MyriadSea recognises that protection of the marine environment is fundamentally important to the ongoing success and sustainability of our business and the businesses of our customers and suppliers.
We are acutely aware of the environmental challenges that some countries are facing as climate patterns change, MyriadSea is committed to Environmentally Sound Shipping.
This means operating our ships in a way that minimises our impact and encourages protection and management of the environment, taking every appropriate effort to reduce or eliminate environmentally harmful waste or pollution. We are committed to a policy of zero spills to the sea, achieved through proactive measures such as source elimination to prevent pollution from occurring.
This requires a high level of environmental awareness on the part of all involved in operating our ships, both onboard and in the office as well as appropriate training and development over time.
To achieve this we must ensure that we continuously develop in this area, learning from industry best practice, remaining alert to regulatory changes and technology advancements, and continuously assessing the effectiveness of our existing processes and procedures. The implementation of environmentally sound shipping is an evolving journey, adapting to evolving industry standards and knowledge.
Many countries rely heavily on a healthy marine environment for the wellbeing of their economies and societies. Our ships trade to many of these countries, and so being responsible about the marine environment also protects our business interests.
EVERYONE AT MYRIADSEA IS RESPONSIBLE FOR ENVIRONMENTAL PROTECTION.
In the implementation of this commitment, we will:
• Take steps to promote environmental awareness amongst all personnel
• Carry out appropriate development and training in environmental protection
• Operate our ships with due regard to the most efficient use of materials and energy
• Minimise the generation of waste
• Dispose of all waste in a safe and responsible manner
• Promote re-use and recycling wherever appropriate and reasonable
• Involve ourselves in industry relevant discussion around environmental protection
• Take steps to ensure that our requirements are being followed
MyriadSea will take all steps necessary to ensure that our vessels comply with all relevant mandatory rules and regulations concerning environmental protection. We will take into account guidance found in relevant industry publications and best practice examples from all parts of the industry.
We encourage an open reporting culture.
Personnel who believe that the requirements of this section have not been followed, can contact at any time any Senior Officer, the Master, the Ship Management Team or Designated Person Ashore (DPA) to report the occurrence. Reports can be made anonymously by phone, email, SMS or any other suitable method, and all such reports will be investigated by the company.
No punitive action will be taken against those who make such reports, except where the reporter knowingly made a false report.
A key element in the implementation of environmentally sound shipping is recognising and understanding potential sources of pollution so that action can be taken to eliminate or to minimise them. We have identified the following classes and potential sources of pollution:
1. Pollution into the sea:
•Oil, this can include:
- Fuel Oil – there are risks when the vessel is being associated with vessel bunkeredbunkering, when oil is being transferredtransfer operations, machinery failures, and hull or tank breach
- Lubricants
- Waste oil
- Cooking oil
- Oil from machinery
- Oil carried as cargo
• Garbage:
Improper disposal of ships garbage has a significant negative impact on the marine environment. Much of the garbage we produce today does not readily decompose, resulting in it remaining in the environment for many years. Even decomposable waste can release harmful toxins into the sea, adversely affecting the marine ecosystem.
• Sewage:
Untreated sewage can contain toxins that are harmful to humans and marine life.
• Ballast Water:
Can contain plant/ animal life/ matter or water-borne pathogens, which if release into a new environment can have devastating effect on local ecosystems and local economies.
• Chemicals, Chemical waste & Paint:
Many chemicals are harmful to humans and/ or marine life and can cause great harm if released into the sea. This includes chemical waste.
• Anti-fouling Paints:
These paints are formulated to prevent the build-up of marine organisms on ship’s hulls, but the compounds used can contain elements that are harmful to marine life.
2. Pollution into the air:
• Exhaust Emissions:
The gases released from exhausts are noxious and unburnt particulates cause smog, acid rain and can affect climate patterns. While motor ships will inevitably release exhaust emissions, steps can be taken to minimise them and their effect on the environment.
• Cargo Vapour Emissions:
Some cargoes can emit extremely hazardous vapours which can have immediate effects on health and wellbeing.
• Ozone Depleting Substances
• Noise Pollution
Causes include unnecessary running of machinery or systems, poorly maintained equipment, lack of awareness by ship’s staff. Noise pollution adversely affects the wellbeing of all onboard and, if it isexcessively loud, can impact local populations leading to ill-will towards the vessel and/ or company.
This list if far from exhaustive. The identification of potential sources of pollution is an ongoing exercise involving both shipboard and office personnel. Only when a potential pollution source has been identified can effective steps be taken to eliminate or minimise it, we strive to do this before an incident occurs.
Fixing pollution after it happens is no solution.
