isn’t a special area under MARPOL Annex I, under Part II of the Polar Code (SOLAS Ch 14) all oil discharge is forbidden in Arctic and Antarctic areas from any ship to which MARPOL applies. We’ll cover the Polar Code in a separate article but for now know that the Antarctic area is anything south of 60 degrees South, and the Arctic area is North of 60 degrees North with a deviation to include Greenland and exclude Iceland and northern Norway.
When can a ship discharge within a special area?
When it is discharging clean or segregated ballast
When discharging processed bilge water from machinery spaces, provided that:
It doesn’t originate from cargo pump-room bilges
It is not mixed with oil cargo residues
The oil content without dilution does not exceed 15 parts per million (ppm)
The ship has operating oil filtering equipment compliant with regulation 16 (see below)
The filtering system is fitted with an automatic stop which is activated if the oil content of the effluent exceeds 15ppm
Of course, a ship may discharge oil or oily mixture in order to secure the safety of the ship or to save life at sea.
It’s acknowledged that discharge may also occur as a result of damage to the ship or ships equipment, provided all reasonable precautions have been taken to prevent or minimise this discharge.
Regulation 16 (1)
Any ship of 400 tons gross tonnage and above but less than 10,000 tons gross tonnage shall be fitted with oil filtering equipment complying with paragraph (4) of this regulation.
Which states that:
Oil filtering equipment referred to in paragraph (1) of this regulation shall be of a design approved by the Administration and shall be such as will ensure that any oily mixture discharged into the sea after passing through the system has an oil content not exceeding 15 parts per million.
Regulation 16 (2)
Any ship of 10,000 tons gross tonnage and above shall be provided with oil filtering equipment, and with arrangements for an alarm and for automatically stopping any discharge of oily mixture when the oil content in the effluent exceeds 15 parts per million.
These requirements can be waived by administrations for vessels operating solely in special areas (e.g. cross-channel ferries). These can instead have holding tanks and discharge oily water to shore facilities.
Ships of 400GT+ must have adequate sludge tanks to store oily residues which cannot be otherwise dealt with, sufficient for the lengths of her voyages. These may have no pipes leading overboard other than the standard discharge connection (used for sending sludge ashore).
Stability requirements for oil tankers are given in Regulation 25A; we’ll cover those in a separate article on stability.
Other documents required onboard
This isn’t under MARPOL, but under the Merchant Shipping Act 1995 (Section 163 and 164) ships carrying more than 2000 tons of oil must have onboard a certificate issued by the secretary of state confirming that she has civil liability insurance in force for pollution. Ships over 1000GT must have a certificate of insurance for liability in force for bunker pollution, and a certificate issued by the secretary of state confirming that she has the same. These are mentioned here because, in the answer to the common question ‘what documents does an oil tanker/cargo ship of over x tons have to carry’ these may form part of the answer.
MCAQs
What is MARPOL?
How does MARPOL apply to us, as a UK vessel?
Should a ship report the failure of her steering gear, under MARPOL?
Annex I
When can ships discharge oil in a special area?
Is the Arctic a special area under Annex I?
Explain the different equipment for oil filtering required on different sizes of vessels
What documents must an oil tanker of 3400GT carry onboard under MARPOL?
Explain the phrase en route.
What is the period of retention for an Oil record book?
What documents would you have onboard to comply with MARPOL, as a 3000GT oil tanker?
Who approves the SOPEP plan?