Marpol 2007

Lloyds Register ASIA
MARPOL 73/78 Annexes I, IV, V and VI
abcd
MARPOL 73/78
ANNEXES I, IV, V and VI
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Lloyds Register EMEA
MARPOL 73/78 Annexes I, IV and VI
AN INTRODUCTION TO MARPOL 73/78
MARPOL 73/78 is an international convention comprising a set of regulations aimed at preventing

pollution of the sea from ships. At present there are six different 'sets' of regulations known as the
Annexes of MARPOL 73/78, each dealing with a different aspect of marine pollution.
These regulations, like the SOLAS, Load Line and Tonnage conventions, are formulated and agreed
by the International Maritime Organization (IMO).
How is Lloyd's Register involved?
Lloyd's Register is authorised by over 140 national authorities to survey ships and issue certification
for compliance with the regulations of the various conventions on behalf of the governments.
Which ships are required to comply with the convention?
The MARPOL convention defines a ship as a vessel of any type whatsoever operating in the marine
environment. The only exceptions to this are warships, naval auxiliary ships or other government
controlled ships on non-commercial service. This means that all vessels, regardless of type or size
must comply with the requirements of the regulations in the various Annexes.
The convention therefore applies to tankers, container ships, general cargo ships, gas carriers, oil
platforms, barges, pleasure craft (yachts, speed boats etc) and oil rigs. This is regardless of size or
whether the particular Annex requires the vessel to undergo surveys and be issued with a certificate.
Types of pollution from ships
Oil, noxious liquid substances (chemicals), packaged cargo, sewage, garbage and air are all types of
pollution that can come from a ship. Other sources currently under consideration are anti-fouling
paints, unwanted aquatic organisms in ballast water and pollution caused by the scrapping of ships.
1.1 The MARPOL Annexes

Annex I: Regulations for the Prevention of
Pollution by Oil from Ships
This Annex, which entered into force on 2 October

1983, requires that ships are designed, constructed,
equipped and operated to ensure that the allowable
limits for the amount of oil a ship may discharge to sea
are complied with. Surveys and certification are
required
Annex II: Regulations for the Prevention of

Pollution by Noxious Liquid Substances in Bulk
This Annex entered into force on 6 April 1987, and

deals with chemical pollution
Annex III: Regulations for the Prevention of

Pollution by Harmful Substances Carried by Sea
in Packaged Form, or in Freight Containers,
Portable Tanks or Road and Rail Tank Wagons
This came into in force on 1 July 1992, and is

operational in nature, with no certification required. The
regulations cover requirements for packing, marking,
documentation, stowage and quantity limitations of
substances identified as Marine Pollutants. It is linked
to the International Maritime Dangerous Goods Code
(IMDG Code)

Annex IV: Regulations for the Prevention of
Pollution by Sewage from Ships
This Annex entered into force on 27 September 2003.

The Annex covers the disposal of sewage, where it can
be discharged; methods for its treatment and storage;
carrying out surveys and issuing certificates.
The United States also have requirements for the
prevention of pollution by sewage. They require that
sewage treatment plants or containment systems are
fitted to ships. Lloyd's Register can issue a Statement of
Compliance with the United States requirements when
specifically requested to do so by an owner/builder
Annex V: Regulations for the Prevention of

Pollution by Garbage from Ships
This Annex came into force on 30 December 1988 and

is applicable to all ships. It is operational in nature so
the owner, master and crew are responsible for
ensuring it is complied with. The Annex regulates how a
ship's garbage is dealt with, what can and cannot be
dumped at sea, where it can be dumped, and how it is
to be dumped
Annex VI: Regulations for the Prevention of

Pollution of Air from Ships
This Annex was adopted by the IMO on 26 September

1997 and entered into force on 19 May 2005. It
regulates NOx emissions from main and auxiliary diesel
engines, SOx content of marine fuel oil bunkers, bunker
quality, cargo vapours from tankers, shipboard
incinerators and the use of ozone depleting substances.
MARPOL Annex I - The Prevention of Pollution By Oil
2.1 Background: From OILPOL 54 to the Prestige disaster

The world's first oil tankers appeared in the late 19th century to carry kerosene for lighting, but the
invention of the motor car fuelled demand for oil. During the World War 2, the standard oil tanker was
the T2 at 16,400 tonnes deadweight. But tankers grew rapidly in size from the 1950s onwards.
The first 100,000-tonne crude oil tanker was delivered in 1959 to cover the route from the Middle East
to Europe round the Cape of Good Hope (thereby avoiding the Suez Canal which had been
temporarily closed following political conflicts in 1956). Shippers saw economies of scale in larger
tankers and by the mid-1960s, tankers of 200,000 tonnes deadweight- the Very Large Crude Carrier
or VLCC - had been ordered.
OILPOL 54
The potential for oil to pollute the marine environment was recognised by the International Convention
for the Prevention of Pollution of the Sea by Oil, 1954 (OILPOL 1954). The conference that adopted
the Convention, was organised by the United Kingdom and provided for certain functions to be carried
out by the IMO when it came into being. In fact the convention that established the IMO, entered into
force in 1958 just a few months before the OILPOL convention, so IMO effectively managed OILPOL
from the start, initially through its Maritime Safety Committee.
The OILPOL Convention recognised that most oil pollution resulted from routine shipboard operations
such as the cleaning of cargo tanks. In the 1950s, the normal practice was simply to wash the tanks
out with water and then pump the resulting mixture of oil and water into the sea.
OILPOL 54 prohibited the dumping of oily wastes within a certain distance from land and in 'special
areas' where the danger to the environment was especially acute. In 1962 the limits were extended by
means of an amendment adopted at a conference organised by the IMO.

Meanwhile in 1965, the IMO set up a Subcommittee on Oil Pollution, under the auspices of its
Maritime Safety committee, to address oil pollution issues.
Torrey Canyon disaster
Although the OILPOL Convention had been ratified, pollution control was at the time still a minor
concern for the IMO. Indeed, the world was only beginning to wake up to the environmental
consequences of an increasingly industrialised society.
This changed in 1967, when the Torrey Canyon ran aground while entering the English Channel,
spilling its entire cargo of 120,000 tonnes of crude oil into the sea. As the biggest oil pollution incident
ever recorded up to that point, it raised questions about measures then in place to prevent oil spills,
while exposing deficiencies in the existing system for providing compensation following accidents at
sea.
It was essentially this incident that set in motion the chain of events that eventually led to the adoption
of MARPOL - as well as a host of conventions in the field of liability and compensation.
First, IMO called an Extraordinary Session of its Council, which drew up a plan of action on technical
and legal aspects of the Torrey Canyon incident.
It was still recognised, however, that although accidental pollution represented the most spectacular
and high profile events, day-to-day operational pollution was the bigger threat.
In 1969, therefore, the 1954 OILPOL Convention was again amended, this time to introduce a
procedure known as 'load on top' that had been developed by the oil industry and which had the
double advantage of saving oil and reducing pollution. Under the system, the washings resulting from
tank cleaning are pumped into a special tank. During the voyage back to the loading terminal, the oil
and water separate. The water at the bottom of the tank is pumped overboard and at the terminal, oil
is pumped onto the oil left in the tank.
However, the enormous growth in the maritime transport of oil and the size of tankers, plus the
increasing amount of chemicals being carried and a growing concern for the world's environment as a
whole, made many countries feel that OILPOL 1954 was no longer adequate, despite the various
amendments it had been adopted.
In 1969, the IMO Assembly decided to convene an international conference to adopt a completely new
convention, which would incorporate the regulations contained in OILPOL 1954. At the same time, the
Sub-Committee on Oil Pollution was renamed the Sub-Committee on Marine Pollution, to broaden its
scope; this became the Marine Environment Protection Committee (MEPC), which was eventually
given the same standing as the Maritime Safety Committee, with a brief to deal with all matters relating
to marine pollution.
The conference was set for October-November 1973, and preparatory meetings began in 1970.
Meanwhile, in 1971 the IMO adopted amendments to OILPOL 1954, which limited the size of cargo
tanks in all tankers ordered after 1972. The intention was that given certain damage to the vessel, only
a limited amount of oil could enter the sea.
1973 International Convention for the Prevention of Pollution from