Damage to the environment and reputations has already been done. Damage to the environment and reputations has already been done. We are committed to identifying pollution sources and eliminating them before incidents occur.
1. PREVENTING POLLUTION A SEA
Many countries treat pollution of the sea extremely seriously. Those who pollute their waters are often subjected to heavy fines (for both individuals and companies) and/ or lengthy terms of imprisonment.
We will not tolerate pollution of the sea.
a. Oil Pollution
This type of pollution has possibly the greatest negative perception in the public eye, and is extremely serious. The sources of oil pollution on ships are varied, and go beyond machinery and engine room operations. All personnel must be aware of the risks and the mitigation measures that have been put in place to prevent spills.
i. Fuel Oil
Whenever the vessel loads fuel oil, there is a risk of spillage into the sea. Failing to follow correct operational procedures, failure to maintain critical equipment, the disconnection of warning and alarm systems, failure to properly supervise operations can all lead to a spillage. There is also a risk of spillage any time fuel is transferred from one tank to another onboard, or if supply lines to machinery fail.
It must be remembered that a fuel oil spill also poses a significant fire hazard.
All operations involving fuel oils must be carried out strictly in accordance with the requirements of B05 Bunkering and all other relevant sections.
ii. Waste Oil (Sludge)
Residual oil waste must be disposed of in a safe and responsible manner, ensuring total compliance with all relevant international and national legislation. It is to be stored in appropriately designated tanks onboard the vessel, and disposal must be in accordance with the vessel’s IOPP Certificate,. usually using the onboard incinerators or \ at a shore reception facility/ service.
Sludge can contain many contaminants, including particulates, oxides, fines, asphaltenes, alkalis, metal elements, mineral elements, bacterial and fungal micro-organisms. It is to be considered toxic, contaminated and hazardous and treated and handled appropriately. There is a risk that harmful and/ or flammable vapours or gases may be emitted from such waste, making the risk of explosion or fire significant.
Sludge can cause significant damage to the marine environment, and proper steps must be taken to eliminate the risk of spillage.
All operations involving waste oil must only be carried out after a proper risk assessment has been completed. Personnel who work with sludge must wear appropriate PPE at all times.
iii. Lubricants
Much of the machinery onboard contains some form of lubricating oil, and often the pollution risk from this type of oil is overlooked. Whenever work is being carried out on machinery the impact of a loss of lubricating oil must be considered at the risk assessment stage and steps taken to eliminate or minimise the risk (or the consequences of that risk). This is by means of a Risk Assessment.
Remember, lubricants are not just found in the engine room, they are also applied to much of the ship’s deck equipment! Greases pose just as much a risk to the environment as any other oil.
All lubricants must be properly stowed, in sealed containers when not in use. Crew responsible for handling them must be aware of the environmental risk associated and the risk mitigation measures identified by the Risk Assessment applicable to the operation.
Small spillages or drips must be addressed as a matter of priority. Oil residues must not be left to accumulate on deck plates, as this poses a risk of them entering the sea or causing injury. All crew have an obligation to report spillages to an Officer immediately.
Waste lubricants are to be disposed of safely and in accordance with the manufacturer’s recommendations. This may involve treating them as waste oil or, in some cases, alternative measures may be needed.
iv. Cooking Oil
Cooking oil is no less of a risk to the environment than oil found in machinery. It must be disposed of properly. This means transferring it in an appropriate metal container to be disposed of ashore. Transfers of cooking oil must be noted in the vessel’s Garbage Record Book as Garbage Category “D”.
The Master must ensure that every Cook who joins the vessel is familiar with the disposal procedures for waste cooking oil.
v. Oil From Machinery
Whenever maintenance or repairs are carried out on machinery containing fuels or oils there is a risk of spillage into the sea. A careful risk assessment must be carried out prior to commencing the work to ensure that all risks are identified and mitigated/ eliminated.
All maintenance must be carried out in accordance with the requirements of B03 Engineering, B06 Maintenance and any other relevant sections.
vi. Oil Record Book
All ships are required to carry an Oil Record Book (Part 1) (ORB1). This official record covers machinery space operations, ballasting/de-ballasting, discharge of engine room bilges, bunkering operations and accidental discharges of oil.
Tankers must also carry an Oil Record Book (Part 2) (ORB2) covering oil cargo operations.
The ORB is an official document that is subject to intense scrutiny by Port State Control Officers.
Incorrectly completed Oil Record Books, or Oil Record Books with false or misleading entries can result in:
• detention of the vessel
• heavy fines
• lengthy terms of imprisonment
All ORB entries must be signed the Officer in charge of the operation, and every completed page must be signed immediately by the Master and Chief Engineer.
vii. Oily Water Separator (OWS)
***Critical Equipment***
The Oily Water Separator is considered critical equipment by the company. When used properly it ensures that the legal limits for the discharge of oily water mixtures are not exceeded. If the OWS is not operating correctly or maintained properly, the vessel may be detained, the company and crew may be subject to fines and the crew may face imprisonment if oil has been discharged into the sea.
