The oily water separator

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					The oily water separator
An unlikely indicator for safety and quality
                                                                                               G waste output versus volumes purchased
Captain Paul Drouin MNI
                                                                                               analysis; and
Marine accident investigator and                                                               G minimising or eliminating leakage.
Principal at
                                                                                               Why an indicator’?
                                                                                               If the steering wheel of your new car came
Safety and quality, one may ask? Isn't the purpose of an                                       off in your hands as you were driving down
oily water separator (OWS) to protect the environment?                                         the road, it would certainly raise questions
                                                                                               about how the steering wheel itself had
  Of course it is – but if ever there were a distinct point at
                                                                                               been installed. But would it not also raise
the intersection of the three grand themes of safety, quality                                  questions as to the safety and quality of
and environmental protection, it is the OWS. And, although                                     that car in general? If a company says it is
                                                                                               committed to environmental protection but
this equipment is usually out of sight and out of mind,
                                                                                               does not train their crew in these matters
maybe it should be more in the thoughts of marine                                              or audit for compliance, does this raise
superintendents and designated ashore. Located deep in                                         questions about their commitment to
bowels of the vessel, this most unlikely indicator reveals                                     safety and quality as well? I think it most
                                                                                               surely does.
much in the way a vessel and a company ‘walk the talk’                                             One of the basic principles of quality
(or not) of their ISM commitments.                                                             management is leadership. Regardless of
                                                                                               the company or organisation, large or small,
                                                                                               it is the leaders who start the quality ball
      he overarching concepts on oil                                                           rolling. They establish ‘unity of purpose’ and

T     discharge, oil residues and OWS are
      simple enough:
                                                  ISM requires a company to establish
                                                  a safety and environmental-
                                                                                               set the course for the organisation. The
                                                                                               leaders are instrumental in creating and
                                                                                               maintaining a culture in which all employees
  1                                               protection policy. Regardless of the         are motivated and proactive in achieving the
  Marpol regulates discharge of oil               specific wording of the company's            organisation's objectives.
  from machinery spaces such that,                policy, the overriding objective with            For shipping companies, one of those
  outside of special areas*, oil                  respect to the environment is the            objectives must be the protection of the
  discharge is prohibited except when;            avoidance of damage to the marine            environment. The leadership, be they
  G the ship is proceeding en route;              environment. This automatically              ashore or onboard, cannot pay lip service
  G the oil content of the effluent is            infers an absolute intolerance to any        to environmental protection and all the
  less than 15 ppm; and                           deviations of practice with respect to       while turn a blind eye to deviations in
  G the ship has in operation an oil              Marpol. None. Zero.                          practice. This not only undermines their
  discharge monitoring and control                                                             credibility, but it reveals to all crew the
  system and oily-water separating/                These overarching concepts are simple       contradictions between the ideals touted
  filtering equipment.                          enough. However, the tasks and                 by the company and the real state of
  (*inside special areas the restrictions are   requirements that relate to the fulfillment    affairs. If these contradictions exist the
  more stringent)                               of the objective may be less so. These         crew will intuitively understand that it is
                                                include, among others;                         OK to cheat or take shortcuts.
                                                                                                   So, if I were to do an audit for safety
  2                                             G creating     useful and complete
                                                                                               and quality on a ship, I would start by
  The operation of any ship will most           procedures for all oil and oil waste related
                                                activity;                                      heading straight for the engine room and
  assuredly bring about a certain
                                                G properly completing the oil record book;     the OWS. I would ask the chief engineer
  amount of oil residues (sludge) that
                                                G training in Marpol compliance and            and other senior engine room staff about
  must be accounted for. There are a
                                                issues;                                        its operation. I would ask to see sounding
  limited number of ways of accounting
                                                G maintenance and operation of the OWS,        records and the oil record book. I would
  for oil residues:
                                                including adequate testing;                    ask about the training they have received
  G they have been transferred to
                                                G maintenance and operation of the oily        in respect of the use of the OWS and
  reception facilities ashore;
  G they have been retained on board;
                                                residue incinerator;                           Marpol requirements. I would look for
  G they have been incinerated.
