Question 1

You arrive at a port in a MARPOL special area and request reception facilities for oily bilge water. The port authority says none are available. What are your options and obligations?

Accepted Answer

MARPOL Article 8 and Regulation 12: port states are obliged to provide reception facilities. If facilities are inadequate or unavailable, you must report this to the flag state and IMO using the IMO MARPOL reception facility reporting format. You may retain the oily water on board and proceed to the next port. You must NOT discharge in the special area. The master should document the port's failure to provide facilities as this provides a defence record and supports the IMO reporting mechanism. The flag state must forward the report to IMO. MARPOL requires port states to provide reception facilities, but enforcement of this obligation is weak in practice — many ports worldwide lack adequate facilities. This is a genuine operational problem in certain special areas. The correct procedure: document the request and refusal in writing; retain the waste on board; proceed to a port where facilities are available; report the inadequacy to the flag state for onward reporting to IMO. IMO maintains a global database of reports of alleged inadequacy of reception facilities (GISIS). Critically, inability to find reception facilities does NOT create a legal right to discharge in a special area — the prohibition is absolute. Port captaincy reports of inadequate facilities have led to improvements in several ports through MARPOL diplomatic pressure.

Question 2

Your examiner asks: "What are the six MARPOL Annexes and what does each cover?" Give a complete answer.

Accepted Answer

Annex I: Oil (mandatory). Annex II: Noxious Liquid Substances in bulk — NLS (mandatory). Annex III: Harmful Substances in packaged form (mandatory). Annex IV: Sewage (mandatory for new ships from 2003; existing ships phased in). Annex V: Garbage (mandatory). Annex VI: Air Pollution from ships — SOx, NOx, ODS, VOC, shipboard incineration (mandatory). All six are now mandatory for parties to MARPOL 73/78. MARPOL 73/78 entered into force 2 October 1983. Originally Annexes I and II were mandatory; III-VI were optional. However, all six are now effectively mandatory as all major flag and port states have ratified all annexes. Key for OOW orals: Annex I (oil) governs the Oil Record Book Part I (machinery space operations) and Part II (cargo/ballast for tankers). Annex V (garbage) governs the Garbage Management Plan and Garbage Record Book. Annex VI (air pollution) includes ECA requirements for 0.1% sulphur fuel in Emission Control Areas (North Sea, Baltic, North American coast, US Caribbean). Candidates must know which annex covers which pollutant — examiners cross-test by describing a pollutant and asking which annex applies.

Question 3

Your vessel is 18 nautical miles offshore in a non-special area. Can you discharge food waste overboard? What about plastic? Describe the MARPOL Annex V discharge requirements.

Accepted Answer

Food waste: may be discharged at least 12nm from nearest land (comminuted/ground food waste at 3nm or more). Plastics: ZERO discharge anywhere at sea — a complete ban regardless of distance or location. Paper, rags, glass, metal, bottles: minimum 12nm from land (not in special areas). Garbage mixed with other substances having different discharge requirements must meet the stricter standard. A Garbage Management Plan and Garbage Record Book are required for vessels 100 GT+. MARPOL Annex V (revised 2013, Reg 3): the key principle is that ALL plastics are banned from any discharge at sea — this is absolute and applies everywhere. Food waste: at least 12nm from nearest land in normal areas; 3nm if comminuted/ground through a screen of no more than 25mm. Special areas (Baltic, Black Sea, Antarctic, etc.): comminuted food waste at 12nm minimum; no other food waste discharge. Dunnage, linings, packing materials: at least 25nm (if not plastic). The Garbage Management Plan (required for ships 100 GT+) must specify procedures for all garbage streams. The Garbage Record Book entries must be made for all discharges overboard and to port reception facilities. Plastic bags used for garbage storage are a common OOW catch question — they must NOT be discharged even if the contents would be allowed.