There are instances when vessels’ engineers and deck officers, namely senior officers had violated the Act and Regulations. Incidents (i) and (ii) below happened in the respective vessel’s engine room, and incident (iii) happened on the vessel’s deck.

Case study:

i) Bilge Holding Tank liquid transferred to Soot Collection Tank

There was water leaking from the vessel’s ballast water treatment system (BWTS). The water accumulated at the engine room aft bilge well. This water was transferred to the bilge holding tank (BHT) and the liquid in the BHT was further transferred to the soot collection tank (SCT). The above transfers were done by crew using wilden pump with temporary hoses. The senior engineer officer (SEO) deemed that the liquid that was transferred into the SCT (“final content”) had no oil content. The SEO then discharged the final content, treating it as the usual soot collection content, i.e., not having to pass through the oily water separator (OWS), overboard.

ii) Modification of oily water separator (OWS) oil sampling line with fresh water hose

The SEO noted high oil content PPM in the OWS. The SEO gave 4th Engineer (4E) the OWS overboard valve key and ordered the 4E to start the OWS. The SEO then asked the 4E to open manhole of the bilge water holding tank (BWHT) to see the content inside. After opening the manhole, 4E resumed his daily job elsewhere in the engine room. The SEO stated that the BWHT’s content was rust and mud. The SEO then modified the OWS oil sampling line with a fresh water running hose (see photograph below) that was connected to the oil content monitor oil sampling line. After that, the SEO discharge the BWHT’s content overboard through OWS.

iii) Transferring of liquid from residual oil tank to port manifold drip tray and falsifying the oil record book part II

The vessel’s residual oil tank (ROT) was discharged to shore facility. After departure port, it was noted that valves of some piping connections to the ROT was left opened resulting in liquid ingress and filled up the ROT. The senior deck officers (SDO) transferred the liquid to port manifold drip tray (“transferred liquid”). Thereafter, treating the transferred liquid as ‘rain water’, the SDO instructed his crew to rig a hose from the port drip tray drain pipe to drain the transferred liquid to the sea. The SDO then amended the oil record book part II (“ORB”) with false information therein.

Why did it happen?

In all above three incidents, the senior officers concerned stated that through their visual observation, the liquid that was discharge overboard albeit through inappropriate means, had no traces of oil.

Conclusion

Ship owners and managers must take note that their vessel’s senior officers are role models to the junior officers and crew on board. Ignorant junior officers and crew will learn incorrect shipboard practices from their seniors in the aforesaid incidents.

Actions of the above senior officers are not acceptable and contravene the Prevention of Pollution of the Sea Act 1990 (“Act”) and Prevention of Pollution of the Sea (Oil) Regulations 2006 (“Regulations”). For the offence of contravening section 7 of the Act, the offender shall be liable to a fine of not less than $1,000 and not more than $1 million or to imprisonment for a term not exceeding 2 years or to both. For the offence of contravening regulation 9 of the Regulations, the offender shall be liable to a fine not exceeding $20,000 or to imprisonment for a term not exceeding 2 years or to both.

Lastly, it is laudable that most ship owners and managers had voluntarily reporting the above wrongful act. MPA had thoroughly investigated all the cases and appropriate actions had been taken against the wrongdoers.