PSC Inspection Finds an OWS Bypass and Inconsistent Oil Record Book
During a port State control inspection in Baku, the inspector finds a flexible hose connected from the bilge main to the overboard line, bypassing the oily water separator. The 15 ppm alarm sensor is wired in the alarm position, and the separator's alarm test record has not been completed for three months. The Oil Record Book Part I contains entries stating that bilge water was transferred to the holding tank, but the holding tank is empty. The chief engineer says the superintendent told him to keep the bilges empty because the holding tank was needed for cargo residues. The master is on the bridge and has not yet been informed. The ship is due to sail in six hours.
1. What are your immediate actions on discovering the bypass during the inspection?
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Stop the inspection from becoming a confrontation, but do not conceal anything. Immediately inform the master and the company's designated person ashore. Instruct the engine room to stop all bilge discharges and isolate the flexible hose. Do not remove or alter the hose, the wiring, or the Oil Record Book before the inspector has photographed and recorded them; preserving evidence is essential, but the unsafe bypass must be made safe under supervision.
Actions:
- Acknowledge the finding to the inspector factually and cooperate.
- Isolate the bypass and secure the overboard valve. Record the time and who isolated it.
- Confirm the oily water separator is not in use and that no discharge is taking place.
- Inform the master, who must contact the company and flag State/class as required.
- Provide the inspector with the Oil Record Book, separator maintenance records, alarm test records, and bunker/sludge receipts. Do not create new entries retrospectively.
- Expect a detention or prohibition of discharge. Do not press for sailing until the port State confirms the ship may proceed.
The master should issue a letter of protest only for factual disagreements, not to obstruct the inspection. The company should arrange legal and technical support.
2. How should the investigation be conducted, and what records must be examined?
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The investigation should establish who installed the bypass, when, and why, but it must also examine the system that allowed it. Start with the physical evidence: the hose, connections, valve positions, alarm wiring, and separator condition. Photograph and tag them before removal. Interview the chief engineer, duty engineers, oiler, and superintendent, and record statements factually.
Examine:
- Oil Record Book Part I entries against holding-tank soundings, transfer pump running hours, and sludge receipts;
- separator maintenance and alarm test records for the last 12 months;
- bilge holding tank capacity and cargo-residue records;
- requisition and disposal receipts for sludge and bilge water;
- superintendent's emails or instructions, and the budget for shore disposal;
- alarm data logs and any override history.
The investigation should determine whether this was a one-off act, a tolerated practice, or a system failure. Check whether the holding tank was genuinely needed for cargo residues and whether shore reception facilities were available at previous ports. Under MARPOL Annex I, discharges of oily bilge water must comply with the 15 ppm limit and be recorded; bypassing the separator is a serious violation. The company should preserve documents for the flag State and port State and consider independent legal advice.
3. What corrective actions and cultural changes should follow, and how should the master and chief engineer handle the commercial pressure?
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The immediate corrective action is to restore the separator and alarm to proper working order, test the 15 ppm alarm, calibrate the oil content meter, and remove the bypass permanently. The ship should not sail with a prohibited discharge arrangement. If the separator cannot be repaired, the bilge water must be retained and discharged to shore reception facilities, with the voyage plan adjusted accordingly.
Longer-term actions:
- Train all engineers on MARPOL Annex I requirements and the Oil Record Book.
- Require weekly alarm tests and monthly separator checks with records.
- Ensure the holding tank is reserved for its intended purpose and that shore disposal is budgeted.
- Introduce a whistleblower or confidential reporting channel.
- Audit the superintendent's instructions and the company's environmental policy.
The master and chief engineer must resist commercial pressure with a clear written position: the ship cannot discharge untreated bilge water, and any instruction to do so must be refused and reported. The master should inform the company that the ship may be detained and that the company must provide shore reception or repair. The chief engineer should document the instruction and the refusal. The company should review the superintendent's conduct and the budget constraints that encouraged the bypass. Disciplinary action may follow for deliberate falsification, but the root cause must also be corrected.