                                                G scrupulous record keeping of tank            discrepancies in waste output versus
                                                soundings;                                     quantities purchased, as well as OWS
Seaways May 2009
output parameters versus oil record book          tank and into barrels. Master could not        discharge of sludge was required. The
entries. I would query the crew on their          account for the origin of the oil within the   company failed to take appropriate action.
perceptions of the environmental                  tank.                                          I An unauthorised discharge bypass
protection procedures and on the                  I Oily water discharge piping leading to       device was discovered. The bypass was
prevailing culture of compliance on issues        the overboard discharge of the OWS was         used to discharge sludge and oily bilge
pertaining to Marpol. If red flags are raised     found to contain thick oil sludge. While       waste into the ocean using the fresh water
around the OWS, it clearly indicates a lack       demonstrating operation of the OWS,            generator discharge piping by connecting
of commitment to the ideals of ISM – hence        crewmembers bypassed the oil sensing           to a portable pump.
to both safety and quality in other areas of      device.                                        I OWS is inoperable posing a hazard to
vessel operations.                                I Excessive oil discovered throughout the      the environment.
                                                  engine room machinery spaces created a            This is truly a shameful litany of blatant
Legally speaking                                  serious fire hazard.                           disregard for the environment. But non-
If consistency and commitment to the ideal        I The vessel has a modified sludge             conformities such as these do not happen
of environmental protection are not               transfer piping system that allows transfer    in a vacuum. Deviations of this proportion
motivation enough; if the carrot of quality       of sludge into two lube oil storage tanks      can only persist on a vessel with the tacit,
management and customer satisfaction              that are not recognised in the vessel's        if not active, accord of company
(among others) is insufficient – then the         international oil pollution prevention         management and vessel leadership. It is
stick of legal tribunals may add urgency to       (IOPP) certificate.                            clearly a failure of leadership that is at the
the equation. On 20 January 2009, the             I Crew was not familiar with essential         nexus – and when present, this failure
American courts confirmed their wide              shipboard procedures relating to the           cannot reasonably be confined to Marpol
jurisdiction over foreign flag vessels, even if   prevention of pollution as evidenced by the    issues but most probably extends to safety
no discharge has taken place in US waters         crew making several attempts to flush and      and quality as well.
or if incorrect entries in the oil record book    clean the OCM without success.
have been made, anywhere at any time.             I Vessel crew has installed a manifold         It's human nature
                                                  onto the arrangement’s discharge side          The Maritime International Secretariat
                                                  sludge transfer pump. The manifold has         has published a six page pamphlet that,
  ‘It will be increasingly important for
                                                  four discharge connections, allowing the       although beguilingly simple, is chock-full of
  shipowners and managers to be
                                                  transfer of sludge from the sludge tank to     very effective guidance on the use of the
  vigilant      in   enforcing    their
                                                  the bilge tank and several unauthorized        OWS. Freely available online at
  environmental compliance programs,
                                                  tanks.                                it is highly
  identifying and correcting improper
                                                  I The vessel has multiple overboard            recommended reading for both
  discharge practices, and ensuring
                                                  discharge connections. An additional valve     management and shipboard personnel.
  that a vessel’s required records are
                                                  and flange connection was added to the         One line in the pamphlet brings to the fore
  accurate and verifiable.”
                                                  discharge manifold of the vessel's sludge      some interesting undercurrents that are
  Maritime Alert, 6 February 2009,
                                                  pump to rig additional portable pump for       worthy of further investigation:
  Holland & Knight LLP (US law firm)
                                                  discharge operations.