Nobody may use the OWS unless they are fully familiar with its operation, testing and maintenance.
The OWS will be inspected by almost every Port State Control Officer. Faults, lack of maintenance or unfamiliarity with correct operation will almost inevitably result in detention of the vessel.
The OWS must never be by-passed, and there must be no method of bypassing it. If modifications to the vessel mean that a bypass possibility is present, then this should be blanked off.
Whenever in port, or when not in use the OWS discharge valve must be closed and locked. The key must be held by the Chief Engineer only. Additionally, if the OWS unit as associated equipment does not meet the requirements of MARPOL Annex I Regulation 14.7 then the OWS discharge valve must also be closed and locked when the vessel is passing through a MARPOL Special Area. Information on which regulation the OWS unit complies with is found on the IOPP Supplement (Form A).
Consider the following:
• There must be a record of all tests and maintenance carried out to the OWS, these should be readily available and all Engineer Officers must know where to find it. A routine test/ maintenance tag should be affixed on or near the OWS unit to provide a visual indication of maintenance carried out. All maintenance records/ tags must be signed by the person who carried out the work.
• All alarms and recording systems must be fully functional at all times. Alarms are to be report to the Chief Engineer, who must notify the Ship Management Team.
• The OWS system has a maximum flow capacity, and PSC inspectors will closely scrutinise flow rates recorded in the ORB against that maximum. The flow rate must never exceed the maximum for the equipment fitted.
• If the OWS unit is fitted with consumable coalescing filters then there must be sufficient spares onboard (refer below), and the filter must be replaced in line with the manufacturer’s recommendations. The filter (as with all internal components of the OWS) must be maintained as per the manufacturer’s instructions and be kept in good condition at all times.
The following extract is taken from the Australian Maritime Safety Authority (AMSA) web page covering common causes of detention at PSC inspection:
“Oily Water Separator (OWS)
An operational Oily Water Separator (OWS) is the evidence an AMSA Inspector requires to be reasonably certain that MARPOL and/or Australian regulations have been, and can continue to be, complied with.
The two major items AMSA Inspectors are able to observe with respect to the OWS functioning correctly are the Oil Record book (ORB) and the OWS itself. Entries in the ORB may be inaccurate and this may lead to an impression that the book data is intentionally inaccurate because oil has been discharged other than in accordance with the regulations.
The OWS is fitted with a monitoring device that measures the oil content of the discharged liquid and an arrangement is provided to allow a simple test of that monitor to ensure any safety devices fitted operate correctly. These devices may include a pump stopping device or a recirculating valve but in any case the actual functions will be as required by the regulations.
AMSA Inspectors will request that an alarm condition be simulated and if the required events do not occur this can be considered grounds for detention. Our Inspectors also report occasional oil monitor problems whereby the unit indicates a level of oil in the discharge, even when fresh water is being used for the test, or whereby the monitor continuously indicates an oil level above the alarm point and the system remains in that alarm condition at all times. These situations may be grounds for detention but AMSA Inspectors will always try to expand the inspection of the OWS sufficiently to determine if there is another cause for the indicated problem. This may include requesting that the filtering/coalescing unit(s) are opened for inspection to assist in determining if the unit has been adequately maintained as a whole. It should be noted that any testing of the OWS must be carried out without any actual discharge overboard taking place.
If clear grounds exist, the AMSA Inspector may also ask for a section of piping after the monitor be removed for internal inspection.
It should also be noted that the OWS is designed with two main elements, the actual separator and the discharge monitor. A defect with either element may constitute grounds for a detention.
It is suggested that ships should routinely verify the following to reduce the chance of detentions:
• All Oil Record Book entries completed according to Marpol.
• Operation of the OWS able to be demonstrated.
• Operation of the OWS monitor able to be demonstrated.
• Verification that the associated monitor, alarm and stopping device are operational.”
Ensuring the OWS, and all its component parts are operated and maintained in good condition is critical to ensuring the vessel does not encounter Port State Control issues.
viii. Maintenance of the Oily Water Separator
The OWS is to be maintained in accordance with the manufacturer’s instructions and guidance. The ship is to develop, with the support of the Ship Management Team, appropriate routine checks and maintenance work that must be carried out to ensure that the system remains operational.
