March 11, 2014
Ships adhering to MARPOL Annex I within the CMOU region
From September 1, 2013 to November 30, 2013, the Caribbean MOU carried out a Concentrated Inspection Campaign (CIC) on MARPOL Annex I regulation 14 arrangements on board ships. This campaign involved nine (9) member States and one (1) Associate Member State of the Caribbean MOU. The CIC was designed to investigate the operability of the oil filtering equipment (OFE) systems and to find out whether sludge has discharged into port reception facilities, burnt in an incinerator or in an auxiliary boiler suitable for burning oil residues, mixed with fuel or other alternative arrangements.
The campaign targeted compliance with the vital points of the requirements of Annex I (Regulations for the Prevention of Pollution by Oil) of the International Convention for the Prevention of Pollution from Ships (MARPOL) to an acceptable level. The campaign was designed to examine a specific area and not intended to detract from the normal coverage of port State control inspections. As such, the CIC was conducted in conjunction with the regular port State control targeting and inspection activities as outlined by the Caribbean MOU.
Preliminary results from this inaugural CIC carried out in the CMOU region indicated that when looking at the objective of the CIC, that is to verify that the Oily Water Separator and Discharge Monitoring systems are installed on board ships in accordance with MARPOL Annex I, it can be reasonably concluded from the results that the level of compliance was very high as most vessels complied with the requirements and there was a limited amount of deficiencies identified and no detentions recorded.
During the course of the campaign, nine (9) member States and one (1) associate member State carried out 250 port State control inspections on individual vessels. Of these PSC inspections, 182 vessels were inspected for the CIC and no vessels were detained. The questionnaire submission rate was good with 73% or 7 out of 10 inspections were accompanied with the CIC questionnaire. In addition, a total of thirty-three (33) deficiencies were recorded as a direct result of this campaign. As per the procedure of the CIC, each individual vessel only had one CIC performed for the period.
When examining the breakdown of ships inspected by ship type, the largest groups of ships inspected during the campaign period were oil tankers with 58 inspections (31.9%) followed by container ships with 30 inspections (16.5%). Of the 182 vessels inspected, thirty-two (32) vessels were found with deficiencies. Of these 31 vessels, Oil Tankers had the highest percentage at 21% of total deficiencies.
With respect to the ship’s flag, there were a total of 182 vessels from 30 flag administrations inspected during the campaign. Panama had the highest number of vessels inspected at 17% followed by Liberia at 13.2%. In addition, Panama had the highest amount of deficiencies identified with 22%.
Data with respect to the results of the CIC in accordance with the ship’s recognised organisation (RO) was also compiled. The total of 182 vessels inspected during the campaign was from 15 different ROs. The results show that 41 or 23% of the vessels inspected under the CIC had Lloyd’s Register as their recognised organisation. This is closely followed by Germanischer Lloyd at 40 or 22% of the vessels inspected.
It was positive to see that there were no major deficiencies identified and no detentions recorded. It is to be noted however that one ship inspected did have major non-conformities and many detainable deficiencies. The vessel however could not be detained under the CIC as the inspecting Member State did not have the requisite MARPOL legislation. The vessel however was detained under other environmental legislation of the State. This therefore illustrates the need to ensure that the relevant IMO conventions are ensconced in the national legislation of the States.
Member States are thereby encouraged to have the IMO Mandatory Instruments enacted in their domestic legislation. This will only further assist the port State control officers in executing their duties and also will further strengthen the ability of the maritime administration to fulfil its obligations.
The results of the campaign and the will be presented to the governing body of the CMOU for submission to the IMO.
Mrs. Jodi Munn-Barrow
12 Ocean Boulevard
2nd Floor, the Office Centre Building
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