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Errors in Oil Record Book Part I Entries

21 Οκτωβρίου, 2013 | Posted by admin in Χωρίς κατηγορία - (Δεν επιτρέπεται σχολιασμός στο Errors in Oil Record Book Part I Entries)

 

OIL RECORD BOOK PART I

Refer to MEPC 1-Circ 736_rev.2 always.
Ship Inspectors (FSC / PSC / Vetting) frequently mention in their Reports improper maintenance of the Oil Record Book (ORB) to Masters and Chief Engineers and about the importance of correctly maintaining the ORB during their visits on board entered vessels.

Sludge can be easily calculated. As a rough guide, approximately 1% (one percent) of fuel shipped, ends up as sludge. This would include all HFO (Heavy Fuel Oil), MDO (Marine Diesel Oil) and LO (Lubricating Oil).

The inspecting authorities SIMPLY wish to be able to see clearly that the total oil shipped plus the oil already on board, less the main engine consumption for that voyage equals the total oil remaining on board (ROB) plus the sludge ROB.

( ROB + bunkered fuel ) – M.E. cons. = ROB + sludge

It is simple arithmetic to add up the amount that should be on board compared with the amount ‘said to be’ disposed. If the figures are not as required and the Inspecting Authority have to hunt for the figures and try to figure out the totals – this gets them suspicious.
In this case you are guilty until you can prove your innocence.

Also sometimes Class may not properly annotate the IOPP certificate and Supplement ‘B’ to include the incinerator and/ or the capacity of the OWS. Thus the ship may be incinerating the oil but according to the IOPP certificate there is no incinerator on board and although you may protest your innocence the Inspecting Authority assumes you have pumped it overboard.

And there is a fine to help concentrate the mind and get the paperwork right next time. !!

ORB entries
Correct entries must be made as per the MEPC 1-Circ 736_rev.2

Sludge retention
Entries under C 11.1 sludge retention and the entries required at the end of a voyage (or weekly if the vessel is on short sea trade) are frequently overlooked and do not include the total ROB sludge. Simply on arrival at any port, if the vessel has been on a passage for more than seven (7) days, then a detailed entry of ALL sludge ROB on a tank by tank basis is required. Vessels on short sea trade or coasting vessel make a weekly entry.

C11.4 entry, in effect from 01st January 2011:

Please refer to the notes in the example #2 in MEPC 1-Circ 736_rev.2  as here below:
Note: Operator initiated manual collection where oil residue (sludge) is transferred (transfer with a pump) into the oil residue (sludge) tank(s). Examples of such operations could be:
1. Collection of oil residue (sludge) from fuel oil separator drain tanks.
2. Collection of oil residue (sludge) by draining engine sump tanks.
3. Adding fuel oil to an oil residue (sludge) tank (all content of a sludge tank is considered sludge).
4. Collection of sludge from bilge water holding tanks – in this case a disposal entry for bilge water is also needed.
So long as CE or his representative has not initiated a manual draining, it need not be written.
Code C 11.4 is required to be used for recording of oil residue (sludge) collected by manual operation in oil residue (sludge) tank. Sludge should be collected and stored only in tanks listed under item 3.1 in the Supplement to the IOPPC.
Code C 11.4 is not required for recording Weekly inventory of sludge.
However, in case of automatic draining of sludge from seperator / purifiers, it is prudent to make such an entry in a MARPOL record book seperately or put an entry for C11.4 stating – Automatic draining from seperator, as a good faith entry, whenever there is an increase.

This is for two reasons:-
1. It is required by MARPOL and the Oil Record book – Section C11
2. If any pollution was to occur during the vessels stay in that particular port you have written proof of what the ship had on board in terms of sludge – tank by tank. A quick sounding of these tanks by the Authorities will prove that you are not the culprit. If the entries are not made then again you are guilty until you can prove your innocence. This will mean getting the P&I correspondent involved, Surveyors to attend, litigation / verifications and of course in the end totally unnecessary costs incurred by the Shipowner.

Incineration of oily rags should be noted in garbage record book and not in oil record book.

C12.3 is only for incineration of Sludge.

Disposal of Water

Entries under D 15.2 disposal overboard of water in sludge frequently do not contain the time of stopping or the TWO geographical positions required (i.e. at Start and Stopping of the Oily Water separator (OWS)) or an inaccurate estimate of the amount disposed of overboard – e.g. the OWS has been on line for about two hours, has a capacity of 2 cu. m and during this period 10 cu. m have been pumped overboard according to the Chief engineer’s entry in the book. Simple arithmetic again !!

Careful attention to entries and knowledge of the pumps and capacities will easily avoid this.

Bunkering
Entries under H 26 (All Fuels including DO and Lub Oils) frequently do not give the required information requested by the Oil Record Book. Read the instructions !!

Refer to Example 18 of MEPC.1 Circ 736. Specification of fuel and sulphur must be included properly.

Simple – study the front cover or the instructions that come with the ORB or alternatively read the MARPOL Regulations – a copy must should be carried on board. (STCW 1995)
Keep the receipts.
Certificate records of sludge pumped to shore facilities or barges are sometimes not retained with the ORB, are lost or not available

– they should be filed within the ORB – stapled or at the back or a clearly noted record made in the book as to where they are maintained.