If the OWS is fitted with consumable parts, these are to be replaced as required by the manufacturers recommendations. Where the manufacturer has not provided a recommendation, then the Chief Engineer and Ship Management Team are to determine an appropriate replacement interval based on:
• Industry best practice
• Guidance from industry bodies
• Performance data for the system
Maintenance must only be carried out by those who are familiar with the system. Full and complete records of all maintenance must be kept onboard.
ix. Spare Parts for the Oily Water Separator
The ship is required to carry sufficient spare parts for the OWS unit and associated equipment. This means, as a minimum, the minimum spare parts identified by the manufacturer of the equipment. However, the Chief Engineer should routinely assess the parts carried onboard and discuss their appropriateness with the Ship Management Team.
All spare parts must be the correct parts for the unit.
x. Non-Functioning of the OWS
If the OWS is not operating correctly, it must not be used and the Ship Management Team & DPA must be informed. Furthermore, steps must be taken to notify the appropriate authorities of this deficiency. This includes ensuring coastal states are notified prior to arrival to prevent unexpected discovery during PSC inspection.
The vessel must not proceed to sea unless the OWS is properly functioning, or unless approval has been sought from flag to proceed. The decision to seek such approval rests with the Ship Manager. It is only to be sought if the company is satisfied that appropriate measures have been taken to store oily mixtures onboard, that there is sufficient capacity for such mixtures for the duration of the intended voyage (plus an appropriate reserve period) and that there is some clearly justifiable reason for seeking to sail to the next port prior to repairing the OWS (i.e. lack of repair services at current port).
xi. Preventing Illegal Bypassing of the Oily Water Separator
Bypassing the OWS is illegal. It has resulted in lengthy terms of imprisonment for seafarers and record fines for shipping companies.
We will not tolerate any action taken by anyone with the aim of bypassing the Oily Water Separator. Anyone found taking such actions will have their employment terminated immediately, this applies equally to ship and shore based personnel.
The company will cooperate fully with port and coastal authorities investigating claims that the OWS has been bypassed.
To minimise opportunities for illegal action, the company requires the following measures be implemented:
• All flexible hoses carried onboard are to be fitted with a unique, permanent identification tag. The tag number is to be recorded in the Identification and Seal Register with the following details:
• Tag number
• Hose purpose/ usage
• Diameter
• Material
• Length
• Storage location
• Disposal date (after disposal)
• Means of disposal (after disposal)
• Signature of the person who disposed of the hose (after disposal)
The hose register must include all hoses on the vessel, meaning all engine department hoses, all deck department hoses and any other hoses.
The Identification and Seal Register is to be held by the Chief Engineer, who is responsible for ensuring it remains up to date.
Flexible hoses must be properly stowed at all times as per the Idenfitication and Seals Register. If they are found stowed improperly, this can lead an inspector to suspect that it may have been used for illegal bypassing of the OWS, resulting in more detailed inspection.
• Portable pumps have been used in some cases where ships have illegally bypassed the OWS, leading inspectors to become suspicious of the intended purpose of such pumps.
The number of portable pumps carried onboard the vessel should be kept at an absolute minimum at all times. All portable pumps are to be properly stowed.
Every portable pump onboard should be uniquely identifiable. If necessary an identification tag should be applied to the pump. Details should be recorded in the Identification and Seals Register:
• Pump identification
• Make and type
• Intended usage
• Date brought onboard
• Stowage location
• Disposal date (after disposal)
• Means of disposal (after disposal)
• Signature of the person who disposed of the pump (after disposal)
• To prevent illegal connections to overboard piping systems, every blank flange associated with any piping system leading overboard (for example engine cooling, salt water service, sewage discharge) shall be secured or fitted with a uniquely number seal that will break if the blank flange is opened.
Details of all seals applied are to be recorded in the Identification and Seals Register:
• Seal Number
• Flange details
• Associated piping system
• Date seal applied
• Signature of person who applied seal
• Date seal removed (after removal)
• Reason seal removed (after removal)
• Signature of person/s who removed seal (after removal)
xii. Prohibition on the Use of Bilge-Main Cross-Connections
The use of cross connections from engine room bilge mains to other piping systems is strictly prohibited except in emergencies.
The use of such crossovers is no different to any other illegal method used to bypass the OWS.
xiii. Oily Water Separator “Anti-Pollution Board”
To reduce the risk of human error in operating the OWS, and to make clear the company’s commitment to environmental protection, we require that an “Anti-Pollution Board” be fitted immediately adjacent to the OWS.
The board must include the following:
• Type-Approval Certificate for the OWS
• Piping Diagram
• Operating Instructions
• Routine Maintenance Instructions
• Company Warning Notice “Preventing Pollution by Oil”
b. Garbage
Pollution caused by inappropriate disposal of garbage has a major impact on marine and coastal environments. Sold waste can harm marine life, toxins can find their way into areas inhabited by humans and larger waste can become a hazard to small vessels.
