VIQ 6.5

On one of our tankers, inspector gave following observation
“Fixed piping system was provided to transfer E/R bilge to slop tank (P). However, it was not remarked in IOPP Certificate as the approved means for disposal of bilge in E/R.”
I could not find any mention in MARPOL Annex 1 that this piping system shall be shown as approved means except IOPP Form “B” section 3.2.4.
Also, class confirms that it is not mandatory to show this in IOPP certificate.
Can someone enlighten me on this observation????

  
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4 Comments

  1. souroulias
    Aug 10, 2011

    it should be recorded after verification by Class on item 3.2.3 under the “other acceptable means” category. No idea why class has replied that it is not required. ABS & DNV duly record clearly same .

  2. Bash Sarkar
    Aug 10, 2011

    Would be nice to know which Class. 3.2.3 remark is pretty standard to record this. Also this is absolutely required to avoid any Oil Record Book infringements as without official remark on the IOPP this becomes impossible to show how and why sludge was transferred. Mind you there is commercial angle to this too. Beware of cargo contamination, unless you’re an Oil Company carrying your own cargo. Always a good idea to inform charterers that sludge has been transferred…

  3. nksharma
    Aug 11, 2011

    Thanks for all your comments. I thinks the entry can only be made in IOPP form “B” 3.2.4 not 3.2.3.
    But my basic question is which MARPOL regulation or MEPC guides such observation? I have seen class rules to follow for such transfer but nothing is mentioned in MARPOL.

  4. Amit Jain
    Aug 12, 2011

    From a safety point of view (and somewhere in SOLAS as well), you are connecting a hazardous zone to a non-hazardous zone by running a pipeline and in my understanding any Class would be keen to survey this item to confirm that measures are in place to prevent back flow of gases to engine room.

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