Keep it neat – keep it clean
Provided the ORB’s are neat and properly record the information there is generally no problem, but if the records have NOT been entered as required, or it looks like a spider has crawled across the page the result could easily be a fine. Use plenty of space for the entries do not try to cram every entry into one line and always leave space between entries.

Look for the Entries (Code I) related to corrections of earlier entries / additional entries / voluntary informations in the circular MEPC 1-Circ 736.

Read before you sign !!
Masters must be aware that as they sign the bottom of each page they are attesting to the accuracy and correctness of the entries.
The rule is always read carefully before you sign ANYTHING !!

Secure the Book and relevant attached documents!!
Most of the Chief Engineers, Masters and Chief Officers do not realize the importance, but it is better to have the Oil / Cargo / Garbage record books, receipts etc in safe custody of the in-charge. You do not want to face a situation of lost book.

AVOID PUTTING YOURSELF IN PROBLEMS, AVOID FACING CRIMINALIZATION.

Source: http://nautraj.blogspot.gr/2011/06/errors-in-oil-record-book-part-i.html

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Correction of Oil Record Books for Greek vessels

28 Ιουνίου, 2013 | Posted by admin in Χωρίς κατηγορία - (Δεν επιτρέπεται σχολιασμός στο Correction of Oil Record Books for Greek vessels)

The Ministry of shipping,Maritime affair and the Aegean  has issued a circular which refers to the current version of Oil Record Book (Part I) required to keep Greek flag vessels, namely in page 22 thereof. As noted, after paragraph C.11.4 “4. Amount of residue collected by manual operation ……. m3 “, has been omitted by mistake in translation in the English language as follows:” 4. Quantity of residue collected by manual operation ……. m3 “.


To avoid problems for ships by PSC inspectors Ministry of shipping issued in english version explanatory note ( click here to download it) which should be printed and placed at the fron page of ORB / Part 1.

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Port State Control – Crew Familiarisation and Training: a weak area

27 Φεβρουαρίου, 2013 | Posted by admin in Χωρίς κατηγορία - (Δεν επιτρέπεται σχολιασμός στο Port State Control – Crew Familiarisation and Training: a weak area)

In accordance with the ISM Code 6.3 and 6.5, the company managing the vessel must ensure that the ship’s personnel are familiar with their duties and should establish procedures for identifying training needs.

Unfortunately, shipboard audits and port state control results show this to be a weak area. In many cases, the crew is unfamiliar with the ship-specific LSA, FFS and pollution-prevention equipment.

An example that requires ship operators’ attention is the crew’s lack of familiarity with the 15ppm Oil Content Meter (OCM), else known as 15ppm Bilge Alarm and their inability to retrieve the built-in history log when so requested by the authorities.

BACKGROUND
IMO resolution MEPC.107(49) of 18 July 2003 adopted the Revised Guidelines and Specifications for Pollution Prevention Equipment for Machinery Space Bilges of Ships.

Oil-filtering equipment and 15ppm OCM approved by latest standards are fitted to newbuildings with a keel laid on or after 01/01/2005 or to existing ships when the equipment is replaced after 01/01/2005.

One of the new features of this latest technology is that the 15ppm OCM is fitted with a built-in electronic history log. The system automatically keeps records of the equipment’s operations. These records must remain available on board for 18 months for third-party inspections (reference MEPC.107 (49) paragraph 4.2).

The ship’s personnel need to be trained to operate the equipment and should be able to retrieve the history log when requested (reference MEPC.07(49) paragraph 1.1.5 and ISM Code).

DEFICIENCIES
During a port state control inspection, the engine-room personnel (usually the Chief Engineer) might be requested to retrieve the electronic log from the OCM. The records are then compared with the entries in the Oil Record Book.

Inspections reveal that very often the crew does not know how to retrieve the log from the unit. Even worse, the crew sometimes completely ignores the fact that the unit keeps a built-in log of its operations and alarms. On several occasions when the records have been compared to the Oil Record Book, serious inconsistencies have been revealed leading to in-depth MARPOL inspections.

RECOMMENDATION TO SHIP MANAGERS

The company should check what types of equipment it has on board its ship and amend its training procedures accordingly. The crew should be trained on the ship-specific type of OCM and should know how to retrieve the history log from the unit.

The company is further strongly recommended to use this facility of the OCM to check the accuracy of the Oil Record Book entries during its internal on board inspections.

Source: DNV

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New Guidance for the recording of operations in the Oil Record Book-Part I (All Ships)

12 Νοεμβρίου, 2011 | Posted by admin in Marpol | PSC - (Δεν επιτρέπεται σχολιασμός στο New Guidance for the recording of operations in the Oil Record Book-Part I (All Ships))

The Marine Environment Protection Committee, at its sixty-second session,  (11 to 15 July 2011), approved a revised text of the Guidance for recording of operations in the  Oil Record Book Part I – Machinery space operations (all ships) (MEPC 62/24, paragraph 7.23),  set out in the annex.

The Guidance is intended to facilitate compliance with MARPOL requirements  on board ships by providing advice to crews on how to record the various operations in the Oil  Record Book by using the correct codes and item numbers in order to ensure a more uniform  port State control procedure. IMO MEPC.1 Circ.736 Rev.2  dated on 6th of October 2011.

Administrations of Parties to MARPOL are invited to encourage implementation of the  annexed Guidance for use aboard ships flying their flags and to disseminate it among all  stakeholders including ship operators, surveyors and port State control officers.

MEPC.1/Circ.736/Rev.1. is revoked.