The company is committed to ensuring proper disposal of garbage, in compliance with all relevant regulations.
i. Disposal to Comply with Relevant Legislation
Disposal of garbage from company ships is to comply with relevant international, regional and national legislation at all times. If the ship is in any doubt as to the relevant regulations, they should contact the Ship Management Team for advice.
Sources of information include:
• MARPOL
• IMO Publications
• Classification Societies
• National Administrations
Everyone has a duty to ensure they understand and comply.
The company will ensure that notices regarding proper disposal of garbage are provided to the vessel and the Master must ensure they are prominently displayed in public areas and that all crew are informed.
ii. Garbage Management Plan
Every ship is required to carry a Garbage Management Plan, which reflects the specific requirements of the vessel. All crew must be familiar with the requirements of that plan, insofar as they relate to their duties.
All crew must be shown the correct system for collection, separation, processing, storage and disposal of garbage as part of their familiarisation with the vessel.
Ensuring compliance with the requirements of the plan is the responsibility of the Master, who should use his routine inspections of the vessel to check the measures that are in place.
iii. Garbage Record Book
Every ship is provided with a Garbage Record Book (GRB), which is an official document used whenever garbage is disposed of, through discharge, incineration or by any other means.
False or incorrect entries in the GRB can lead to detention of the vessel and/ or heavy fines.
It is important that the correct category of garbage is noted in the record book and that the person in charge of the disposal operation signs each entry. Each completed page should be signed by the Master immediately upon completion.
iv. Disposal
Where garbage is landed ashore, receipts for discharge must be provided to the ship. These are to be retained and properly filed. In the event that Master considers the shore-based reception facilities are inadequate, the Master should notify the Ship Management Team giving details about the nature of the inadequacy.
Where garbage is incinerated, it is important that incineration is carried out within the operating limits of the incinerator. No one may use the onboard incinerator unless they have been properly trained in its use. Proper records of maintenance must be maintained and all engineering Officers should know where to locate these if asked.
v. Incinerator “Anti-Pollution Board”
To reduce the risk of human error in operating the incinerator, and for the company’s commitment to environmental protection to be clear, we require that an “Anti-Pollution Board” be fitted immediately adjacent to the incinerator.
The board must include the following:
• Type-Approval Certificate
• Incinerator Drawings
• Operating Instructions
• Routine Maintenance Instructions
c. Sewage
Untreated sewage is a significant hazard to the health of marine life and humans near the coast. It is capable of transmitting disease, can be a carrier of harmful organisms and its presence can cause significant ill-will towards the maritime industry. Most countries take the pumping of untreated sewage into the sea extremely seriously and punish those who do so with extremely heavy fines and imprisonment.
The company will not tolerate pollution of the sea by sewage.
i. Sewage Treatment Plant
MyriadSea ships are all fitted with Sewage Treatment Plants, which make sewage safe for disposal into the sea. These plants are highly effective, removing contaminants and harmful organisms from the effluent. However, the equipment only works if it is properly used and maintained.
The Sewage Treatment Plant is only to be operated by personnel who have been properly trained and familiarised with the equipment. Furthermore, the system is to be maintained in accordance with the manufacturer’s recommendations.
All Engineering Officers should know the maintenance routines for the Sewage Treatment Plant, or where to locate them, and should be able to locate maintenance records when requested. In addition to full records, a visual indication of inspection/ maintenance (maintenance tag) should be attached to the Sewage Treatment Plant itself to show routine inspections are being carried out.
All maintenance records must be dated and signed by the person who carried out the inspection.
ii. Sewage Treatment Plant “Anti-Pollution Board”
To reduce the risk of human error in operating the Sewage Treatment Plant, and to make the company’s commitment to environmental protection clear, we require that an “Anti-Pollution Board” be fitted immediately adjacent to the Sewage Treatment Plant.
The board must include the following:
• Type-Approval Certificate for the Sewage Treatment Plant
• Piping Diagram
• Operating Instructions
• Routine Maintenance Instructions
• Company Warning Notice “Preventing Pollution by Sewage”
d. Ballast Water
The following quote from www.globallast.imo.org (the IMO ballast water management portal) highlights the risks ballast water poses to the marine environment:
“It is estimated that some 3-5 billion tonnes of ballast water is transferred throughout the world each year with an individual ship carrying anything from several hundred litres to more than 130,000 tonnes of ballast water, depending on the size and purpose of the ship.
A potentially serious environmental problem arises when this ballast water contains marine life.
