Oily water separator failure with pressure to discharge illegally

The proposal is illegal, irrespective of the distance offshore.

• Annex I requires that any discharge of oily bilge water from machinery spaces go through oil filtering equipment producing an effluent of not more than 15 ppm, with the 15 ppm alarm and the automatic stopping device in operation, the ship under way, and the discharge not diluted to achieve compliance. With the alarm defective and the separator contaminated, there is no compliant route to the sea. The 60 nm distance removes the special-area prohibition; it does not remove the equipment requirement.
• Bypassing the separator with a temporary hose is a 'magic pipe'. It is a deliberate discharge of oil, criminal in most jurisdictions - including flag state law and the laws of almost every coastal state - with penalties for the company, the master, the chief engineer and anyone who assists.
• The cadet and the OOW are exposed. Witnessing or assisting is aiding the offence, and failing to report it can be treated as complicity. The correct response for any junior officer is to refuse and to report, in writing if necessary, to the master and the DPA.
• The master has overriding authority under the ISM Code to refuse a discharge that would breach the convention, and to refuse any instruction from the company or the charterer that conflicts with safety or pollution prevention.

What is legal: retain the bilge water on board, or repair the equipment and then discharge through the compliant route with an ORB Part I code C entry. Nothing in the convention requires the water to go to sea.

1. Stop making bilge water. Reduce the inflow: fix leaks, use drip trays under the purifiers and fuel/lube oil fittings, avoid water washing of machinery spaces, and collect small quantities in drums. A 1.2 m³/day rate can often be halved by housekeeping alone, and the holding tank then lasts longer.

2. Repair the equipment. Fit the spare 15 ppm alarm unit, clean or replace the separator coalescer, and obtain the correct insert through the agent at the next port or by launch. Get the manufacturer's service documentation and a service report as evidence that the equipment is compliant. Test with a calibration check on the alarm and a sample through the separator before any discharge.

3. Use the remaining capacity with a plan. At 9.5 of 12 m³ with two days to overflow, plan the last transfer into the holding tank, keep the tank sounding log, and if necessary put the excess into a certified portable tank or drum for shore disposal - this must itself be recorded and landed through a licensed reception facility, not dumped.

4. Land it. Arrange a reception facility at the discharge port, or at an anchorage if there is a barge, and record the receipt and the quantity in the ORB (code C) and the garbage/oily waste records. Annex I requires adequate reception facilities for this purpose and a port cannot refuse a reasonable request.

5. Tell the company. Report the equipment failure to the DPA immediately, request the spares and the repair budget, and record the decision path. A documented request that is refused is powerful protection for the master and the ship's officers.

6. Contingency. If the tank genuinely cannot be kept from overflowing, the options are to slow the accumulation, to transfer to another approved tank after checking the piping diagram, or to amend the passage plan to reach a port with facilities sooner - not to discharge.

Immediate response

• Do not destroy or hide it. Secure the hose, the pump connection and the area, photograph and tag them, and log the find with the time, place and who was present.
• Report up and out. Inform the master in writing, and report to the company DPA and, if the master is involved, direct to the DPA under the company's whistleblowing procedure. Do not wait for the next port.
• Preserve the paper trail. The Oil Record Book, the tank soundings, the engine room log, the alarm history and the maintenance records are the evidence. Making a false entry in the ORB is itself an offence, and altering or 'tidying' the book after the event converts a discharge problem into an obstruction problem.
• Prepare for port state control. A magic pipe, an inoperative 15 ppm alarm, a hose with oil residue and a mismatched ORB are classic detention and prosecution triggers. Expect an expanded inspection; have the equipment repaired, the records straight and the crew briefed to state the facts.

What should have been recorded at the time

• The date and nature of the 15 ppm alarm failure and the separator defect, in the engine room log and the planned maintenance system.
• The chief engineer's instruction and the master's decision, including a refusal, with the time and the names.
• Bilge holding tank soundings twice daily, all transfers, and the ORB Part I code C entries for retention and for shore disposal, with the reception facility receipts.
• The DPA notification and the request for spares.

A written record made at the time is what distinguishes the officer who refused from the officer who assisted, and it is what the company, the flag state and any court will look at first.