David Nichol, Regional Loss Prevention Executive, Thomas Miller P&I (Europe) Ltd, gave a presentation entitled “Pollution Prevention and Mitigation” and explained how The UK P&I Club Risk Assessment Scheme works towards that end. The scheme has at its core a team of experienced master mariners and chief engineers visiting hundreds of entered vessels at strategic ports around the world annually. These risk assessments focus on the cause of P&I claims and provide suggestions for improving on board preventative and recovery controls for specific hazard areas, including marine pollution. Mr. Nichol provided a brief overview of the scheme and showcased well illustrated examples of good ship board practice and common failures relating to pollution prevention.
The UK P&I Club began employing in-house ship inspectors 26 years ago at a time when all P&I Clubs were experiencing a large number of high value claims caused by structural failure or machinery breakdowns. In the early days, the Club inspectors therefore gave priority to assessing the physical condition of ships visited as well as the standards of regulatory compliance. However, since that time, the picture has improved considerably with progressively fewer incidents being related to maintenance issues, principally due to the introduction of the ISM Code, more vigilant PSC inspections, additional regulation as well as higher commercial expectations in respect of how ships should be operated.
In response to the change in claims experience, the UK P&I Club’s Board of Directors requested the loss prevention department to adapt the ship visit regime to focus on the factors that currently cause claims. A “bowtie” scheme was adopted featuring identified preventive controls which are designed to prevent an incident which may lead to a claim from occurring as well as recovery controls in place for mitigating the effects of an incident. The following hazard areas are included in the scheme: personal injury & health, navigation & port risks, pollution, cargo and equipment failure.
The following diagrammatic example shows a simple bowtie for bilge and slop operations. Ratings for each control are entered into a vessel type spreadsheet by the assessor, from which a report is generated providing a list of the assessor suggestions for improving controls as well as an overall risk factor score.
Pollution Hot Spots
It is not unusual to find incorrect or incomplete entries on an Oil Record Book. Usually, this is merely a misunderstanding on the part of the Chief Engineer as to how entries should be made rather than a deliberate attempt to deceive. In such cases, we communicate to the Chief Engineer the IMO MEPC.1 Circ. 736/ Rev.2 which provides guidance on the matter as well as our related Technical Bulletin.
The Oily water separator is an item of critical equipment which requires periodically maintenance and checks in accordance with manufacturer’s instructions. Furthermore, clear procedures and instruction notices should be posted at the equipment as shown. Associated with the oily water separator is the overboard discharge valve which is usually kept locked and sealed when not use. The Club assessors frequently provide advice with respect to improving locking and sealing arrangements as well as proper control of transfer equipment. The essential aim is for the chief engineer to have full control of the equipment so as to deny any unauthorized access. However, if keys to locking devices are left hanging in the control room, all preventive actions taken may go to waste. The keys should always be kept under the sole custody of the Chief Engineer.
Bunkering plans and checklists are important working documents designed to ensure bunkering procedures are followed correctly. The Club assessors sometimes note that checklists are being completed by the Chief Engineer after the completion of bunkering in his office, rather than at the time and place of the task. Pre-work planning meetings and tool box talks should also be carried out involving all persons involved in the operation. Bunker manifolds and valves should be clearly labelled and colour coded to reduce the risk of an incorrect hose connection or valve operation which may result in tank overflow and bunker contamination. Oil spill containment measures will also be checked by the assessors by ensuring that scupper and saveall plugs are properly fitted and in good condition.
Garbage management requires the proper segregation of garbage onboard. Therefore separate labelled and colour coded bins for each garbage category should be provided of sufficient capacity for operational requirements. The segregation starts at the point where the garbage is deposited. Improper segregation will not only constitute a contravention MARPOL requirements but may also present a fire hazard.
In general, it is of the utmost importance to exercise good housekeeping, maintenance and cleanliness of all spaces and equipment on board to prevent pollution incidents. The less waste that is generated, the easier it is to handle and control. The Club assessors will also verify that the crew is capable of responding to an oil spill incident, that relevant drills and training are carried out and proper clean up equipment is readily available.
Above text is an edited article of David Nichol’s presentation during 2017 GREEN4SEA Conference & Awards
You may view his presentation video by clicking here
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The views presented hereabove are only those of the author and not necessarily those of GREEN4SEA and are for information sharing and discussion purposes only.
David Nichol, Regional Loss Prevention Executive, Thomas Miller P&I (Europe) Ltd
David Nichol is a master mariner with 39 years of experience in the shipping industry. After sea service on tankers, bulk carriers and OBO’s, he worked as a ship surveyor and marine consultant for 18 years performing a wide range of casualty investigations, ship inspections and cargo surveys, with the majority of assignments being P&I related. From 2010, he was employed as a P&I Club senior claims executive before joining the loss prevention department of the UK P&I Club 3 years ago. David is based is the UK Club’s Piraeus office assisting members with loss prevention advice, training and education initiatives, as well as carrying out regular shipboard P&I risk assessments