Midnight Bypass: Oily Bilge, a Wired Alarm and a PSC Inspection Tomorrow
A 5,000 GT cargo ship is alongside at Aktau. The engine room bilge holding tank is nearly full, with about 14 m³ of oily bilge. The oil water separator's 15 ppm alarm has been intermittent for three days, and the second engineer has wired a bypass so the pump can run and the bilges discharge straight overboard. He says the previous chief did the same, that the shore reception service takes four days to arrange and costs USD 4,000, and that the charterer is pressing for departure. The PSC inspection is scheduled for the morning. You find no Oil Record Book entries for the last two weeks and the 15 ppm alarm sensor is unplugged. You are called to the engine room at 00:30.
1. State your immediate actions and the legal position you explain to the second engineer.
Read the worked answer
Stop the operation now. Isolate the pump, remove the bypass wire, tag the breaker and the valve, and re-plug the alarm sensor or physically secure the overboard line blank so the discharge cannot be repeated by anyone on the next watch. Note the time, the tank soundings, whether there is a sheen alongside, and photograph or record the wiring as found - this becomes evidence either way.
Legal position: MARPOL Annex I Regulation 15 permits discharge of machinery-space bilge only through 15 ppm oil filtering equipment, with the ship proceeding en route and outside any special area; a ship alongside in port fails the en route condition on its face, so even a perfectly working separator would not make this discharge lawful. Bypassing the alarm is not a technical shortcut, it is an intentional discharge of oil, and it exposes the ship, the owner, the master and the individual engineer to criminal and administrative liability under the flag state and the port state, quite apart from Kazakhstan's national rules and the port's own requirements. The fact that 'the previous chief did the same' is an aggravating systemic finding, not a defence.
Tell him clearly and privately that the discharge has stopped, that he is not to operate the separator until it is repaired and re-tested, and that a written statement will be taken. Do not destroy the wiring before it has been recorded.
2. Explain the Oil Record Book position: what must be recorded, by whom, and why two weeks of silence is itself a serious finding.
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The Oil Record Book, Part I covers machinery-space operations. Every transfer, retention, treatment and discharge of bilge water, every malfunction of the 15 ppm equipment, and every delivery to a shore reception facility must be entered as it happens - date, time, tank, quantity, and the operation code - by the officer in charge of the operation, and each completed page is signed by the master. Entries are made in ink in chronological order; corrections are a single line through, initialled and dated, never an erasure or a rewritten page.
So the record must now show: the equipment failure and its dates; that discharge was stopped; the quantity retained in the holding tank; the eventual transfer ashore with the reception facility's receipt reference; and the repair and re-commissioning test of the 15 ppm equipment with Class or service attendance.
Two weeks of silence is serious for three reasons. First, an ORB is a statutory record; missing entries are an offence in themselves and under Annex I the book must be retained on board for three years. Second, gaps in a book that PSC compares against tank soundings, soundings logs and reception receipts read as concealment - and a book that has been falsified is treated far more severely than a book that shows an honest malfunction. Third, it tells the port state that the ship's SMS is not detecting its own non-conformities, which goes to the ISM audit and possibly to the company's Document of Compliance, not just to this ship.
3. Set out the plan to get the ship to sea lawfully, and how you handle the PSC inspection.
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Capacity and containment first: with 14 m³ in a nearly full holding tank, identify an empty tank or a certified portable container that can lawfully hold the bilge, so the ship has retention capacity for the planned voyage. If capacity cannot be found, the ship cannot sail - a ship that must either discharge or overflow will discharge.
Reception: book the licensed shore reception facility through the agent even at the quoted cost; four days is a commercial problem, not a legal excuse. Obtain and file the receipt, and enter the transfer in the ORB against that receipt.
Repair: raise a defect for the 15 ppm alarm, get the maker's service or Class attendance, fit the sensor, and prove the equipment with a witnessed test; record the repair and the test result. If parts cannot be obtained in Aktau, the options are a condition of class with the flag state's agreement, a voyage with verified retention capacity and the separator isolated and tagged as defective - not a voyage with a bypass. Notify the company and the DPA formally the same night: this is an ISM non-conformity and a reportable incident, and the company's response is part of the record.
PSC: declare the defect. Show the isolated and tagged separator, the repair order, the ORB entries, the reception booking, and the written statements. A port state that finds a declared and contained defect deals with it as a deficiency; a port state that finds a wired alarm and a blank book deals with it as a detention and possibly a prosecution. Voluntary disclosure, done before the inspector finds it, is the only course that keeps the master and the ship in control of the outcome.