Ships
The 1973 conference in October-November 1973 incorporated much of OILPOL 1954 and its
amendments into Annex I covering oil, while other annexes covered chemicals, harmful substances
carried in packaged form, sewage and garbage.
Annex I expanded and improved on OILPOL in several ways. It specified requirements for continuous
monitoring of oily water discharges and included the requirement for governments to provide shore
reception and treatment facilities at oil terminals and ports. It also established a number of 'special
areas' in which more stringent discharge standards were applicable, including the Mediterranean, Red
Sea and Gulf, and Baltic Seas. These special areas would be implemented when the littoral states
concerned had provided adequate reception facilities for dirty ballast and other oily residues.
An important regulation of Annex I was Regulation 13, which required segregated ballast tanks on new
tankers over 70,000 deadweight tonnes. The aim was to ensure that ballast water (taken on board to
maintain stability, such as when a tanker is sailing empty to pick up cargo) is never going to be
contaminated by oil carried as cargo or fuel.
As it turned out there was slow progress in the convention's ratification, partly because of technical
problems in ratifying Annex II and it became a major concern.
At the same time, a series of tanker accidents in 1976-1977 mostly in or near United States waters
and including the stranding of the Argo Merchant, led to demands for more stringent action to curb
accidental and operational oil pollution. Although the Argo Merchant, which ran aground off
Massachussetts in December 1976, was a small tanker carrying 27,000 tonnes of oil, it caused huge
public concern because the oil slick threatened New England resorts and the Georges Bank fishing
ground.
The U.S.A took the lead in asking the IMO Council, in May 1977, to consider adopting further
regulations on tanker safety. The Council agreed to convene a conference in February 1978 - the
Conference on Tanker Safety and Pollution Prevention.
A working group met in May, June and July, and a combined MSC/MEPC met in October, to prepare
basic documents for the conference.
1978 Conference on Tanker Safety and Pollution Prevention
The conference in February 1978, adopted a protocol to the 1973 MARPOL Convention, absorbing
the parent Convention and expanding on the requirements for tankers to help make them less likely to
pollute the marine environment.
The Protocol expanded the requirements for segregated ballast tanks to all new crude oil tankers of
20,000 dwt and above, and all new product carriers of 30,000 dwt and above. The Protocol also
required segregated ballast tanks to be protectively located; in other words placed in areas of the ship
that would minimise the possibility and amount of oil outflow from cargo tanks after a collision or
grounding.
New tankers over 20,000 dwt were required to be fitted with crude oil washing systems. Crude oil
washing, or COW, is the cleaning or washing of cargo tanks with high-pressure jets of crude oil. This
reduces the quantity of oil remaining on board after discharge.
The Protocol also called for existing tankers over 40,000 dwt to be fitted with either segregated ballast
tanks or crude oil washing systems, while for an interim period it allowed some tankers to use clean
ballast tanks, whereby specific cargo tanks could be dedicated to carrying ballast water only.
Additional measures for tanker safety were incorporated into the 1978 Protocol to the International
Convention for the Safety of Life at Sea (SOLAS), 1974. These included the requirement for inert gas

systems (whereby exhaust gases, which are low in oxygen and thus non-combustible, are used to
replace flammable gases in tanks) on all new tankers over 20,000 dwt and specified existing tankers.
The SOLAS Protocol also included requirements for tanker steering gear, stricter requirements for
carrying radar and collision avoidance aids, and stricter regimes for surveys and certification.
To speed up MARPOL's implementation, the conference gave countries a three-year 'grace period, in
which they were not bound by the provisions of Annex II from the date of entry into force of the
Protocol. This enabled countries to accept Annex I while having three years to implement Annex II.
Both the 1978 MARPOL and SOLAS Protocols were seen as major steps in raising construction and
equipment standards for tankers through more stringent regulations.
If the world needed a further reminder of the need for strict anti-pollution regimes, it got it just one
month after the 1978 Conference, when the Amoco Cadiz ran aground off Brittany. The tanker, filled
with 223,000 tonnes of crude oil, lost its entire cargo to more than 130 beaches, with oil up to 30 cm
thick in some places. It was France's worst ever oil spill.
Sufficient countries had ratified MARPOL by October 1982, and on 2 October 1983 the MARPOL
1973/78 the convention entered into force.
Since then, there have been a number of amendments to the convention.
3.1 Exxon Valdez disaster

It was another tanker accident that led to one of the most important changes to Annex I since the
adoption of the 1978 Protocol.
In March 1989, the Exxon Valdez, loaded with 1,264,155 barrels of crude oil, ran aground in the north
eastern portion of Alaska's Prince William Sound, spilling about one-fifth of its cargo. It was the largest
crude spill in U.S. waters to date, and probably the one that also gained the biggest media coverage:
the public demanded action - and duly got it.
The U.S. introduced its Oil Pollution Act of 1990 (OPA 90), making it mandatory for all tankers calling
at its ports to have double hulls.
The U.S. also came to the IMO, calling for double hulls to be made a mandatory requirement of
MARPOL. The implications of the Exxon Valdez spill were not lost on IMO Members, and the MEPC
began discussions on how the U.S. proposals could be implemented.
As on previous occasions, there was some resistance on the part of the oil industry to the mandatory
introduction of double hulls, mainly due to the cost of retrofitting existing tankers.
At the same time, several IMO Member States wanted other designs to be accepted as equivalents
and that measures for existing ships should also be contemplated. In 1991 a major study into the
comparative performances of the double-hull and mid-height deck tanker designs was carried out by
the IMO, with funding from the oil and tanker industry.
It concluded in January 1992 that the two designs could be considered as equivalent, although each
gave better or worse outflow performance under certain conditions.
Eventually, the MEPC agreed to make mandatory double hulls or alternative designs "provided that
such methods ensure the same level of protection against pollution in the event of a collision or
stranding". These design methods should also be approved by the MEPC.