Since just one cubic metre of ballast water may contain up to 50,000 zooplankton specimens (Locke et al.1991, 1993; Gollasch 1996; Kabler 1996) and/or 10 million phytoplankton cells (Subba Rao et al. 1994), and the majority of marine species include a planktonic phase in their life cycle, there are literally thousands of different marine species that may be carried in ships’ ballast water – basically anything that is small enough to pass through a ships’ ballast water intake ports and pumps. This includes bacteria and other microbes, small invertebrates and the eggs, cysts and larvae of various species, including most fish, although not all of these will survive in the ballast tank because it is a hostile environment with considerable disturbance, lack of food and light.
Closely associated with ballast water are ballast sediments. When a ship takes on ballast water it also takes on material contained in the water. In turbid or shallow waters this often includes solid material. When this material enters the ballast tank it settles to the bottom as ‘sediment’ and provides a substrate for a variety of marine species, notably dinoflagellates. According to the Convention sediments are defined as “Matter settled out of ballast water within a ship”.
Ballast water is thus recognised as one of the principal vectors of potentially invasive alien species, and is estimated to be responsible for the transfer of between 7,000 and 10,000 different species of marine microbes, plants and animals globally each day (Carlton, 1999).”
Until recently the potential risks associated with ballast water transfer were not fully understood. However improvements in knowledge have led to the IMO and World Health Organisation WHO recognising the potential risks and taking international action to address them.
The risks can be severe. Again an extract from www.globallast.imo.org:
“The introduction of alien species into a new environment can have serious negative consequences for the environment, for the economy and for human health.
Ecological impacts may include:
• Competing with native species for space and food
• Preying upon native species
• Altering habitat
• Altering environmental conditions (e.g. decreased water clarity)
• Altering the food web and the overall ecosystem
• Displacing native species, reducing native biodiversity and even causing local extinctions
Economic impacts may include:
• Reductions in fisheries production (including collapse of the fishery) due to competition, predation and/or displacement of the fishery species by the invading species, and/or through habitat/environmental changes caused by the invading species;
• Impacts on aquaculture (including closure of fish-farms), especially from introduced harmful algal blooms;
• Physical impacts on coastal infrastructure, facilities and industry, especially by fouling species;
• Reduction in the economy and efficiency of shipping due to fouling species;
• Impacts or even closure of recreational and tourism beaches and other coastal amenity sites due to invasive species (e.g. physical fouling of beaches and severe odours from algal blooms);
• Secondary economic impacts from human health impacts of introduced pathogens and toxic species, including increased monitoring, testing and diagnostic and treatment costs, and loss of social productivity due to illness and even death in affected persons;
• Secondary economic impacts from ecological impacts and biodiversity loss;
• The costs of responding to the problem, including research and development, monitoring, education, communication, regulation, compliance, management mitigation and control costs.
Human health impacts
• Given the magnitude of ongoing ballast water transfers, there is significant potential for large-scale movement of micro-organisms by ships. This has received attention from both epidemiologists and invasion biologists.
• There is evidence that cholera epidemics can be directly associated with ballast water discharges (see Examples of IAS). While Vibrio cholerae and other pathogens are normal constituents of coastal waters, they do not ordinarily occur in high enough concentrations to cause human health problems. However, with expanding world trade and an increasing number of ships moving among international ports, the transfer of microbes could well be the most insidious threat related to ballast water discharge.
• In addition to bacteria and viruses, ballast water can also transfer a range of species of microalgae, including toxic species that may form harmful algae blooms or ‘red tides’. The public health impact of such outbreaks is well documented and includes paralytic shellfish poisoning, which can cause severe illness and even death in humans.”
The International Convention for the Control and Management of Ships Ballast Water and Sediments (BWM Convention) was adopted in 2004. The purpose of this convention is to minimise and ultimately eliminate the transfer of harmful aquatic organisms and pathogens from ships ballast systems.
i. Commitment to Compliance
We are committed to complying with all relevant legislation and regulations to ensure that all ballasting operations are carried out in a manner that minimises or eliminates impact on the local marine environment while acknowledging that at all times the safety of the ship and those onboard is paramount.
ii. Ballast Water Management Plan
The BWM Convention requires that all vessels carry a Ballast Water Management Plan. All vessels are supplied with this plan. It is intended to provide guidance and has been tailored to the ships unique arrangements. The plan also contains relevant ballast water reporting forms for various coastal states.
The plan is approved by the Flag State (or Class on behalf of Flag).
iii. Method: Ballast Exchange at Sea
One approved method of minimising possible Ballast Water contamination is through Ballast Water exchange carried out a sufficient distance from the coast to cause harm. This method will, in time, be phased out and prohibited by the BWM convention.
