Question 1

RISQ's guidance on exhaust gas cleaning ("scrubber") systems (Q5.23) flags corrosion of the overboard discharge distance piece as a real, documented failure mode — caused by poor protective coating application — that can allow water ingress into the engine room, ballast tanks, or cargo holds. Why does RightShip recommend monitoring the INTERNAL condition of this specific pipe through the PMS, rather than relying on general hull/pipework survey intervals?

Accepted Answer

Open-loop scrubber wash water is acidic and corrosive, so a pipe carrying it is exposed to accelerated, atypical corrosion compared to ordinary seawater pipework — a failure here is also unusually consequential because it sits at the hull boundary, meaning undetected wastage can progress directly to uncontrolled water ingress rather than a contained internal leak This is a relatively recent, real-world failure pattern that emerged as scrubbers were retrofitted fleet-wide following the 2020 sulphur cap — RightShip's specific PMS recommendation exists because routine survey intervals were not originally designed around this corrosive-discharge-at-the-hull-boundary risk, and undetected wastage here has a more severe consequence (direct water ingress) than ordinary pipework corrosion elsewhere.

Question 2

RISQ Q5.1 requires the Oil Record Book Part 1 to be completed correctly, with distinct sections for non-automatic bilge discharge (D), automatic discharge systems (E), oil filtering equipment defects (F), accidental discharges (G), bunkering (H), and voluntary bilge-holding-tank declarations (I). Why does the ORB use this many separate, specific sections rather than one general "discharge log"?

Accepted Answer

Each section corresponds to a distinct operational scenario with its own compliance requirements and risk profile — collapsing them into one general log would make it impossible to verify which specific control applied at the time (e.g. whether the oil filtering equipment was working, or whether a discharge was accidental versus routine), which is exactly what an inspector or investigator needs to establish after the fact This structure is what makes the ORB forensically useful, not just a record-keeping formality — a code "I" entry (filtering equipment defective, valve sealed shut) tells a very different story from a code "G" entry (accidental discharge), and conflating them would defeat the purpose of being able to reconstruct exactly what happened and why during any given discharge event.

Question 3

RISQ's guidance on emergency bilge suction and overboard discharge valves (Q5.13) states that sealing these valves in the closed position "shall not be construed as a requirement for the valve to be blanked or physically locked" and that the valve "shall always remain available for use in case of an emergency." Why does the regulation deliberately avoid a method (like a padlock) that would make the valve harder to open?

Accepted Answer

A numbered breakable seal achieves the pollution-prevention control (detecting and recording any unauthorised opening) without compromising the valve's availability for genuine emergency use — a padlock or blank would prevent accidental/unauthorised discharge equally well, but could also delay or block legitimate emergency use when the valve is actually needed, which is an unacceptable trade-off for an emergency-designated valve This is a deliberately balanced control: the breakable-seal method satisfies the pollution-prevention need (you can tell if the valve was opened without authorisation, and a record trail exists) while preserving the valve's core purpose as an emergency device that must never be genuinely obstructed. A method that fully prevented opening would defeat the valve's reason for existing.