No.

6/98 SHIP TYPE: Liquefied Gas Carrier SIZE(GRT): 7000

Edited by DTP-245 BUILT YEAR: 1972

MARPOL 73/78 Annex I - blanking bilge discharge from engine room

Course of events During vetting survey of the vessel by a major oil company representative it was pointed out that the bilge system did not comply with MARPOL 73/78 regulations since a direct overboard connection from the bilge pump in the engine room was fitted as per original design. The crew was wrongly informed that this direct overboard connection had to be blanked off in order to comply with MARPOL 73/78 and to pass the vetting survey. Several similar incidents of incorrect interpretation of MARPOL 73/78 have also been reported as a result of Port State Control inspections. Extent of damage By blocking the overboard connection from the bilge pump by blank flanges, locked hand wheels, removed spool pieces etc., the proper operation of the required bilge system in case of engine room flooding would be seriously hampered or even prevented. Disabling the overboard discharge onboard dry cargo vessels will remove the only means of pumping out water from cargo holds in an emergency, for example as a result of grounding or collision. Probable cause Apparently, misinterpretations of how to exercise the MARPOL 73/78 regulations among some surveyors in the maritime field still occur. Unfortunately, it is not always realized that safety must take precedence over pollution prevention. Lessons to be learned Both SOLAS (Ch.II-1 Regulation 21) and DNV Rules for Steel Ships (Pt.4 Ch.1 Sec.4) require the ship to be provided with a bilge pumping system to be operable under all practical conditions. The system is required for safety reasons and is to be operable on very short notice, for instance, in connection with a sudden flooding of the engine room or cargo hold. The MARPOL 73/78 regulations provide for non-emergency operational situations. Annex I Reg. 9 covers control of discharge of oil while Reg. 10 covers methods for prevention of oil pollution from ships operating in a Special Area. Exeptions in case of emergency or distress are addressed in Annex I Reg. 11 as follows: Regulation 11 Exceptions Regulation 9 and 10 shall not apply to: (a) the discharge into the sea of oil or oily mixture necessary for the purpose of securing the safety of a ship or saving life at sea; (b) the discharge into the sea of oil or oily mixtures resulting from damage to a ship or its equipment. Hence MARPOL requirements in no way conflict with, or overrule the requirements of SOLAS and Class Rules. Thus: In an emergency situation the crew must be able to pump water directly overboard, as is also provided for by the SOLAS regulations. The MARPOL regulations provide for non-emergency, operational situations. Blinding, automatic stopping arrangements (if oil exceeds 15ppm) or other locking arrangements of the overboard pipe from the main bilge pump should never take place as this would seriously affect the safety of the ship and is in conflict with SOLAS and Class requirements. One should ensure that all piping used for clean bilge or ballast are free from oil contaminated water prior to using the bilge/ballast pumps for direct overboard pumping. This is an operational issue and should be emphasized in the pumping instructions onboard. Use this information in case inspectors apply the incorrect MARPOL interpretation. Casualty Information is published by Det Norske Veritas, Classification Support. Det Norske Veritas NO-1322 Hvik, Norway T +47 67 57 99 00 el: Fax: +47 67 57 99 11 The purpose of Casualty Information is to provide the maritime industry with 'lessons to be learned' from incidents of ship damage and more serious accidents. In this way, Det Norske Veritas AS hopes to contribute to the prevention of similar occurrences in the future. The information included is not necessarily restricted to cover ships classed with DNV and is presented, without obligation, for information purposes only. Queries may be directed to Det Norske Veritas, Classification Support, NO-1322 Hvik, Norway. Fax: +47 67 57 99 11, e-mail: experience.feedback@dnv.com Det Norske Veritas AS. This publication may be reproduced freely on condition that Det Norske Veritas AS (DNV) is always stated as the source. DNV accepts no responsibility for any errors or misinterpretations.

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