Environmental compliance has always been under review and close monitoring in shipping, thus the industry has introduced numerous of regulations aiming to reduce pollution globally and in specific areas (ECAs, US ports, EU ports, Arctic zones, MARPOL Special Areas etc.). But what happens when economic cost is an obstacle to organizations’ ecological decisions?
There is no doubt that an organisation’s attitude is linked inevitably with additional costs. Antifouling paints means an extra cost for expensive paints. Ballasting of water needs special additions and modifications of tank and pipeline system of older vessels and more specified and complex mechanisms ballasting-deballasting for the new. Use of low sulfur fuels is costly and are inevitable expenses as well. All the above combined with a number of additional eco-practices constitute a big dilemma for operators to decide whether is preferable to comply with regulations or not.
At this crossword, the presence of Port State Control is vital. PSC aims to eliminate the substandard shipping while it motivates operators to abide to international and regional regulatory. This means that vessels should not only follow regulations but also to keep records and complete appropriate forms and logbooks demonstrating an environmental friendly activities during their voyage. As an example may be used the fact that one of the identified Clear Ground for More detailed inspection by a PSCO is the absence or failure to demonstrate the ODME records of tanker vessels.
Key areas of environmental compliance
Currently, the main categories of inspections focused on environmental regulation compliance that PSC insist on are the following:
Aiming to the prevention of environmental pollution, MARPOL with its six Annexes bring to the fore matters of ecological attitude, urging ship companies for compliance.
- MARPOL Annex I refers to oil pollution prevention during operations as well as accidental discharges. Port state control usually review SOPEP/SMPEP compliance, documentation, record keeping, and Oil spill fighting equipment. A SOPEP drill may also be conducted.
- MARPOL Annex II is introduced for bulk carriers with dangerous noxious liquid substances carriage. According to this regulation residues containing noxious substances are not allowed to discharge within 12 miles of the nearest land. Documentation review and procedures are included in PSC inspection
- MARPOL Annex III is also issued in order to prevent pollution caused by harmful carriage in a packaged form. Port State Control inspects the existence of proper equipment that reduces risk on board and also techniques and loading-unloading practices that are followed by the crew.
- MARPOL Annex IV covers the prevention of pollution by sewage as requires that ships are prohibited to discharge sewage at the sea. The condition and operational status of Sewage treatment system (if applicable) and crew familiarity will be checked. Appropriate documentation and compliance with discharge distances is also targeted by PSCOs.
- MARPOL Annex V aims to deal with the problem of garbage existing in oceans. Port State Control inspects the Garbage Management Plan followed onboard and ensures that crew members manage to store the garbage in ways that don’t harm the environment.
- MARPOL Annex VI is about air emissions. The sulfur content in fuel is the main concern for PSC and compliance of change over procedures, implementation and record keeping will be checked. The fuel noncompliance within special areas is a high marked detainable item.
- Ballast Water Management
According to MOU reports, most deficiencies related to Ballast Water Management are because of one of the following:
- Not properly filling and record keeping of the actions been taken
- Incorrect ballast water exchange
- Not approved plan
- Lack of appropriate familiarization
Since BWMC implementation, the Port State Control has been focusing on BWMS installation, operation, training and record keeping.
By the time EU-MRV first reporting period (31 December 2018) took place, Port State Control would check approved plans, records keeping, reports and monitoring processes to be as appropriate.
- Energy Efficiency
Since 2013 the Ship Energy efficiency Management plan has been introduced to industry. During 2019 the part II of SEEMP including Data Collection System for emissions will be a part of PSC focus on environmental compliance.
- Actions taken by MOUs
Using the Concentrated Inspection Campaign (CIC) tool Paris MoU supported by other MoUs also organized a MARPOL Annex VI focused campaign currently running (for 1st September to 30th November). An eleven topics questionnaire has been issued and is used during inspections aiming to check the compliance on fuel oil use, handling, sampling and air emissions, including appropriate record keeping
- Challenges ahead
Compliance to Environment Regulations is a challenge for industry and these requirements are not always followed by all as in some cases it’s been observed a violation of such regulations. Compliance is considered to be difficult because companies are obliged to implement an improvement of design and operation of ships to ensure that they produce the minimum impact on environment. This can be achieved taking into consideration the following:
- Goals of compliance should be set by Top/Senior management
- Trained personnel
- Record keeping is always a good guide for crew and the objective evidence during inspections
- Lessons learned extracted from incidents related to environment are useful in order to avoid same mistakes in the future
- Continual periodic audits in order to verify that company (and vessels) complies with the regulations.
Compliance is critical for the future of environment and moreover it constitutes mirror of a well-organized organisation. All stakeholders should understand that the cost of a polluting accident is always bigger than the cost of compliance.