USA

USCG - MARPOL Annex I Enforcement Policy

The US Coast Guard recently published a policy letter, "Guidance for the Examination of MARPOL Annex I During Port State Control Examinations," (see below) which establishes new inspection and testing procedures for USCG Port State Control Officers (PSCO).

The policy letter addresses the following issues:

Oil Record Book - Irregular/Falsified Entries

"the PSCO should be aware that the Coast Guard and Department of Justice may use a falsified oil records book (ORB) as criminal evidence against a ship and its crewmembers suspected of an illegal discharge."

PSCOs are directed to investigate oil record book "irregularities" which may include:

• if amounts processed exceed rated capacity of the pollution prevention equipment;
• entries for wrong codes, dates that are not in order and missing pages;
• repetitive entries that may indicate falsification of oil records book activities;
• if waste oil, sludge, bilge and other tank levels noted during the inspection vary significantly from last entries; and
• record quantities of oily bilge water pumped to holding tanks or processed by the OWS directly from the bilge wells do not compare to observed conditions with the machinery space.

Oil Discharge Monitoring Equipment

"PSCOs should be aware that the Coast Guard has learned of instances where such monitoring equipment has been tampered with, similar to OWS equipment in order to discharge oily waste that exceeds allowable limits. Recent examples of tampering include manually changing recorder entries such as vessel speed and dates."

Operational Inspection of Equipment
"PSCO should examine overboard piping to identify conditions that may indicate the disassembly of piping segments, flanges, blanks, or valves tied into any system that lead overboard. . .The PSCO should pay particular attention to loose bolts, blanked flanges, capped pipes, dead-end valves and tees, chipped paint, evidence of work such as handprints against the hull or piping, or even fresh paint, oil stains, drippings, splatter oil on valve stems, particularly near systems capable of directing fluids overboard."

There is further guidance concerning:

• IOPP Certificates
• Shipboard Oil Pollution Emergency Plans
• OWS testing
• bilge alarms
• sludge tanks
• incinerators
• standard discharge connections and
• Coast Guard procedures for detaining a vessel under MARPOL Annex 1.

Download document

USCG - Guidance for the Examination of MARPOL Annex I During Port State Control Examinations