1992 'double hull' amendments
The amendments introducing double hulls (or an alternative) were contained in Regulation 13F Prevention of oil pollution in the event of collision or stranding. The amendments were adopted in
March 1992 and entered into force in July 1993.
Regulation 13F applies to new tankers - defined as delivered on or after 6 July 1996 - while existing
tankers must comply with the requirements of 13F not later than 30 years after their date of delivery.
Tankers of 5,000 dwt and above must be fitted with double bottoms and wing tanks extending the full
depth of the ship's side. The regulation allows mid-deck height tankers with double-sided hulls as an
alternative to double hull construction.
Oil tankers between 600 dwt and 5,000 dwt, had to be fitted with double bottom tanks and the capacity
of each cargo tank is limited to 700 cubic metres, unless they are fitted with double hulls.
The MEPC also adopted Regulation 13G, concerned with existing tankers, which made provision for
an enhanced programme of inspections to be implemented, particularly for tankers more than five
years old.
Regulation 13G also allowed for future acceptance of other structural or operational arrangements such as hydrostatic balance loading (HBL) - as alternatives to the protective measures in the
Regulation.
The Erika disaster and revised single-hull phase-out schedule
On 12 December 1999, the 37,238-dwt tanker Erika broke in two in heavy seas off the coast of
Brittany, France. It was carrying approximately 30,000 tonnes of heavy fuel oil. Although the crew was
saved, some 14,000 tonnes of oil was spilled and more than 100 miles of Atlantic coastline was
polluted.
As a result, proposals were submitted to the MEPC to accelerate the phase-out of single-hull tankers
contained in the 1992 MARPOL amendments.
The amendments to Regulation 13G in Annex I of MARPOL 73/78 were adopted by the MEPC's 46th
session in April 2001.
The Prestige disaster
The Prestige tanker incident of 2002 led to calls for further changes to MARPOL 73/78. The MEPC at
its 49th session in July 2003 agreed to an extra session of the Committee to be convened in
December 2003. It considered the adoption of proposals for an accelerated phase-out scheme for
single hull tankers, along with other measures, including an extended application of the Condition
Assessment Scheme (CAS) for tankers. New Regulation 13H was created for the heavy oils. The
revised Regulation 13G/H came into force on 5 April 2005.
3.2 Overview
With effect from 1 January 2007 MARPOL Annex I has been reformatted and the regulations
renumbered. There are seven Chapters as follows:
Chapter 1
General
Chapter 2
Survey and certification
Chapter 3
Requirement for machinery spaces for all ships
Chapter 4
Requirement for the cargo area of oil tankers
Chapter 5
Prevention of oil pollution arising from an oil pollution incident
Chapter 6
Reception facilities
Chapter 7
Special requirement for fixed or floating platforms
The extent of compliance is determined by applying the following factors:
Type of vessel - tanker or ship other than a tanker
Size of vessel - gross tonnage, deadweight and length
Age of vessel - new ship or existing ship, new tanker or existing tanker, pre or post-double
hull requirement dates
The various regulations have differing application dates.
Which vessels do these regulations apply to?

MARPOL defines a 'ship' as a vessel of any type whatsoever, operating in the marine environment
and so the regulations apply to all ships, including oil platforms, barges, private yachts.
The regulations do not apply to warships, naval auxiliary vessels or other government owned or
operated vessels in non-commercial service.
Some exemptions may be included in certain regulations for vessels such as hydrofoils and
hovercraft, which are not able to comply because of the nature of their construction.
All vessels of 400 gross tonnes (gt) and above, and all oil tankers of 150 gt and above must be
surveyed and issued with certificates as evidence of their compliance with the regulations. Smaller
ships must comply with the regulations but are not required to be surveyed or issued with certificates.
However, a Statement of Compliance can be issued if requested by the owners or if required by the
flag authority.
How are these regulations applied?
The regulations are applied by individual governments when surveying ships and issuing appropriate
certificates. Lloyd's Register is authorised by over 140 governments to act on their behalf, so in effect
undertakes the work of the government in applying these regulations.
After an initial survey, and provided the regulations are complied with, a certificate is issued for five
years. During this period the vessel must undergo annual, intermediate and periodical surveys. These
are normally on an annual basis, i.e. the vessel will have four surveys during the five year period.
At the second or third annual survey, an intermediate survey is held, this being more onerous than an
annual survey. On or before the fifth anniversary of the initial survey - i.e. the expiry date of the
certificate - a renewal survey is held. The renewal survey is a very thorough examination of the
pollution prevention equipment. The five-year cycle then starts again.
A certificate must be accompanied by a 'Record of Construction and Equipment', which details the
construction of the vessel, the regulations applicable to it, and the equipment fitted.

What are the sources of oil pollution from ships?
There are two main sources of oil pollution from ships. One is from waste oil created in the machinery
space: purification of fuel and lubricating oil, oil leakages from machinery and water ballast in fuel oil
tanks. The other is from the cargo space of ships carrying oil in bulk: water ballast in cargo tanks and
cargo tank washings.
For operational reasons, ships do make some discharges to sea. Before the introduction of MARPOL
there was no control of these discharges.
Regulations 15 and 34 state exactly where and how oily water mixtures can be discharged to sea. The
remaining regulations deal with how such discharges are prevented, or kept within the limits
prescribed in Regulations 15 and 34, which may be by or a combination of operational measures,
equipment, or the design and construction of the vessel.
The discharge requirements stipulate that:
1.
For cargo area discharges from an oil tanker:

the tanker is not within a Special Area;
the tanker is more than 50 nautical miles from the nearest land;
the tanker is proceeding en route;
the instantaneous rate of discharge of oil content does not exceed 30 litres per nautical
mile;
the total quantity of oil discharged into the sea does not exceed for existing tankers
1/15,000 of the total quantity of the particular cargo of which the residue formed part,
and for new tankers 1/30,000 of the total quantity of the particular cargo of which the
residue formed a part; and
the tanker has in operation an oil discharge monitoring and control system and a slop
tank arrangement as required by Regulation 29 of MARPOL Annex I.
2.
For machinery space discharges from any ship of 400 GT and above, other than an oil
tanker and from machinery space bilges excluding cargo pump room bilges of an oil tanker
unless mixed with oil cargo residue:
the ship is not within a Special Area;
the ship is proceeding en route;
the oil content of the effluent without dilution does not exceed 15 parts per million; and
the ship has in operation equipment as required by Regulation 14 of MARPOL Annex I
(oily water separator and bilge monitor).
The Regulations can now be conveniently split into two parts. Those Regulations which apply to all
vessels and those applying only to tankers.
3.3 Regulations applying to all ships

Regulations 1 to 10 contain definitions, the requirements for surveys and issue of certificates,
exemptions and Port State Control requirements. Regulations 15 and 34 deal with when and where
oily water may be discharged and the allowable limits.
The remaining regulations in this group deal with the construction of the ship and its equipment rather
than operational matters, and are therefore particularly relevant to the work carried out by Lloyd's
Register.

Regulation 16 - Segregation of oil and water ballast and carriage of oil in forepeak tanks
This Regulation applies to new ships other than oil tankers of 400 gt and above and new oil tankers of
150 gt and above.
No ballast is to be carried in oil fuel tanks, except in abnormal conditions, meaning severe weather
conditions or certain vessels that need to carry large quantities of fuel oil.
When ballast is carried in fuel oil tanks it should be discharged to shore reception facilities or to the
sea in compliance with Regulation 15, using oil filtering equipment. An entry must also be made in the
Oil Record Book.
No oil shall be carried in the forepeak or any tank forward of the collision bulkhead. This applies to all
ships of 400 gt and above whose contracts are placed after 1 January 1982 or whose keels are laid
after 1 July 1982.
All vessels not included in the above should comply with these requirements as far as is reasonable
and practicable.
Regulation 14 - Oil discharge monitoring and control system and oil filtering equipment
This Regulation describes the equipment necessary to achieve the discharge limits of 15ppm, and the
monitoring requirements enabling the ships staff to measure the oil content of oil/water mixture being
discharged.
There are three basic pieces of equipment involved:
Oil Water Separator - used to describe 100ppm equipment (not permitted after 1 July
1998).
Oil Filtering Equipment - used to describe 15ppm equipment.
Monitoring Equipment - more commonly referred to as a bilge monitor or 15ppm alarm.

