environmental compliance - intertanko.com · testing with air is not acceptable. procedure followed...

“Environmental Best Practices ”.

Panagiota P. Chrysanthi

________________________________________

Manager & DPA/EMR

Quality, Safety & Environmental Department

Andriaki Shipping Co. Ltd.

Direct line: +30-210-6152429

Phone: +30-210-6152300

Mobile: +30-6932-393521

Fax: +30-210-6152301

Address: Fragoklissias 9, Maroussi, 151 25, Greece

[email protected]

ENVIRONMENTAL COMPLIANCE

INTERTANKO TANKER FORUM

ROME 22ND JUNE 2018

ENVIRONMENTAL COMMITTEE

mailto:[email protected]

Introduction

Officers Responsibilities

VGP

OPA 90

MARPOLSOLAS

ISM


ROME 22ND JUNE 2018


Still non compliance ?


ROME 22ND JUNE 2018


• Whistle Blowers- Environmental Compliance Programs –Probation - fines (acc. to fleet, accounts)

• ORB Wrong Entries OR mishandling - Suspicious of violations

• Pollution incidents [Iranian vessel explosion / sinking East China Jan 2018]

• PSC deficiencies on wrong Garbage / sewage / sludge management

Oil Record Book repeated findings

Deficiencies Related to ORB Entries

Operational tests of the OWS and OCM

not properly performed /

recorded.

Wrong codification.

Calibration of OCM not properly

followed / recorded in the ORB.

Operation of Incinerator not

properly recorded.

OWS, Incinerator wrong entries of

rate.

IOPP Form B- tanks description

- Handling


ROME 22ND JUNE 2018


Oil Record Book repeated findings

Pressure testing of cargo & bunker lines – ORB Entries


ROME 22ND JUNE 2018


The type of testing required

by 33 CFR 156.170(c)(1)(iii)

and (iv) is static liquid

pressure testing. Testing

with air is not acceptable.

Procedure followed for

cargo and bunker lines

testing should be in

accordance with

regulations. “Cut-corners”

eventually will be crossed

checked against entries

(both Oil Record Books and

interviews with responsible

officers i.e. Vetting

Inspections)

Reasons why?


ROME 22ND JUNE 2018


• Workload – not time available to drill down on regulations and effectively digest

• Various regulations and interpretations – legislation is not always aligned

• Crew awareness – culture – training effectiveness

• Deviation instead of postponement

How to enhance compliance ?


ROME 22ND JUNE 2018


• Keep it simple

• Adopt practices which can be easily implemented with objective the compliance but without increasing workload to the extent possible

• Provide concise guidance on regulations and interpretations / give clear instructions

• Invest on Crew awareness – training

• Encourage reporting – promote no blame culture

• Enhance tool for effective auditing / monitoring

• Assign roles / increase accountability of individuals

• Show top management commitment

• OWS & OCM tested and calibrated frequently as to ensure that operation has not been compromised

Voluntary Environmental Management Voluntary Disclosure Policy

Seal to control unauthorized use / Seal Inventory / Logbook

Implementation & Examples


ROME 22ND JUNE 2018


Seal to control unauthorized use / Seal Inventory / Logbook



ROME 22ND JUNE 2018


• Discharge piping systems that are or may be connected to the oily bilge system.• Main Cross Connections• Emergency Bilge Suctions• Main Bilge Suctions• Bilge Shore Connections (transfer system & valves)• Sludge Shore Connections (transfer system & valves)• Sewage Shore Connections (transfer system & valves)• Sewage Overboard• OWS piping system• OWS overboard• OWS fresh water line• Remotely operated valves• Blank flanges connected to any piping leading overboard (salt water, M/E raw water cooling and so on)• Flanges from bilge pump to waste oil tank, bilge tank, waste oil incinerator tank• Bosun Bilge valves (discharge / overboard)• Forward eductor driving valve• Valves connected to stripping pumps for de-ballasting operation in case E/R bilges are connected to

ballast piping system.• Piping on Open Air Deck to slop tank (if applicable)• ODME open air deck control valve & blank flange (if applicable)

E- ORB



ROME 22ND JUNE 2018


• PREVENT repeated violations including

• Evaporation of sludge is not being recorded• False entries for the transfer of bilge water• Weekly ROB entries for sludges not performed (ECP requirement)• Disposal of cooking oils, lubricants, etc., not properly documented in the ORB• Missing entries for the transfer of the contents of the Overflow Tanks• Scratches and overwriting in the ORB• Maintenance (& filter replacement) of the OWS not properly recorded• Operational tests of the OWS and OCM not properly recorded• Wrong codification• Calibration of OCM not properly recorded in the ORB• Operation of Incinerator not properly recorded• OWS, Incinerator wrong entries of rate• IOPP tanks description• Calculations

Garbage Management



ROME 22ND JUNE 2018


• INTERTANKO guidance with clarifications • Clear marking

Housekeeping - controlled process



ROME 22ND JUNE 2018


• Controlled procedure for flexible hoses• Flexible Hoses leading to the bilge wells to • direct various leakages from machinery and pump should be removed, otherwise inventoried and their

use logged.• Keep tools in proper condition


ROME 22ND JUNE 2018


Continue out of the (regulatory)field. Be Green

environmental compliance - intertanko.com · testing with air is not acceptable. procedure followed...

Documents