                                                  I The vessel's crew was transferring fuel
   As a signatory to the Marpol                   oil (FO) sludge into oily water tank. Oily       ‘Ship operators have ultimate
Convention, the US has taken an                   water tank not recognised by IOPP                responsibility for establishing a
aggressive stance on policing for                 certificate for sludge storage. Crew stated      compliance culture within their
compliance. And it is easy to see why. A          insufficient storage for sludge. Total           companies, and it is important that
quick overview of the port state control          approved capacity for sludge oil is 2.2          every effort is made to ensure that
detentions conducted by US officials in           cubic meters.                                    seafarers do not engage in any illegal
2008 reveals the following;                       I Tanks designated for oil residues are at       conduct in the mistaken belief that it
                                                  (or near) maximum machinery spaces               will benefit their employer.’
PSC findings                                      capacity and are inadequate for the ship's
I The oily water separator system failed          intended voyage.
to operate equipment properly when                I The vessel's sludge oil storage tank's          Both a ‘compliance culture’ and ‘the
tested. Oil content meter (OCM)                   water connection stripping pipe has been       mistaken belief that it will benefit their
continually flashes alternating error codes       modified. A section of the piping was          employer’ are different keys to the same
indicating ‘repairs needed’ and                   removed, and a flex hose was installed         lock. It is human nature to try to do the
‘contaminated water’.                             allowing for the transfer of sludge            right thing, to do well in the eyes of one’s
I Oil record book not maintained and              anywhere.                                      employer. If training and guidance on the
with improper entries. Oil record book            I The vessel has insufficient capacity for     use and maintenance of the OWS is
contains one page for the past five years         the storage of sludge oil. This lack of        lacking; if shore-based management are
and there are no receipts for discharge           capacity resulted in the vessel making         never on board asking questions; if audits
ashore.                                           unapproved modifications to the sludge         are not performed on oil consumption and
I Crew is not familiar with essential             tank piping.                                   oily residue management – then the crew
shipboard procedures relating to the              I Vessel's safety management system has        will take it upon themselves to do the ‘right
prevention of pollution by oil.                   failed to ensure protection of environment.    thing’ which, at the end of the day, may well
I Aft peak ballast tank was used                  On multiple occasions, the chief engineer      be the wrong thing. Through their inaction
incorrectly as a sludge tank. PSC officers        reported to company that the vessel's          and silence, management will have
observed crew bailing oily water out of           sludge storage was nearing capacity and        telegraphed their intentions to the crew.

                                                                                                                          Seaways May 2009
   And what better example of the above
than the US Coast Guard itself. In 2007, a
                                                anyone can. Both the lack of a compliance
                                                culture and the mistaken belief that their      For your diaries
former chief warrant officer in the US Coast    actions would benefit their employer were
Guard, a main propulsion assistant on a         probably central in this and many other         (07) UK, Solent Branch, Warsash Maritime
Coast Guard vessel, was indicted for lying      examples of OWS bypass scenarios.               Academy, Evening meeting: e-Navigation:
to federal criminal investigators about his                                                     enhancing safety, security and protection of
knowledge of the direct overboard                                                               the marine environment;
discharge of bilge wastes into the sea.
                                                Conclusion                                      Tel: 0207 9281351 email:
                                                For companies of goodwill that want to do
   His rank and duties made him one of                                                          (13-14) Latvia, Maritim Park Hotel, Riga, 12th
                                                the right thing, nothing could be easier
the key persons in the engine room                                                              European Manning and Training Conference;
                                                than to audit or give unambiguous               Tel: +44 (0)20 7017 5511
hierarchy. He later admitted having
                                                guidance in respect of the management of        email:
knowledge of the direct discharge of bilge
                                                oily residues. Simply put, all sludge must      (15) Ireland, Matheson Ormsby Prentice
wastes overboard. In all likelihood he
                                                be accounted for, all transfers                 (Solicitors), 70 Sir John Rogerson's Quay,
could not have acted alone: some other
                                                documented, and testing of the OWS must         Dublin 2. Irish Maritime Law Association
engine room personnel must have assisted
                                                be an ongoing affair. Training in the use of    Seminar Shipping - Prospects, Pollution and
in the practice, because a reconfiguration
                                                the specific equipment and in the               Piracy; email:
of engine room equipment was necessary.