Used to describe equipment that can monitor the discharge, record the ppm of discharge
outflow and, where the regulations require, automatically stop the discharge when the limit
of 15ppm is reached or in the event of monitor failure.
Vessels of between 400 gt and 10,000 gt must be provided with 15ppm equipment to process
machinery space discharges. i.e. an oily water filter.
Vessels of 10,000 gt and over must be provided with a 15ppm oil filter with an alarm that operates at
15ppm and an automatic stopping device. Any vessel that carries ballast in fuel oil tanks must also be
fitted with this equipment.
Vessels that require discharging within a Special Area should also be fitted with an automatic stopping
device, 15ppm filtering equipment and a 15ppm alarm to comply with discharge requirements for
Special Areas.
All the equipment provided in compliance with Regulation 14 must be of an approved type. Type
approval certificates are issued by or on behalf of National Administrations.
Resolution MEPC.60 (33) is the standard applicable to all equipment fitted after 30 April 1994 but
before 1 January 2005, and Resolution A.393(X) applies to equipment fitted prior to 30 April 1994.
Different standards have been developed over the years; the date on which the equipment was fitted
will decide which standard was applicable at that time.
The IMO's Marine Environment Protection Committee (MEPC) introduced, in IMO Resolution MEPC.
107(49), important revisions to the Guidelines and Specifications for the type approval of this
equipment which entered into effect on 1 January 2005.

There are significant differences between the new Specifications and those they replace.
The Guidelines and Specifications for Pollution Prevention Equipment for Machinery Space Bilges of
Ships, IMO Resolution MEPC.107(49), replaces MEPC.60(33), and applies to all 15 ppm bilge
separators (oil filtering equipment) and 15 ppm bilge alarms (oil content meters) installed on board
ships on or after 1 January 2005.
All 15 ppm bilge separators and 15 ppm bilge alarms installed on ships with keel laying on or after 1
January 2005, should be tested in accordance with MEPC.107(49) and be provided with a type
approval certificate issued by or on behalf of an Administration. In addition, if the equipment is to be
supplied to a ship flying the flag of a European Union member state, it must also be certified in
accordance with the EU Marine Equipment Directive (MED).
Equipment currently in service, or fitted to ships prior to 1 January 2005, does not need retesting and
can continue in operation under its current type approval certification. Replacement equipment
supplied to any ship after 1 January 2005 should comply with MEPC.107(49).
Some ships were fitted with separating or filtering equipment prior to Annex I coming into force.
However, the equipment did not always comply with the standards required. These ships were allowed
to use "add on" units (known as process units) to bring the equipment up to the required standard.
This also applied to equipment meeting the other older standards mentioned above. The IMO books
Oily Water Separators and Monitoring Equipment and Pollution Equipment under MARPOL 73/78
contains the relevant IMO resolutions.
A waiver is available from the requirements of Regulation 16 for vessels engaged solely in voyages
within Special Areas. In such cases all oily mixtures must be discharged to reception facilities.
Regulation 12 - Tanks for Oil Residues (Sludge)
This regulation requires that sludge tanks are provided on all ships of 400 gt and above, for waste oil,
sludge, and so on, which cannot be pumped overboard in accordance with Regulation 15.
The required tank capacity can be calculated using a formula based upon daily fuel consumption,
maximum length of voyage and type of fuel oil used (diesel or heavy).
These tanks should be designed and constructed so as to facilitate their cleaning, and the discharge
of residues to reception facilities. They should be fitted with heating coils, if used to store heavy oil and
must be provided with a designated pump for discharge ashore. They should have no connection to
any bilge system or overboard, other than to the Standard Discharge Connection.
Ships may also use homogenisers, incinerators or burn the sludge in the ships boilers, a reduction in
the sludge tank size being allowed for vessels so equipped.

Refer all also to MEPC/circ.235 Guidelines for Handling Oily Wastes in Machinery Spaces of Ships,
which is currently being revised.
Standard Discharge
Connection
15pmm
filter
15ppm alarm
3-way valve
Pump
Pump
Sludge Tank
Bilge Holing
Tank
Overboard

Regulation 13 - Standard Discharge Connection
This regulation requires that all vessels must be provided with a standard discharge connection for
discharging waste oils to shore reception facilities. The dimensions of the Standard Discharge
Connection are shown on the diagram.
Regulation 36 - Oil Record Book

Every oil tanker of 150 gt and above and every ship of 400 gt and above other than an oil tanker, are
required to be provided with an Oil Record Book Part I (Machinery Space Operations). This book must
be completed:
whenever bunkers or lube oil is loaded and discharged; or
if the tanks are ballasted or cleaned, whenever dirty water involved in this operation is
discharged either to sea or to shore; or
whenever sludge is disposed of and whenever bilges are discharged overboard or ashore.
Every oil tanker of 150 gt and above is required, in addition to Part I, to be provided with an Oil Record
Book Part II (Cargo/Ballast Operations). This book is a record of all cargo operations, including the
loading and discharging of cargo, cleaning of cargo tanks, loading and discharging of ballast and the
disposal of tank washings, either to sea or ashore, etc.
Regulation 37 - Shipboard Oil Pollution Emergency Plan
Every oil tanker of 150 gt and above, and every ship other than an oil tanker of 400 gt and above,
must have on board a 'Shipboard Oil Pollution Emergency Plan' (SOPEP).
This contains instructions to the vessel's master detailing the reporting procedure to be used in the
event of an oil spill, and checklists or instruction to ensure that appropriate action is taken to minimise
or stop the outflow of oil.
This plan is of an operational nature but it is required to be approved by or on behalf of the vessel's
Flag Administration.
Vessels carrying Noxious Liquid Substances are required to be provided with a further plan known as
a 'Shipboard Marine Pollution Emergency Plan for Noxious Liquid Substances' (SMPEP-NLS) or, as
an alternative, a combined plan known as a 'Shipboard Marine Pollution Emergency Plan' (SMPEP).

The IMO has produced guidelines for the development of SOPEPS and SMPEPS which should be
read in conjunction with the general principles for ship reporting systems and ship reporting
requirements, including guidelines for reporting incidents involving dangerous goods, harmful
substances and/or marine pollutants.
3.4 Tankers
Before considering the Regulations which apply to tankers, it is useful to understand how a tanker
operates.
3.
A fully laden tanker arrives at a discharge port
4.
The cargo is pumped ashore
5.
Ballast is taken on board
6.
The tanker sails back to a loading port
7.
It discharges the ballast
8.
A cargo is loaded
9.
It sails to a discharge port
In terms of item 3 - where does the tanker put the ballast? The cargo tanks were traditionally used as
ballast tanks thus creating an oil/water mixture. The ballast containing the oil/water mixture cannot be
discharged at the loading port. To overcome this problem the tanker washes a set of tanks and fills
these with clean ballast, which can be discharged at the loading port. The 'dirty' ballast is discharged
at sea along with the residues from tank cleaning - at least that was how it was done historically (and
still is on single hull tankers).
On tankers with Segregated Ballast Tanks (SBT) or double hulls, sufficient ballast is taken into the
segregated ballast tanks for most ballast voyages. Only on rare occasions, in the event of extreme
weather conditions or emergency situations, would ballast be taken into cargo tanks.
Concern about oil pollution led to the development of what is known as the 'load-on-top' system. This
was developed by the tanker operators, not the IMO.
Instead of discharging the residues from the tank washings to sea, they are retained on board in a
slop tank. The oil/water mixture is allowed to settle, and then the water is pumped off the bottom. This
leaves the oil plus a small amount of water in the slop tank. The tanker when proceeds to the loading
port as before. Cargo is loaded into all tanks including on top of the slops. The cycle is then repeated.
It should be noted that the load-on-top procedure only works with crude oil cargoes. For product
refined oil cargoes such as petrol, jet fuel or diesel oil, the slops are either retained on board or
discharged ashore.
3.5 Regulations applicable to oil tankers

