Maritime Questions › Annex2 3 Command
A drum marked as a Marine Pollutant (Annex III/IMDG) is lost overboard during cargo operations in port. Your examiner asks: "What are your reporting obligations as Master?"
A. Report the loss as a pollution incident under MARPOL's reporting provisions (in addition to any port/terminal incident reporting and the vessel's own SMS incident reporting under the ISM Code), giving the substance identity, quantity and circumstances — the Marine Pollutant marking specifically exists to trigger this reporting obligation even though the package may otherwise be small in physical size or quantity compared with a major spill.
B. No MARPOL reporting obligation arises from losing a single packaged item overboard, regardless of its Marine Pollutant marking.
C. Reporting is required only if the package is confirmed to have actually ruptured and released its contents, not merely lost overboard intact.
D. Marine Pollutant incidents are reported exclusively to the cargo insurer, with no flag state or coastal state MARPOL reporting obligation.
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A. Decline the booking, or insist on a tank arrangement that the vessel's actual certification covers — carrying a substance in a tank/arrangement not covered by the approved Certificate of Fitness and P&A Manual is not a commercial risk to be weighed against charter revenue, it is a compliance and safety limit; the ISM Code's master's-overriding-authority provision exists precisely to protect this kind of decision from commercial pressure.
B. Accept the booking provided the charterer indemnifies the vessel in writing against any MARPOL enforcement action.
C. The decision should be deferred entirely to the company's commercial department, since certification compliance is treated as a shore-side administrative matter, not a Master-level safety decision.
D. Any noxious liquid cargo may be carried in any tank provided the quantity is below a certain threshold, regardless of the vessel's actual certification.
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A. The discharge criteria are a fixed environmental/legal requirement, not a target to be approximated — the vessel must either maintain the required speed/distance/conditions for the discharge to proceed lawfully, delay the discharge until those conditions can be met, or retain the washings for shore disposal; schedule pressure does not create an exception to Annex II discharge criteria, and proceeding with a non-compliant discharge exposes the vessel and Master to real enforcement risk in addition to being a genuine pollution-prevention failure.
B. Minor shortfalls against the discharge criteria are acceptable provided the Oil Record Book — not the Cargo Record Book — reflects the discharge accurately.
C. Scheduling pressure is a valid basis to proceed with discharge outside the criteria, provided the company commercial department approves it in writing.
D. Discharge criteria under Annex II apply only inside Special Areas; outside Special Areas there is no minimum speed or distance requirement at all.
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