Section 17.1 Annex I: Prevention of Oil Pollution (SOPEP, Bilge Water Management)

MARPOL Annex I focuses on preventing pollution by oil from ships. For bulk carriers, this primarily relates to oil from machinery space bilges (fuel oil, lubricating oil, hydraulic oil, etc.) and fuel oil tanks (bunkers). While bulk carriers do not typically carry oil as cargo, the principles for preventing operational oil spills are paramount.

Key Requirements and Aspects for Bulk Carriers:

1. Shipboard Oil Pollution Emergency Plan (SOPEP):

Mandatory Requirement: All ships of 400 gross tonnage and above (which includes all bulk carriers) are required to carry an approved SOPEP.

Purpose: The SOPEP provides detailed procedures and guidance for the Master and crew on how to respond to an oil pollution incident. It aims to prevent or minimize oil outflow in the event of damage to the ship or an operational spill.

Content: A SOPEP typically includes:

Procedures for reporting an oil pollution incident (to coastal states, port authorities, company, etc.). This section should contain a list of authorities or persons to be contacted.

Steps to be taken to control discharge (e.g., operational spills during bunkering, bilge discharge).

Procedures for coordinating with national and local authorities to combat pollution.

Ship-specific drawings of fuel and oil piping systems, tank locations, and SOPEP equipment locations.

Inventory of SOPEP equipment (e.g., sorbents, non-sparking hand pumps, containers, protective gear).

Familiarity and Drills: The crew must be familiar with the SOPEP, and regular drills should be conducted to ensure preparedness. These drills should be recorded.

Approval: The SOPEP must be approved by the Flag Administration or a Recognized Organization (RO) acting on its behalf.

2. Machinery Space Bilges and Oily Water Separating Equipment (OWS):

Zero Discharge in Special Areas (unless stringent conditions met): In designated “Special Areas” (e.g., Mediterranean Sea, Baltic Sea, Antarctic area), any discharge of oil or oily mixtures from ships is prohibited, except under very specific conditions (e.g., processed through an OWS ensuring effluent is less than 15 ppm, ship is en route, not within 12 nautical miles of land, and has an Oil Filtering Equipment monitoring and alarm system).

Discharge Outside Special Areas:

The ship must be en route.

The oily mixture must be processed through an approved OWS.

The oil content of the effluent without dilution must not exceed 15 parts per million (ppm).

For ships over 400 GT but less than 10,000 GT, the discharge must not originate from cargo pump-room bilges on oil tankers. For ships 10,000 GT and above, the equipment must also be fitted with an alarm and automatic stopping device if the 15 ppm limit is exceeded.

Oil Filtering Equipment (15 ppm Equipment): Bulk carriers must be fitted with approved oil filtering equipment (OWS) that produces an effluent with an oil content not exceeding 15 ppm. This equipment must be regularly maintained and tested.

Oil Content Meter (OCM) and Alarms: The OWS is typically fitted with an OCM that continuously monitors the oil content of the effluent. If the oil content exceeds 15 ppm, an alarm will sound, and an automatic stopping device should prevent the overboard discharge.

Standard Discharge Connection: Ships must be fitted with a standard discharge connection for transferring oily bilge water to reception facilities.

3. Oil Record Book (ORB) – Part I (Machinery Space Operations):

Mandatory Requirement: All ships to which Annex I applies must maintain an ORB Part I.

Purpose: To record all operations involving oil or oily mixtures in machinery spaces. This provides a transparent record of how oil and oily water are managed onboard.

Entries: Detailed and accurate entries must be made without delay for operations such as:

Bunkering of fuel or lubricating oil.

Collection, transfer, and disposal of oil residues (sludge).

Discharge of bilge water to sea or to reception facilities.

Accidental or other exceptional discharges of oil.

Failures of the oil filtering equipment.

Accuracy and Integrity: The ORB is a critical legal document. Entries must be accurate, signed by the officer(s) in charge of the operation, and countersigned by the Master. Falsification of the ORB can lead to severe penalties.

Retention: The ORB must be kept onboard for a period of three years after the last entry has been made.

4. Management of Oil Residues (Sludge):

Sludge Tanks: Ships must be equipped with sludge tank(s) of adequate capacity to receive oil residues (sludge) from the purification of fuel and lubricating oils and from oil leakages in machinery spaces.

Disposal: Sludge cannot be discharged overboard. It must be disposed of by:

Incineration in an approved shipboard incinerator (subject to Annex VI regulations).

Discharge to port reception facilities.

Other approved means (e.g., burning in auxiliary boilers if permitted and designed for it, though less common on modern bulk carriers).

Records: All operations involving sludge (collection, transfer, incineration, discharge ashore) must be meticulously recorded in the ORB Part I.

5. Fuel Oil Tank Protection (for new ships):

MARPOL Annex I includes regulations concerning the location of fuel oil tanks on new ships (delivered on or after 1 August 2010) to minimize the risk of oil spills in case of collision or grounding. This typically involves requirements for double-hull protection or equivalent measures for fuel oil tanks.

6. Bunkering Operations:

Pre-Bunkering Procedures: Before bunkering, a pre-transfer conference should be held between the ship and the bunker supplier to agree on procedures, communication methods, emergency signals, and spill response actions. A pre-bunkering checklist should be completed.

Spill Prevention:

Ensure scuppers are plugged.

Have SOPEP equipment readily available at the bunker station (e.g., drip trays, sorbents, non-sparking tools).

Maintain proper watch on tank levels, pipelines, and connections.

Establish clear communication between the ship and the bunker barge/terminal.

Emergency Shutdown: Ensure procedures are in place for emergency shutdown of the bunkering operation.

Recording: All bunkering operations must be recorded in the ORB Part I.

7. Surveys and Certification:

International Oil Pollution Prevention (IOPP) Certificate: Ships of 400 GT and above must be surveyed and issued with an IOPP Certificate, which confirms compliance with Annex I. This certificate is subject to initial, annual, intermediate, and renewal surveys.

Condition of Equipment: All equipment related to Annex I (OWS, OCM, pumps, piping, SOPEP equipment) must be maintained in good working order and be ready for use at all times.

Best Practices for Bulk Carriers:

Proactive Maintenance: Regularly maintain the OWS, OCM, pumps, and associated piping to ensure optimal performance and prevent failures.

Crew Training: Ensure all engine room crew are thoroughly trained in the operation and maintenance of the OWS, the proper procedures for bilge water management, and the accurate completion of the ORB. All crew should be familiar with the SOPEP.

Strict Adherence to Procedures: Implement and enforce strict adherence to company procedures for bilge water management, sludge handling, and bunkering.

“Clean Bilge” Policy: Strive to minimize oil leakage in machinery spaces through good housekeeping and prompt repair of any leaks. This reduces the load on the OWS.

Vigilance During Bunkering: Treat bunkering operations with utmost seriousness to prevent spills.

Regular Drills: Conduct frequent SOPEP drills and bilge spill response drills. Compliance with MARPOL Annex I is not just about avoiding penalties; it’s about protecting the marine environment from oil pollution, a responsibility that lies with every individual onboard a bulk carrier.