Question 1

While alongside in a UK port, your vessel's fuel tank overflows due to a defective valve, releasing approximately 50 litres of diesel into the dock. What are your immediate obligations?

Accepted Answer

PORT OIL SPILL — immediate obligations: (1) STOP THE SPILL: close the valve; stop any fuel transfer; identify and isolate the source; (2) NOTIFY PORT AUTHORITY: immediately report to the harbour master via VHF or telephone — port operators are required to have pollution response plans; (3) NOTIFY COASTGUARD: MCA Maritime Rescue Sub-Centre or MRCC — all discharges in UK waters must be reported under the Merchant Shipping (Oil Pollution) Act 1971 and MARPOL; the National Pollution Hotline (0800 80 70 60) should be called; (4) SOPEP ACTIVATION: activate the vessel's SOPEP if the spill is significant — deploy boom and absorbent pads if the vessel carries them; (5) OIL RECORD BOOK: record the incident accurately — time, nature of spill, volume estimate, actions taken; (6) COMPANY/DPA: notify immediately — DPA coordinates with P&I Club who manages pollution liability; (7) RETAIN EVIDENCE: photograph the spill, the defective valve, and any containment action taken; (8) DO NOT ADD DETERGENT: do not attempt to disperse the spill with washing-up liquid or detergents without coastguard approval — dispersants require MCA/EA authorisation in UK port waters. There is no minimum threshold for reporting oil discharges to UK authorities — ANY discharge of oil into UK waters must be reported. The Merchant Shipping (Oil Pollution) Act 1971 and MARPOL Annex I both create reporting obligations. In port, the harbour master is the first point of contact followed by the MCA. Diesel vs HFO: diesel (gas oil) is less persistent in the marine environment than HFO — it evaporates more quickly and is less likely to cause lasting environmental damage. However, it is still toxic to marine organisms in the short term and its discharge is still illegal. Dispersants in port: the use of chemical dispersants to break up oil in port waters is controlled. In the UK, dispersants require approval from the Environment Agency (EA) and MCA — using washing-up liquid (as is sometimes attempted) is not approved and can spread the contamination. The correct approach is physical removal: booms to contain, sorbent pads to recover. P&I Club involvement: the P&I Club manages environmental liability and pollution cleanup costs. Their correspondent should be contacted immediately — they can arrange specialist oil spill response contractors if the spill is beyond the vessel's own response capability.

Question 2

You are master of a 350 GT near-coastal cargo vessel. The engine room bilge is filling and you are 8nm offshore. Can you discharge bilge water overboard and under what conditions?

Accepted Answer

MARPOL Annex I bilge water discharge — small vessel rules: MARPOL Annex I Regulation 15 covers machinery space bilge water. For vessels of 400 GT and above: bilge water may be discharged overboard only if: (a) outside Special Areas; (b) more than 12nm from the nearest land; (c) vessel is en route (not at anchor or in port); (d) oil content does not exceed 15 ppm (monitored by approved OCM); (e) Oil Record Book entry made. For vessels BETWEEN 400 GT and 400 GT (your vessel at 350 GT): MARPOL Annex I Regulation 15.2 applies a different regime — vessels of less than 400 GT must retain oil residues and bilge water on board or deliver to port reception facilities. There is no 15 ppm discharge provision for vessels under 400 GT outside special areas. PRACTICAL IMPLICATION: your 350 GT vessel CANNOT legally discharge bilge water overboard at 8nm. Options: (a) Pump to the bilge holding tank; (b) Continue to port and discharge to reception facilities; (c) If flooding emergency — it may be necessary, but this is a distress provision only. MARPOL Annex I has different requirements for different vessel sizes. The key threshold is 400 GT. At 350 GT, this vessel falls below the 400 GT threshold — the Regulation 15.2 retention requirement applies. This is a detail frequently missed. For vessels of 400 GT and above, the 15 ppm overboard discharge provision in Regulation 15.1 applies (with the 12nm and underway conditions). For vessels 400 GT and above in special areas (Baltic, North Sea, Antarctic, etc.): zero discharge — all must be delivered to port reception facilities. Special areas for MARPOL Annex I include: the Mediterranean, Baltic, Black Sea, Red Sea, Gulfs Area, Gulf of Aden, Antarctic, North West European Waters (including North Sea and English Channel). These are heavily enforced.

Question 3

Your near-coastal vessel is 15nm offshore. The cook wants to throw over the side: (a) food scraps, (b) plastic packaging, (c) paper. What does MARPOL Annex V permit?

Accepted Answer

MARPOL Annex V (as amended 2013) — garbage discharge: (a) FOOD WASTE: may be discharged in territorial sea (>3nm from nearest land) or in special areas (>12nm from nearest land) only when comminuted or ground (passed through 25mm mesh) and the vessel is en route. Outside special areas and >12nm from land: food waste may be discharged without comminution provided it does not create a floating debris hazard; (b) PLASTIC — ALL FORMS: completely prohibited for overboard discharge in all ocean areas. This includes synthetic fishing nets, plastic bags, plastic packaging of any kind. No minimum distance applies — plastic NEVER goes overboard; (c) PAPER, RAGS, GLASS, METAL, CROCKERY: prohibited within 12nm from nearest land; permitted (outside special areas) beyond 12nm from land. IN THIS SCENARIO: food scraps at 15nm — permitted with caution (outside special area, >12nm, en route). Plastic — ABSOLUTELY PROHIBITED at any distance. Paper — permitted at 15nm in non-special areas. A Garbage Management Plan (for vessels 100 GT+) must be carried and followed. MARPOL Annex V (2013 amendments): the plastic prohibition is absolute — there is no distance at which plastic can legally be discharged overboard. This applies to all vessels of all sizes, in all sea areas. MARPOL defines "garbage" broadly: all kinds of victual, domestic and operational waste. Garbage Management Plan: required for all vessels of 100 GT+, and vessels certified to carry more than 15 persons. Must specify: procedures for the collection, storage, processing, and disposal of garbage; person responsible. The Garbage Record Book is required for vessels of 400 GT+ and those certified to carry 15+ persons. Special areas for MARPOL Annex V (more restrictive): Mediterranean, Baltic, Black Sea, Red Sea, Wider Caribbean, Antarctic, North Sea. Food waste restrictions in these areas are tighter (>12nm, comminuted/ground required).