Oily Water Separator Systems: Practical Advice

© chokniti / Adobe Stock

By Matthew Bonvento

Magic Pipes, 15 PPM alarms, crew familiarization, improper
entries in the oil record book, oil record book not maintained:
these are all terms used by various Port State Control (PSC)
officers worldwide when referencing the oily water separator.
When PSC so decides, it also has the option of making one of
these an ISM deficiency, adding another black mark against a
vessel. Nevertheless, even with such an important piece of
equipment and the records documenting its proper use, both are
often neglected. Avoiding the pitfalls associated with this
mandatory equipment is an important skill to learn, even in the
case of the sharpest, most dedicated engineer.

The origin of the requirement for an oily water separator system
comes from the International Conference on Pollution of the Sea
by Oil, written on May 12, 1954. Article III of the convention
lays out the groundwork for the discharge of oily waste from a
vessel. The standards of the 1954 conference have evolved
significantly over time, eventually becoming the more stringent
standards of today. For example, in 1954, the standard discharge
from a vessel could be no more than 100 parts per million.
Today's standard is just 15 ppm. The convention also heralded the
first time that the use of an oil record book had been required.
The original conference was a U.K. requirement and laid the
foundations of MARPOL Annex I. This U.K. conference was one of
the foundations of our current oil pollution prevention
standards. For the purposes of this primer, 50 engineers of
various ratings - from QMED to chief engineer - the engineering
departments of two maritime universities, as well as an oily
water separator OEM were all surveyed. Virtually all of the
engineers surveyed stated that the only training received on
board was familiarization training from their relief or the chief
engineer, with only a few receiving training at their national
maritime university. Out of 50 engineers surveyed, 58 percent of
them believe that more extensive training is necessary. The other
42 percent are satisfied with the traditional model of on board
training and familiarization given by the chief engineer. The
engineers wishing for more training requested better
OEM-generated manuals, DVDs and/or flash drives. Some engineers
would like to see a manufacturer representative on board to
conduct instruction in the use of the OWS, as well as further
instruction in to the requirements of MARPOL Annex I.

In looking at the Paris and Tokyo MOUs, only about two percent of
the deficiencies noted by Port State Control had anything to do
with MARPOL Annex I in the years 2013 and 2014. That said; of all
the Port State Control Form Bs reviewed, nearly all involved
non-functioning, malfunctioning, or bypassed Oily Water
Separators, which resulted in a detention.

While it is possible to receive a dispensation for repairs from
the flag state, that's not always the case, and a vesseldetained
awaiting parts and repair can cost valuable time and money.
Additionally, these types of detentions can trigger the Flag
State or Recognized Organization to require an Intermediate ISM
audit. That's because an infraction into vessel pollution is
almost inevitably considered a safety management deficiency as
well. The devil is in the details, but when it comes to Coast
Guard, PSC, and/or accident inspections, one thread becomes very
clear: the oil record book is the gateway into determining if the
oily water separator is actually used, and if it is used, is it
used appropriately. MEPC.1/Circ 736/REV.2 provides instructions
and examples in to the proper entry requirements of the oil
record book.

Addressing this situation head on, the 58 percent of engineers
who wish to see change would like to see the equipment manuals on
board with colored picture diagrams, as well as have the units
labeled and color coded to ensure that each part of the system
can be easily identified. Adjustments such as these are easy
enough to implement at very little cost to the vessel owner or
manager. The remainder of the engineers expressed a desire for
more detailed training provided at either the university or the
company level. Not to sound like a disgruntled deckie, but if we
were to look at what the requirements that are under Table A/II-1
and Table A/II-2, ECDIS is a standalone requirement going so far
as to require deck officers to have the training in the type
specific units that are on board the vessel. The IMO believes
that type specific and generic training, working in conjunction
with each other, is necessary to reduce the amount of casualties
that can be caused by the over reliance on ECDIS. Having sailed
on a number of vessels with ECDIS, prior to the carriage
requirement, the only way to learn the system prior to these
requirements was to read the manual and hope that your relief
left decent turnover notes. In my experience this often left to
conflicting use of the system by the various officers of the
watch who may have been shown the usage of the system
differently.

Looking at OWS systems as critical equipment - like GMDSS, or
ECDIS, for example - then it would follow that at the very
minimum there should be a generic training covering the basic
science such as the physics and principles behind the operation
of the OWS system. Another overlooked aspect of this issue
involves such variables such as the types of oils, lubricants,
detergents - which vary greatly from vessel to vessel and port to
port - and their collective impact on the hardware. Engineers not
equipped with the knowledge of how this plays a factor in
operations will have a difficult time operating the same
equipment with competence, or in compliance.

As we progress with technological advances, toward more unmanned
machinery and autonomous operations, greater burden will be
placed on those left on board to run this critical equipment. If
more than half of the engineers surveyed believe that we should
be doing more in regards to training, then perhaps it is time to
listen to them.

The Author

Matthew Bonvento is the Senior Manager for Safety, Security,
Regulatory, and Quality Compliance for Vanuatu Maritime Services
Ltd. Additionally he is a licensing instructor in Long Island. He
holds a Masters in International Transportation Management, and
an Unlimited Chief Officers License as well as a 1,600-ton Master
license.

Mar 3, 2017

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