The following regulations are additionally applicable to oil tankers:
3.6 Regulation 18 - Segregated Ballast Tanks, Dedicated Clean Ballast and Crude
Oil Washing
This Regulation requires that every new Crude Oil Tanker of 20,000 dwt and above and every new
Product Tanker of 30,000 dwt and above must be provided with Segregated Ballast Tanks (SBT).
The capacity of SBT tanks must be such that the vessel's draft is a minimum of 2.0 + 0.02L and a trim
not exceeding 0.015L, where L = vessels length, and such that the propeller is fully immersed. There

must be sufficient segregated ballast capacity so that the vessel can operate safely without using
cargo tanks for ballast, except in exceptional circumstances such as heavy weather.
Every new Crude Oil Tanker of 20,000 dwt and above is required to be provided with a Crude Oil
Washing (COW) System.
Every Existing Crude Oil Tanker of 40,000 dwt and above must be provided with a Segregated Ballast
Tank (SBT) system, meeting the requirements referred to earlier, or, in lieu of an SBT system, a Crude
Oil Washing system.
Every Existing Product Tanker of 40,000 dwt and above must be provided with either an SBT or a
Dedicated Clean Ballast Tank (DCBT) system.
These are the basic requirements as required by Regulation 13. There are three aspects of Regulation
13 that require more explanation; they are Protective Location, Crude Oil Washing and Dedicated
Clean Ballast.
Segregated Ballast
A Segregated Ballast System (SBT) is a system that is physically separated from the tanker's cargo oil
and fuel oil systems, and is used only for the carriage of ballast. Completely separate means that the
SBT pipework must be physically separated from the oil system. Provision may be made for the
emergency discharge of ballast using a cargo pump, by means of a connection through a portable
spool piece and a non-return valve to prevent oil from passing back to the ballast tanks. The spool
piece must be removed when not in use and a permanent notice displayed adjacent to it, restricting its
use.
3.7 Regulation 18.8 - Requirements for Dedicated Clean Ballast Tanks

Regulation 18.8 requires that existing products tankers of 40,000 dwt and above, not fitted with SBT,
are provided with a Dedicated Clean Ballast Tank (DCBT) System.
A DCBT system could be described as a temporary semi-segregated ballast system, the disadvantage
of the system being that cargo carrying capacity is lost.
The system is achieved by using one (or more) of the vessel's normal cargo pumps, part of the in-tank
piping system and a suitable number of tanks to enable the draft and trim requirements of Regulation
18.2 as for SBT to be met. The pumps, lines and tanks used are isolated from the rest of the cargo
system by existing valves plus, in some cases, additional valves and /or blanks. Sections of line may
need to be removed or added.
The arrangements and operational procedures for Dedicated Clean Ballast Tanks should contain at
least all the provisions of the Specifications for Oil Tankers with Dedicated Clean Ballast Tanks, IMO
Resolution A.495 (XII), the basic requirements of which are as follows:
The discharge must be monitored by an Oil Discharge Monitoring and Control System.
Maximum oil content 15ppm.
The DCBT must be isolated from the cargo system by at least two valves.
The lines and pumps used should be arranged so they can be effectively flushed prior to
loading/discharging the ballast, without permitting any oily water to enter the Dedicated
Clean Ballast Tank.
Any part of the DCBT piping system, while in use, must be isolated from the cargo system
by at least two valves, or equivalent. This isolation should also include inert gas, tank
venting and tank washing systems.
The DCBT piping must be connected to the least practicable number of cargo pumps.
The vessel to be provided with an approved Dedicated Clean Ballast Tank Operations
Manual, which contains full details of how the system operates, valves to be opened/shut,
pumps used, line flushing procedures, discharge and loading procedures for ballasting.
These vessels were phased out by the end of 2005.
3.8 Regulation 33 - Crude Oil Washing

Crude Oil Washing (COW) is a system where the cargo tanks are washed during discharge with the
crude oil cargo. Washing the tanks with the cargo has the effect of removing from the tanks internal
structure deposits which would otherwise remain on board. This means that less oil is left on board,
therefore less oil in dirty ballast and less oil that could be discharged into the sea.
The system works because crude oil has a solvent effect on the tar/waxy deposits which settle out
during the loaded voyage. There is an additional benefit in that cargo out-turns are higher when COW
is used, although there is a disadvantage in that cargo discharge times can be increased.
The installation and associated equipment complies with the requirements of the IMO Revised
Specification for the Design, Operation and Control of Crude Oil Washing Systems. (A.446 (XI)), which
includes:
10. That the System, pipework, valves etc. are:
steel of other suitable material, properly joined and supported;
permanent and independent of any other system;
fitted with an over pressure device;
fitted with pressure gauges;
tested to 1 times the working pressure; and
piping to be anchored to the ship's structure, provided with means to allow for
expansion, and the anchoring to be such that hydraulic shock can be absorbed.
11. No part of the system is to enter the Engine Room and any tank cleaning heater is to be
fitted with double shut-off valves or clearly identifiable blanks to enable its effective
isolation.
12. The tank washing machines:
are to be approved by the Administration;
each machine to be isolated by a stop valve; and
the number and location of the machines to be such that no more than 10% of the
horizontal surface and no more than 15% of vertical areas are in 'shadow'. This is
assessed by 'Shadow Area Diagrams', which must be approved.
13. Crude Oil Washing Surveys. The effectiveness of the system is to be confirmed by an
effectiveness survey.
The basic requirements for the control of the system are:
The pump supplying the Crude Oil Washing System (usually a cargo pump) is to be of
sufficient capacity to operate the maximum permitted number of machines at the required
back pressure.
The stripping system is to be capable of keeping the tank bottom dry when washing the
bottom of the tanks, and removing the oil at a rate of 1.25 times the maximum discharge
rate of the maximum number of machines operated simultaneously.
Level gauges, hand dipping points, suction/discharge pressure gauge on pumps/eductors

are to be provided in order to monitor the system.
Means to be provided in order to drain the entire cargo system and washing system, to a
cargo tank and ashore. For discharge ashore, a small diameter line is to be provided that
leads to the outboard side of the manifold valves.
The crew operating the system are to be properly trained.
An inert gas system must be fitted to vessels operating a Crude Oil Washing System. This
requirement is over and above any requirement under SOLAS to fit an inert gas system.
Sufficient tanks are to be Crude Oil Washed prior to each ballast voyage, in order that
ballast water is not put into tanks that have not been crude oil washed (this means that
heavy weather tanks must be washed at every discharge).
An Approved Crude Oil Washing Operations and Equipment Manual which contains
instructions on how the system is to be operated in order to achieve the requirements for
tank cleanliness and safety.
3.9 Regulation 2.5 - Existing tankers engaged in specific trades

Refer to regulation for requirements. No Lloyd's Register class tankers are operating to this regulation
and none are likely to.
3.10 Regulation 18.10 - Existing oil tankers having special ballast arrangements
Refer to regulation for requirements. No Lloyd's Register class tankers operating to this regulation and
none are likely to.
3.11 Regulation 18.12 to 18.15 - Protective Location of Segregated Ballast Spaces

This regulation has been superseded by the requirements of regulation 19 for newer tankers falling
under the requirements of that regulation.
Every new Crude Oil Tanker of 20,000 dwt and above, and every new product tanker of 30,000 dwt
and above must be fitted with SBT. This SBT must be Protectively Located.
This means that the SBTs required by Regulation 18 and which are located within the cargo tank
length, should be arranged to provide a measure of protection against oil outflow in the event of
grounding of collision.

