1.4 MARPOL (Challenge Questions)

Question 1

What is the significance of 1st Jan 2020 (IMO 2020) with respect to MARPOL Annex VI?

Answer 1

On and after 1 January 2020, MARPOL permitted limit for sulphur content in ships’ bunker fuel oil will be reduced from 3.50% mass by mass (m/m) to 0.50% m/m for ships operating outside designated emission control areas.

Question 2

What is the obligation of the Master and shipowner if they are unable to obtain IMO2020-compliant fuel?

What is FONAR?
(Hint: https://www.nortonrosefulbright.com/en-au/knowledge/publications/5c72cf58/enforcing-imo-2020-are-we-ready)

Answer 2

If, despite best efforts, it was not possible to procure compliant fuel oil, the Master or shipowner must immediately notify the port and flag state. This notification by the ship is commonly referred to as a Fuel Oil Non-Availability Report (FONAR).

As per the 2019 Guidelines, the FONAR has a standard reporting format but state parties may develop more detailed guidance. The submission of a FONAR does not render a ship compliant with the Regulations but rather is a factor that shall be taken into account by a port or flag state when determining what steps to take against a ship for non-compliance.

Question 3

What is the discharge criteria for discharging oil-cargo residues originating from cargo spaces and cargo pumprooms of an oil tanker?

Answer 3

Discharging oil-cargo residues originating from cargo spaces of an oil tanker:
As per MARPOL Annex I, Reg 34:
Outside Special Area:
- Tanker is not in a special area.
- More than 50nm from the nearest land.
- En route.
- Instataneous rate of discharge not more than 30L/nm.
- Total quantity of discharge of residue does not exceed 1/15000 for existing ships and 1/30000 for new ships of the total quantity of cargo residue.
- Tanker must have a ODMCS and a slope tank arrangement.

Inside Special Area:
- Prohibited to discharge.
- Does not apply to clean or seggregated ballast.

Discharging oil-cargo originating from cargo pumprooms of an oil tanker:

Question 4

New Zealand has not ratified MARPOL Annex VI. Will a vessel registered in New Zealand be exempt from IMO 2020 when it is visiting an Australian port?
(Hint: Parties to the Convention must apply the requirements of the Convention to ships of non-Parties to ensure that no more favourable treatment is given to such ships.)

Question 5

What are the codes relating to MARPOL Annex III?

Answer 5

IMDG

Question 6

What is the discharge criteria to pump out oily bilges from the vessel.

E.g 6 nm off perth, engineer wants to discharge. What would your answer be?

Answer 6

As per MARPOL Annex I Regulation 15

• Oily mixture does not originated from cargo pump room.
• Oily mixture not mixed with oil cargo residues.
• En route.
• Effluent without dillution not more than 15ppm.
• Must pass through an Oil Filtering Equipment onboard.
• Automatically stops when content exceeds 15ppm. (Device)
• No discharge within Antarctic and Arctic Area.
• The vessel should try it’s best to discharge outside the special area before entering the special srea.