A capped 15 ppm alarm eight miles off the coast

Immediate answer. No. He makes no entry until the facts are established, and he certainly does not write "internal transfer" for an overboard discharge. The ORB is a statutory record; a false entry is a separate and usually more serious offence than the discharge it conceals, and it destroys the only contemporaneous evidence that might later protect him.

The legal position.

• MARPOL Annex I Regulation 15 allows machinery space bilge water overboard only where all the conditions are met: the ship is proceeding en route, the mixture is processed through 15 ppm equipment compliant with Regulation 14, and the effluent without dilution does not exceed 15 ppm. There is no distance allowance in Regulation 15 - the 12 nm and 50 nm figures people quote belong to other discharges, not bilge water.
• A capped alarm defeats the required alarm and automatic stopping device. From that moment the ship has no compliant oil filtering equipment in operation, so the Regulation 15 basis fails even if the true oil content happened to be under 15 ppm. The equipment deficiency is itself a Regulation 14 breach.
• At 8 nm the ship is inside the territorial sea. MARPOL does not authorise a discharge there; the coastal State's own law applies and Nigeria, through NIMASA, restricts discharges in its waters. The master should be in no doubt that he is relying on nothing when he relies on "we were outside 12 miles".
• Intentional discharge from a ship of this size is a criminal matter for the flag State and the coastal State, and a detainable deficiency for a port State.

What I do next. Tell the Third Engineer to keep the capped alarm and wired valve untouched as evidence, and report to the master immediately - not to the Chief Engineer first, and not to the Cargo Control Room. The master has the overriding authority, and this is exactly the decision that authority exists for.

I decline to make the false entry, and I put that in writing. An unlawful order does not transfer the criminal liability to the master; the person who signs or makes a false ORB entry is exposed in their own right, and the OOW is the officer who would sign the page.

Sequence.

1. I tell the master at once, in the presence of a witness if possible, that I will not record a discharge as a transfer, and I state what I believe happened: alarm capped, valve wired open, two hours' discharge, 8 nm off the coast.
2. I make a factual entry in the ship's logbook and a note of protest/letter to the master, timed and dated, recording what I was told, what I observed, what I was instructed to do, and that I declined. I keep a copy. If the ORB has not yet been completed, I leave it unaltered rather than "correcting" it.
3. I inform the company through the Designated Person Ashore under the ISM Code. The DPA route is the one mechanism the system gives a junior officer, and it works best when used immediately and factually, not as a threat.
4. If nothing is done, the seafarer's complaint procedures under MLC 2006 Title 5 and the SMS give me a route to the flag State, and I can raise it with the port State Control officer at the next port or through the pilot/agent. The master cannot lawfully prevent a report of a suspected pollution offence.
5. I preserve evidence: the alarm unit, the wiring, the ORB pages, the tank soundings, the GPS track and time, the engine room log entries, and the names of everyone present.

Tone matters. This is not insubordination; it is a refusal to commit an offence. The master may genuinely be trying to protect his Chief, his ship and his own career. The answer is to make the lawful position clear and put the decision back where it belongs, documented.

What the PSCO will look at, in roughly this order:

• The International Oil Pollution Prevention Certificate and its supplement; the ship's SMS procedures for bilge water and the SOPEP.
• The Oil Record Book, Parts I and II: completeness, sequence, consistency with tank soundings, with the engine room log, with port reception facility receipts, and with the vessel's track. Any entry that does not add up invites an expanded inspection.
• The oily water separator: physical condition, the 15 ppm bilge alarm, the automatic stopping device, the calibration certificate, and a functional test. A capped alarm or a bypass pipe will be found by a competent inspector within minutes.
• The bilge holding tank soundings and the piping arrangements - a "magic pipe", a hidden hose, or a valve wired open is a detention item.
• Annex V and Annex VI records: Garbage Record Book and plan, bunker delivery notes, the sulphur changeover logbook, and the Ballast Water Record Book and management plan.

Likely outcome. If the tampering is still present, the ship is detained: inoperative pollution prevention equipment and evidence of an intentional discharge are clear grounds for detention under the port State control procedures, with a notification to the flag State and classification society and an entry in the inspection database. The master, the Chief Engineer and the company face administrative and criminal exposure in Nigeria, and the flag State will run its own investigation. If the discharge has stopped and the equipment has been restored and proven, the position is much better - but the false ORB entry, if one was made, is a far worse finding than the discharge itself.

Practical point for the ship. The best protection at the boarding is a complete, honest, consistent paper trail. Concealment converts a rectifiable equipment deficiency into an allegation of deliberate pollution.