3.12 Regulation 19 - Prevention of oil pollution in the event of collision or
stranding
This regulation applies to all oil tankers of 600 dwt and above for which the building contract is placed
on or after 6 July 1993 or, in the absence of a building contract, whose keels are laid on or after 6
January 1994, or which are delivered on or after 6 July 1996, or which have undergone a major
conversion after these dates.
All oil tankers of 5,000 dwt and above are required to be constructed with ballast or other spaces
along the entire cargo tank length which extend the full depth and breath of the vessel, i.e. a double
hull.
The wing tanks are to be a minimum width 'w'.
For vessels of 5,000 dwt and above:
For vessels under 5,000 dwt, cargo tanks should be arranged such that the maximum capacity of any
tanks does not exceed 700m unless it has wing tanks complying with the following:
The double bottom tanks or spaces are to have a minimum vertical depth of 'h'.
For vessels of 5,000 dwt and above, in lieu of Regulation 13E, h = B/15(m) or 2.0m whichever is the
lesser, the minimum value of 'h' being 1.0m
For vessels under 5000 dwt, h = B/15(m) and the minimum value of 'h' is 0.76m
Where B = Maximum breadth in metres.
Suction wells in cargo tanks may protrude into the double bottom below the boundary line defined by
the distance 'h', provided that such wells are as small as practicable and the distance between the well
bottom and bottom shell plating is not less than 0.5h.
On crude oil tankers of 20,000 dwt and above, and product tankers of 30,000 dwt and above, the
aggregate capacity of the wing tanks, double bottom tanks, forepeak and after peak tanks shall not be
less than the capacity of segregated ballast required to meet the draft and trim requirements of
Regulation 18.2. These tanks should be located as uniformly as practicable along the cargo tank
length.
Ballast piping must not pass through cargo tanks and cargo piping must not pass through ballast
tanks.
Other methods of design and construction of oil tankers than those already described may be
accepted, provided that they can give the same level of protection against oil outflow in the event of
collisions or stranding. Such alternatives are to be approved and be in accordance with IMO
guidelines.
The damage stability requirements for oil tankers of 20,000 dwt and above are also increased under
the requirements of Regulation 19, such that bottom raking damage over a larger area is taken into
account.

3.13 Regulation 20 - Prevention of oil pollution in the event of Collision or
Stranding Measures for existing tankers
A revised regulation 20 entered into force on 5 April 2005. This regulation applies to oil tankers of
5,000 dwt and above, delivered prior to the dates on which regulation 19 enters into force. It does not
apply to ships already complying with regulation 19, or those having double bottoms complying with
regulation 18 and double sides satisfying the requirements for type 2 chemical tankers.
Tankers are divided into three categories depending on their size, the cargoes which they carry (crude
oil, persistent oils or product oil) and the extent to which they comply with certain of the requirements
of MARPOL Annex I (SBT, PL and COW). Tables are used to determine, for each category of oil
tanker, the date on which regulation 13F becomes applicable.
A Category 1 oil tanker could only trade beyond 25 years from it's date of delivery if it is provided with
wing or double bottom spaces offering at least 30% side or bottom protection, or if it operates with
hydrostatically balanced loading. It may then trade up to the date on which regulation 19 becomes
applicable. These vessels were phased out by the end of 2005.
In addition Category 2 and 3 oil tankers exceeding 15 years from the date of their delivery, after 5 April
2005, are subject to compliance with a Condition Assessment Scheme (CAS) adopted by the IMO.
The requirements for CAS are detailed in IMO resolution MEPC.94 (46) as amended.
This regulation is difficult to follow so Lloyd's Register have developed some flow diagrams to guide
Owners/Managers and surveyors through it.
Your attention is drawn to the fact that there are three versions of Regulation 20, the previous two
versions are shown in the thick MARPOL book, but the current version is in a small amendment book.
3.14 Regulation 21 - Prevention of oil pollution from oil tankers carrying heavy
grade oil as cargo
Since both the ERIKA and PRESTIGE were carrying heavy product oils, there was demand o have a
Regulation to deal with the problem. Regulation 21 entered into force on 5 April 2005. This regulation
applies to oil tankers of 5,000 dwt and above, delivered prior to the dates on which regulation 19
enters into force. It does apply to tankers between 600 and 5000 dwt in 2008. The European Union
implemented the requirements for vessels over 5000 dwt from October 2003.
This regulation is difficult to follow so Lloyd's Register have developed some flow diagrams to guide
Owners/Managers and surveyors through it.
Beware that United States had previously OPA90 so did not implement Regulation 20 since it had a
more strict equivalent with OPA90. With the amendments to Regulation 20 in some cases you cannot
trade internationally under MARPOL but you can under OPA90. Also since Regulation 21 was an
amendment to Regulation 20 therefore 21 is not implemented in United States. OPA90 has not been
amended.

3.14.1
New IMO regulation 20 flow charts (Note in the flow diagrams below the old MARPOL
Annex I numbering system is used, whereby regulation 20 appears as regulation 13G
and regulation 21 appears as regulation 13H)

MARPOL Annex I regulation 13G flow chart
MARPOL definitions
Application dates for 13F
(new 19) are:
Is the ship an oil

tanker of 600 tonnes
deadweight?
building contract placed

on or after 6 July 1993,
or
YES
in the absence of a
building contract, the
keel laying or similar
stage of construction is
on or after 6 January
1994, or
NO
Was ship delivered

before 13F (new 19)
dates and is ships
deadweight 5000?
Regulation
13G
(new 20) is not
applicable. But see
Regulation 13H +
EU + Fujairah +
OPA 90 flow charts
NO
YES
delivery on or after 6 July

1996
Does ship comply with

13F(3)(a) and (b) (new
19.3.1&2) full double
sides
and
double
bottom?
MARPOL definitions
The
requirement
for
minimum
distances
between the cargo tank
boundaries and the ship
side and bottom plating
need not be met in all
respects. In that event, the
side protection distances
shall not be less than those
specified in the IBC Code
for type 2 cargo tank
location and the bottom
protection distances shall
comply with regulation
13E(4)(b) (new 18.15.2) of
MARPOL Annex I.
Regulation 13G&H
(new 20& 21), EU
and
Fujairah
regulations are not
applicable. But see
OPA 90 flow chart.
YES
NO
13F(4) (new 19.4) middeck tanker or with 13F(5)
(new
19.5)
other
approved method of design
and construction?
Regulation 13G&H
(new 20& 21), EU
and
Fujairah
regulations are not
applicable. But see
OPA 90 flow chart.
YES
NO
MARPOL definitions
For the purpose of this reg:
Does
ship carry
crude oil, fuel oil,
heavy diesel oil or
lubricating oil?
In the new Regulation

19.3 (old 13F(3)) the oil
cargo tanks can be
protected by Type 3
Chemical or Noxious
Liquid Substance tanks.
NOTE 1
Regulation 1(26) (new 1.28.4)
requires SBT and PL [see reg 13
(new 18)], a COW system (crude
oil tankers only [see reg 13B
(new 33.1&2+35.1&2)]) and a
small diameter stripping line to
the manifold [see reg 18(4) (new
30.4)}.
Regulations 13G&H
(new 20& 21), and
EU regulations are
not applicable. But
see
Fujairah
&
OPA 90 flow charts.
YES
NO
Is ships deadweight
< 20,000 but
5,000 tonnes?
Is ships deadweight
< 30,000 but
5,000 tonnes?
Fuel oil means heavy distillates

or residues from crude oil or
blends of such materials intended
for use as a fuel for the production
of heat or power of a quality
equivalent to the specification
acceptable to the Organization.
NO
NO
YES
Heavy diesel oil means diesel oil

other than those distillates of
which more than 50 per cent by
volume distils at a temperature
not exceeding 340C when tested
by the method acceptable to the
Organization.
Does ship comply

with requirements for
a new oil tanker as
defined in regulation
1(26) (new 1.28.4)?
(See note 1)
YES
NO
YES
Category 3
Category 2
Category 1
Category 3
Now refer to 13G flow chart appropriate to the Category of oil tanker + 13H flow chart.
See also the European Union, and Fujairah flow charts plus United States OPA 90 information.