All those involved in Ballast Exchange operations must be entirely familiar with the ballast system fitted to the vessel and must know how to respond to failures or other emergencies that may be encountered. A risk assessment must be carried out before any Ballast Exchange operation commences.
A failure of any part of the ballasting system during an Exchange operation can have serious consequences, and is to be treated with due urgency. In every case the Master is to be informed, and they in turn are to inform the Ship Management Team. Immediate action is to be taken to ensure the safety of the ship.
If the ship is already fitted with a Ballast Water Treatment Plan, then exchange at sea will no longer be a permitted method of ballast water treatment.
The preferred method is via the use of Ballast Treatment Plant, however some local regulations may require an additional exchange at sea.
iv. Method: Treatment
With the entry into force of the BWM convention, by late 2022 this will be the only permitted method that will enable a ship to carry out ballasting operations in port or in coastal waters.
If the vessel is fitted with a Ballast Water Treatment Plant (BWTP), then this is the primary means of carrying out ballast water operations.
There are multiple types of BWTP in use at sea, however irrespective of their make or method of treatment, they are only effective if properly maintained, operated and inspected. Only personnel who have been properly familiarised with the operation of such systems may use, maintain or inspect them. All engineering Officers should be able to locate maintenance records and routines.
v. Method: Isolation
Where the vessel cannot handle ballast water using the exchange or treatment methods, then it will need to be retained onboard or discharged into a shore-based reception facility. This method has significant operational and cost implications and is therefore only be considered if no alternative is available and after consultation with the Ship Management Team.
vi. Priority of Safe Operations
There are risks associated with ballast operations. If not executed properly, they can be extremely dangerous. At all times, the stability and strength limitations of the vessel must be taken into consideration and never exceeded.
BALLAST WATER MANAGEMENT MUST NEVER PUT THE VESSEL AT RISK
e. Chemicals
Chemicals used onboard can contain hazardous compounds, which affect the health and wellbeing of humans or the health of the marine environment. Appropriate disposal measures must be in place to eliminate this risk.
All chemicals must be properly stowed at all times and access strictly controlled to prevent unauthorised use. Chemicals should only be used by personnel sufficiently familiar with their use, risks and disposal requirements.
Chemicals will always be provided with Material Safety Data Sheets (MSDS) and most product labels will provide information on safe and correct disposal. The manufacturers advice must be followed at all times. If there is any doubt, then the Ship Management Team should be contacted for advice, and the product retained onboard for landing ashore as waste.
Many containers holding products classified as “marine pollutants” are labelled with the following internationally recognised symbol:
However, it is important to note that just because a products label does not have the above symbol , it does not mean it will not harm the marine environment. Follow the manufacturers guidance at all times.
f. Paints
Paint used for maintenance work onboard is both a fire hazard and a pollution risk. The product must always be disposed of in accordance with the manufacturer’s recommendations. If there is doubt as to the requirements for proper disposal then the Ship Management Team should be contacted for advice.
g. Anti-Fouling Paints
These paints are designed to keep the ship’s hull as smooth as possible, on the basis that the smoother the hull the less resistance it encounters in the water, thereby improving fuel efficiency.. They do this by inhibiting the growth of marine organisms on the hull. Some of these paints containing compounds that can have a negative impact on the broader marine environment. To counter this in 2001 the IMO introduced the International Convention on the Control of Harmful Anti-Fouling Systems on Ships. This convention effectively outlawed harmful anti-fouling paints and requires that all vessels carry a certificate evidencing the compliance of the anti-fouling system that is in use.
2. PREVENTING POLLUTION OF THE AIR
With the growing recognition of the long-term impact that pollution of the air has, the IMO introduced Annex VI to MARPOL in 1997 with the express purpose of limiting the main air pollutants contained in ships exhaust gases and controlling Ozone Depleting Substances (OSD’s). The annex entered into force in 2005 and has been revised several times since introduction.
The following quote is from the IMO:
“Although air pollution from ships does not have the direct cause and effect associated with, for example, an oil spill incident, it causes a cumulative effect that contributes to the overall air quality problems encountered by populations in many areas, and also affects the natural environment, such as tough acid rain.”
We are committed to operating our ships in a manner that minimises our footprint with respect to air pollution, by improving onboard practices and knowledge.
a. Exhaust Emissions
At all times our ships are required to burn fuel that is within the sulphur limit defined by IMO for the area in which it is trading. Failure to do so can have serious consequences, including detention of the vessel and fines or imprisonment for personnel.
Since January 2020, the global fuel oil sulphur cap is 0.5%. Fuel with more sulphur content than this can only be used by ships fitted with an approved exhaust gas cleaning system.
Since March 2020, it is prohibited to carry any fuel onboard with a sulphur content of more than 0.5% (unless an exhaust gas cleaning system is fitted).