Apparently, bilge wastes were transferred       requirements of Marpol is necessary. But        (18) UK, SE England Branch, Royal Cinque
from the aft bilge to the deep sink and then    the equipment must also be of quality,          Ports Yacht Club, Waterloo Crescent, Dover,
overboard, bypassing the OWS.                   function as designed and have enough            Branch AGM followed by Return from the
   But beyond the persons directly involved     resources assigned to ensure proper             Antipodes; Tel: 01304 372192
in the practice, what of the vessel's master    operation. If the OWS is malfunctioning –       (19) UK, North of Scotland Branch, Shell
and chief engineer? At the very least, they     expect to pay for pumping out at shore          Woodbank, Aberdeen, Annual General
obviously did not ask the right questions.      reception facilities. Simply put, that is the   Meeting; Tel: 01339 741285
What of shore management? They most             cost of doing this business.                    email:
evidently were not preoccupied with                Any company official who wants to            (19-20) The Netherlands, Amsterdam Hilton
ensuring compliance. As is often the case,      know how they measure up with respect to        Hotel, Tugnology '09; Tel: +44 (0)1225 868821
operational personnel are targeted first        environmental protection has only to step       email:
and foremost as guilty parties – yet the true   on to the deck plates of the engine room        (19-20) UK, London, 2nd Maritime Corporate
cause of the failure is actually much higher    and ask a few questions about the OWS.          Social Responsibilty; Tel: +44 (0) 20 7369 1656
                                                But the answers to such questions go far        email:
up the ladder. But my point here is
                                                beyond how the company is doing with            (19) UK, SW England Branch, Royal Plymouth
somewhere else. If Coast Guard employees,
                                                environmental protection. They will also        Corinthian Yacht Club, Madeira Road, Plymouth
with all of the resources and training that a
                                                                                                AGM followed by The Isolated Mariner;
top-notch organisation such as the USCG         likely indicate how it measures up in both
                                                                                                Tel: 01752 585701 email:
can muster, make these bad decisions –          safety and quality.
                                                                                                (19-21) The Netherlands, Amsterdam, Ballast
then, given similarly poor leadership,          I
                                                                                                Water Management; Tel: +44 207 981 2504
                                                                                                (25-29) Italy, Cotone Congressi Genova,
                                                                                                Genoa, IAPH World Port Conference;
                                                                                                Tel: +44 (0) 20 7017 4378
                                                                                                (26-29) Singapore, Grand Copthorne
                                                                                                Waterfront Hotel, Seafarers 2009 - Financial
                                                                                                Crisis Today, Human Crisis Tomorrow - Are
                                                                                                We Heading That Way?; Tel: (65) 6514 3180
                                                                                                (27) Piraeus, Hellenic Branch, Afternoon
                                                                                                meeting - Paperless Navigation;
                                                                                                Tel: 30 210 4292964 email:

                                                                                                (09) Antwerpen, Belgium Branch, Antwerp
                                                                                                Maritime Academy, Noordkasteel Oost 6,
                                                                                                2030 Antwerpen, The Human Element;
                                                                                                Tel: + 32.3.458.29.30
                                                                                                (09) UK, Southampton Master Mariners Club,
                                                                                                12-14 Queen's Terrace, Southampton,
                                                                                                SO14 3BP, Solent Branch AGM;
                                                                                                Tel: 0207 9281351 email:
                                                                                                (11-12) UK, Trinity House, Newcastle,
                                                                                                Nautical Institute AGM and MARS Seminar;
                                                                                                Tel: 0207 9281351 email:
Seaways May 2009

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