Category 1
A Category 1 oil tanker shall comply with the requirements of Regulation 13F (new 19) of MARPOL 73/78 Annex I not later
than 5 April 2005 or the anniversary of the date of delivery of the ship on the date or in the year specified as follows:
5 April 2005 for ships delivered on 5 April 1982 or earlier;
The anniversary of the date of delivery of the ship in 2005, for ships delivered after 5 April 1982.
When the tanker reaches the dates stipulated above, there are limited options to allow any continued trading,
but there are a few examples: (a) the tanker change to MARPOL 73/78 Annex I Category 2 or 3, as shown on the previous page; or
(b) the tanker is to no longer carry MARPOL 73/78 Annex I oil cargoes, but only to carry Annex II Noxious
Liquid Substances or Chemical Code cargoes. Please note that MARPOL 73/78 Annex II is also revised from 1
January 2007, the permitted cargo lists will be revised and the Approved Procedures & Arrangements Manual
to be updated.
(c) the tanker is to be used as a Floating Storage Unit (FSU) or Floating Production Storage and Offshore facility
(FPSO)
NOTE
The Condition Assessment Scheme (CAS) will not apply to these ships, as no Category 1 ship will be permitted to
trade beyond 2005.

Category 2 and 3
A Category 2 or 3 oil tanker shall comply with the requirements of Regulation 13F (new 19) of MARPOL 73/78 Annex I not
later than 5 April 2005 or the anniversary of the date of delivery of the ship on the date or in the year specified as follows:
5 April 2005 for ships delivered on 5 April 1977 or earlier
The anniversary of the date of delivery of the ship in 2005 for ships delivered after 5 April 1977 but before 1 January 1978
The anniversary of the date of delivery of the ship in 2006 for ships delivered in 1978 and 1979
The anniversary of the date of delivery of the ship in 2007 for ships delivered in 1980 and 1981
The anniversary of the date of delivery of the ship in 2008 for ships delivered in 1982
The anniversary of the date of delivery of the ship in 2009 for ships delivered in 1983
The anniversary of the date of delivery of the ship in 2010 for ships delivered in 1984 or later
A Category 2 or 3 oil tanker of 15 years and over after the date of its delivery shall comply with the Condition Assessment Scheme
adopted by the Marine Environment Protection Committee by resolution MEPC.94 (46), as amended, to enable it to trade until the
dates stipulated above. The first CAS survey shall be carried out concurrent with the first intermediate or renewal survey after 5
April 2005, or after the date when the ship reaches 15 years of age, whichever occurs later, and at 5 year periods thereafter.
NOTE
The Administration of a State which allows, suspends, withdraws or declines the application of CAS to a ship entitled to fly its flag shall
communicate to the IMO details of the ship for circulation to other Administrations for their information and appropriate action, if any.
OPTION 1
OPTION 2
In the case of a Category 2 or 3 oil tanker fitted with only double

bottoms or double sides not used for the carriage of oil and
extending to the entire cargo tank length, or double hull spaces
which are not used for the carriage of oil and extend to the entire
cargo tank length, but does not fulfil the conditions for being
exempted from the provisions of regulation 13G(1)(c) (new 20.1.3),
the Administration may allow continued operation of such a ship
beyond the dates specified above, provided that:
The Administration may allow continued

operation of a Category 2 or 3 oil tanker
beyond the dates specified above, if
satisfactory results of the Condition
Assessment Scheme warrant that, in the
opinion of the Administration, the ship is fit
to continue such operation, provided that
the operation shall not go beyond the
anniversary of the date of delivery of the
ship in 2015 or the date on which the ship
reaches 25 years after the date of its
delivery, whichever is the earlier date.
(a) the ship was in service on July 1, 2001;

(b) the Administration is satisfied by verification of the official
records of the ship that it complied with the conditions specified
above;
(c) the conditions of the ship specified above remain unchanged; and
(d) such continued operation does not go beyond the date on which
the ship reaches 25 years after the date of its delivery.
The first CAS survey shall be carried out

concurrent with the scheduled intermediate
or renewal survey due prior to the
anniversary of the date of delivery of the
ship in 2010.
NOTE
(a) The Administration of a Party to the present Convention which allows the application of Option 1 above, or allows, suspends, withdraws or
declines the application of Option 2 above, to a ship entitled to fly its flag shall forthwith communicate to the Organization for circulation to the
Parties to the present Convention particulars thereof, for their information and appropriate action, if any.
(b) A Party to the present Convention shall be entitled to deny entry into the ports or offshore terminals under its jurisdiction of oil tankers
operating in accordance with the provisions of: Option 1 above beyond the anniversary of the date of delivery of the ship in 2015; or Option 2
above.

MARPOL Annex I Regulation 13H Flow Chart
MARPOL definitions
For the purpose of this
regulation heavy grade
oil means any of the
following:
(a) crude oils having a
density at 15C higher
than 900 kg/m3
(b) oils, except crude oils,
having either a density at
15C higher than 900
kg/m3 or a kinematic
viscosity at 50 C higher
than 180 mm2/s
(c) bitumen, tar and their
emulsions.
Is the ship an oil tanker of

600 tonnes deadweight
carrying heavy grade oil as
cargo, regardless of its date
of delivery?
NO
Regulation 13H
(new 21) is not
applicable.
YES
MARPOL definitions
The
requirement
for
minimum
distances
between the cargo tank
boundaries and the ship
side and bottom plating
need not be met in all
respects. In that event, the
side protection distances
shall not be less than those
specified in the IBC Code
for type 2 cargo tank
location and the bottom
protection distances shall
comply with regulation
13E(4) (b) (new 18.15.2)
of MARPOL Annex I.
In the new Regulation
19.3 (old 13F(3)) the oil
cargo tanks can be
protected by Type 3
Chemical or Noxious
Liquid Substance tanks.

13F(3)(a) and (b) (new
19.3.1 & 2) full double
sides and double bottom?
YES
Regulation 13H
(new 21) is not
applicable.
NO
Does ship comply with 13F(4)

(new 19.4) mid-deck tanker
or with 13F(5) (new 19.5)
other approved method of
design and construction?
YES
Regulation 13H
(new 21) is not
applicable.
NO
Regulation 13H (new 21) is applicable for an oil tanker carrying heavy grade oil.
Now refer to the flow-chart on the following page for the requirements of Regulation 13H
(new 21).