If for any reason the sulphur cap requirements cannot be met, the Ship Management Team must be informed immediately and a course of action agreed. No Master may accept a fuel delivery of non-compliant fuel without the express written authorisation of the Managing Director.
Smoke emissions from the funnel must be properly controlled, and all Officers, both deck and engine, must pay attention to this. Of particular importance is the Deck Officer of the Watch’s duty to advise the Engineer Officer of the Watch if they have any concerns regarding the state of the exhaust emissions. This could include excessive smoke, or the release of soot/ particulate matter.
The best way to minimise harmful exhaust emissions is to ensure that all equipment is properly maintained and being properly operated by trained, familiarised personnel.
If the vessel has ongoing concerns about the state of exhaust emissions from the funnel, they should seek advice from the Ship Management Team.
b. Cargo Vapour Emissions
Some cargoes can emit noxious vapours into the atmosphere, which have an immediate impact on the health of those working the cargo and longer-term impacts on the environment. In order to counter this risk all cargo operations involving the risk of a release noxious vapours are to be carried out in accordance with the relevant international and international regulations.
In addition, all such operations should be the subject of a fully completed risk assessment.
c. Ozone Depleting Substances (ODS’s)
As a result of the reduction in the earth’s ozone layer over time, the IMO took steps, with the introduction of Annex VI of MARPOL, to phase out the use of CFC’s and ultimately HCFC’s onboard ships. Despite this there remain some ships with certain systems that contain ODS’s and measures must be taken to prevent the “deliberate release” of these into the atmosphere.
No new Ozone Depleting Substances may be fitted to a vessel.
Whether a vessel has ODS’s onboard is recorded in the IAPP Certificate Supplement. If a vessel does have such substances onboard then the following measures apply:
• The ODS must not be deliberately released into the atmosphere.
• When servicing or decommissioning systems containing ODS’s, the substance must be contained in a controlled manner and if not to be reused onboard, landed to an appropriate reception facility.
• Any equipment containing ODS’s which is redundant is to be landed ashore for appropriate decommissioning or disposal.
• Any ship with ODS’s listed on the IAPP Supplement must carry and use and ODS Record Book in which any supply, recharging, repair, discharge or disposal of an ODS is to be recorded.
At all times the manufacturer’s instructions for handling equipment containing ODS’s is to be strictly followed, and if there is nay then the Ship Management Team should be contacted for advice.
All systems which contain ODS’s must be subject to regular maintenance and inspection (as per the manufacturer’s instructions). This should include checking and recording readings/ levels to ensure that there are no system leaks.
Failure to properly record maintenance and inspections to systems containing Ozone Depleting Substances can lead to detention of the vessel and fines.
d. Noise Pollution
Unnecessary noise onboard and emitted from the vessel can have serious negative effects on the health and well-being of crew members and create ill-will from communities near the vessel’s trade routes. Vessels are designed with noise thresholds, and much of the noise pollution created onboard is a result of poor maintenance or operating practices.
Excessive noise can impact crew members ability to rest, impairing their ability to function safely and putting them and the vessel at risk.
To keep noise from machinery to an acceptable level:
• Ensure that all equipment is maintained to the required standard.
• Run only the minimum amount of equipment required for safe and effective operations. Running unnecessary equipment is not only a noise pollutant but creates operating, maintenance and repair costs for the company.
To minimise noise pollution in accommodation spaces:
• Ensure all doors to and from stairwells are kept closed
• Have consideration for the spaces you are in or passing through before making noise. Are you passing by your colleague’s cabin?
The company believes that energy efficiency and environmental protection go hand in hand, and so is committed to ensuring that our ships are operated in the most efficient manner. All ships have a Ship Energy Efficiency Management Plan (SEEMP), and this is the basis of efficient operations.
Additionally, the company recognises that ship’s staff may have ideas and suggestions for further improving efficient operations and encourages personnel to make these ideas known to onboard leadership and/ or the Ship Management Team.
Some of the key concepts that apply to energy efficient shipping are:
• Ensuring all machinery is operated in an optimal way, as well as careful monitoring of overall operating condition while in use
• Using only as much equipment/ machinery as actually required for the operation at hand
• Not leaving equipment running idle when it is not needed
• Monitoring vessel speed and equipment load carefully, operating at the most economical condition to meet commercial requirements
• Ensuring that all equipment is properly maintained
• Lighting to be used as required for operational, safety and security reasons, but switched off when not required. Vessels and Ship Management Teams should consider introducing energy efficient lighting systems
The above are key concepts and ideas, and must be supplemented by the requirements of the SEEMP and other onboard practices. All personnel should consider energy efficiency when planning operations that are to be carried out onboard.