Maritime Questions › Marpol Nc
The refrigeration engineer tells you the vessel's galley refrigerator needs re-gassing. It uses R-22 (HCFC). What regulatory considerations apply?
A. REFRIGERANT GAS REGULATIONS: R-22 (chlorodifluoromethane, HCFC-22) is an ozone-depleting substance regulated under the Montreal Protocol (1987) and its Kigali Amendment. EU/UK REGULATIONS: the EU F-Gas Regulation (No 517/2014) and UK equivalent (retained post-Brexit): (1) R-22 PROHIBITION: R-22 was phased out — in the EU/UK, use of virgin R-22 for servicing was prohibited from 1 January 2015; (2) RE-USE/RECYCLED: recycled R-22 may still be used for servicing existing equipment in some categories, but this is increasingly restricted; (3) IN PRACTICE: most refrigeration engineers do not carry R-22 anymore; the practical solution is to RE-GAS with an approved substitute refrigerant (R-407C, R-290 propane-based, or others) after conversion of the refrigeration system by a certified engineer; (4) CERTIFIED ENGINEER: refrigerant handling in the UK requires an F-Gas certified engineer — certification under EU Regulation 303/2008 or UK equivalent; an uncertified person cannot legally handle refrigerants; (5) MARPOL ANNEX VI Regulation 12: prohibits deliberate emissions of ozone-depleting substances. Intentional venting of R-22 is prohibited and potentially criminal; (6) SHIP'S LOG: refrigerant quantities used and recovered must be recorded.
B. R-22 is a standard industrial refrigerant available in any gas supply depot. Any engineer can re-gas the refrigerator without special certification.
C. MARPOL does not cover refrigerant gases — these are governed solely by domestic health and safety regulations that do not apply to vessels at sea.
D. Release the old refrigerant to atmosphere before re-gassing — this is standard procedure for refrigerant changeover and has no environmental implications.
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A. 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.
B. Any vessel can discharge bilge water beyond 3nm from shore. MARPOL only applies to vessels over 1000 GT.
C. Discharge is permitted at 8nm as long as the bilge water is mixed with sea water to reduce the oil content below 50 ppm.
D. MARPOL does not apply within territorial waters (12nm). Beyond 12nm, all bilge water discharge by any vessel is unrestricted.
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A. 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.
B. Food scraps and paper can always be discharged more than 3nm offshore. Plastics can only be discharged if they are biodegradable.
C. MARPOL Annex V only applies to commercial vessels over 5000 GT. Small near-coastal vessels are exempt from all garbage regulations.
D. All waste can be discharged at more than 12nm offshore — this is the MARPOL Annex V general limit for all waste types.
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