MARPOL Annex I Regulation 13H Flow Chart
Oil tankers with deadweight of 5000 tonnes
Oil tankers with deadweight of 600 but < 5000 tonnes
The tanker must be fitted with both double bottom tanks or spaces
complying with the provisions of regulation 13F(7)(a) (new 19.6.1) of
MARPOL Annex I, and wing tanks or spaces arranged in accordance with
regulation 13F(3)(a) (new 19.3.1) and complying with the requirement for
distance w as referred to in regulation 13F(7)(b) (new 19.6.2), not later than
the anniversary of the date of delivery of the ship in the year 2008.
Wing tanks required for the protection of the entire cargo tank length by
Regulation 19.6.2, for the purpose of compliance with Regulation 21.4.2,
can be used as cargo tanks for the carriage of oil other than heavy grade oils
when the ship is provided with cargo tanks so arranged that the capacity of
each cargo tank does not exceed 700m.
The tanker must comply with the requirements of Regulation

13F (new 19) of MARPOL 73/78 Annex I not later than 5
April 2005.
OPTION 1
OPTION 2
OPTION 3
In the case of an oil tanker carrying heavy grade oil as

cargo fitted with only double bottoms or double sides
not used for the carriage of oil and extending to the
entire cargo tank length, or double hull spaces which are
not used for the carriage of oil and extend to the entire
cargo tank length, but does not fulfil the conditions for
being exempted from the provisions of regulation
13H(1)(b) / 13G(1)(c) (new 21.1.2/20.1.3), the
Administration may allow continued operation of such a
ship, provided that:
The Administration may allow continued operation

when carrying crude oil having a density at 15C
higher than 900 kg/m3 but lower than 945 kg/m3
beyond 5 April 2005, if satisfactory results of the
Condition Assessment Scheme referred to in
regulation 13G(6) (new 20.6) of MARPOL Annex I
warrant that, in the opinion of the Administration, the
ship is fit to continue such operation, having regard to
the size, age, operational area and structural conditions
of the ship and provided that the operation shall not go
beyond the date on which the ship reaches 25 years
after the date of its delivery.
The Administration may

allow continued operation
of an oil tanker beyond the
anniversary of the date of
delivery of the ship in 2008,
if, in the opinion of the
Administration, the ship is
fit to continue such
operation, having regard to
the size, age, operational
area
and
structural
conditions of the ship,
provided that the operation
shall not go beyond the date
on which the ship reaches
25 years after the date of its
delivery.
(a) the ship was in service on 4 December 2003;

(b) the Administration is satisfied by verification of the
official records of the ship that it complied with the
conditions specified above;
(c) the conditions of the ship specified above remain
unchanged; and
(d) such continued operation does not go beyond the
date on which the ship reaches 25 years after the date of
its delivery.
The first CAS survey shall be carried out concurrent

with the first intermediate or renewal survey:
-
after 5 April 2005, or
after the date when the ship reaches 15

years of age
whichever occurs later, and at 5 year periods

thereafter.
NOTE 1
The Administration of a Party to the present Convention may exempt an oil tanker of 600 tons deadweight and above carrying heavy grade oil as cargo
from the provisions of this regulation if the oil tanker:
(a) either is engaged in voyages exclusively within an area under its jurisdiction, or operates as a floating storage unit of heavy grade oil located within
an area under its jurisdiction; or
(b) either is engaged in voyages exclusively within an area under the jurisdiction of another Party, or operates as a floating storage unit of heavy grade
oil located within an area under the jurisdiction of another Party, provided that the Party within whose jurisdiction the oil tanker will be operating
agrees to the operation of the oil tanker within an area under its jurisdiction.
NOTE 2
(a) The Administration of a Party to the present Convention which allows, suspends, withdraws or declines the application of Options 1, 2, 3 or NOTE 1
above to a ship entitled to fly its flag shall forthwith communicate to the Organization for circulation to the Parties to the present Convention particulars
thereof, for their information and appropriate action, if any.
(b) Subject to the provisions of international law a Party to the present Convention shall be entitled to deny entry of oil tankers operating in accordance
with the provisions of Options 1, 2 or 3 above into the ports or offshore terminals under its jurisdiction or deny ship-to-ship transfer of heavy grade oil
in areas under its jurisdiction except when this is necessary for the purpose of securing the safety of a ship or saving life at sea. In such cases, that
Party shall communicate to the Organization for circulation to the Parties to the present Convention particulars thereof for their information.

European Union requirement Flow Chart
This flow diagram applies to Category 1, 2 or 3 oil tankers flying an EU flag, and tankers
irrespective of their flag entering or leaving a port or an offshore terminal or anchoring in an area
under the jurisdiction of an EU Member State
With effect from October 21, 2003, no oil tanker with a deadweight ? 5000, carrying heavy grades of oil, irrespective of its flag, shall be
allowed to enter or leave ports or offshore terminals or to anchor in areas under the jurisdiction of an EU Member State, unless such
tanker is a double-hulled oil tanker.
Oil tankers with a deadweight of ? 600 but < 5000 shall comply with this requirement no later than the anniversary of the date of
delivery of the ship in the year 2008.
Oil tankers operated exclusively in ports and inland navigation may be exempted from this obligation provided that they are duly
certified under inland waterway legislation.
NOTE:
Heavy grades of oil shall mean:

1.
Crude oils with a density at 15C of over 900kg/m3 (corresponding to an API grade of less than 25.7);
2.
Fuel oils with a density at 15C of over 900kg/m3 or a kinematic viscosity at 50C of over 180mm2/s (corresponding to a kinematic
viscosity of over 180 cSt);
3.
Bitumen and tar and emulsions thereof.
Category 1
A Category 1 oil tanker shall comply with

the requirements of Regulation 13F (new
19) of MARPOL 73/78 Annex I not later
than the anniversary of the date of
delivery of the ship in the year specified
as follows:
2004 for ships delivered in 1981 or earlier
2005 for ships delivered in 1982 or later
The Condition Assessment Scheme does

not apply to these ships as they will have
been phased out.
NOTE
Until October 21, 2005, an EU Member
State may, in cases where ice conditions
require the use of an ice-strengthened
vessel, allow ice-strengthened single-hull
oil tankers, equipped with double bottoms
not used for the transport of oil and
extending over the entire length of the
cargo tank, carrying heavy grades of oil, to
enter or leave a port or offshore terminal or
anchor in an area under the jurisdiction of
that Member State, provided that the heavy
grades of oil are transported only in the
vessels central tanks.
Category 2
Category 3
A Category 2 or 3 oil tanker shall comply with the requirements of Regulation 13F
(new 19) of MARPOL 73/78 Annex I not later than the anniversary of the date of
delivery of the ship in the year specified as follows:
2004 for ships delivered in 1976 or earlier
2005 for ships delivered in 1977
2006 for ships delivered in 1978 and 1979
2007 for ships delivered in 1980 and 1981
2010 for ships delivered in 1984 or later
Irrespective of its flag, a single-hull oil tanker above 15 years of age shall not be
allowed to enter or leave ports or offshore terminals or anchor in areas under the
jurisdiction of an EU Member State beyond the anniversary of the date of delivery of
the ship, in 2005 for Category 2 and 3 tankers, unless it complies with the Condition
Assessment Scheme (CAS) adopted by MEPC.94(46) as amended by MEPC.99(48)
and MEPC.112(50). The first CAS survey shall be carried out concurrent with the first
intermediate or renewal survey after 5 April 2005, or after the date when the ship
reaches 15 years of age, whichever occurs later, and at 5 year periods thereafter.
Oil tankers of Category 2 or 3 which are equipped only with double bottoms or
double sides not used for the transport of oil and extending for the whole length of
the cargo tanks, or with double-hulled spaces not used for the transport of oil and
extending for the whole length of the cargo tanks, but which do not meet the
conditions for exemption under the provisions of MARPOL Annex I Regulation
13G(1)(c) (new 20.1.3), may continue to be operated after the date specified above,
but not beyond the anniversary of the date of delivery of the ship in 2015 or the date
on which the ship reaches 25 years after the date of its delivery, whichever is the
sooner.
3.15 Segregated Ballast Tanks (SBT) Upgrade

If the non-cargo spaces are to be used for ballast then the ballast arrangements must at least meet
the requirements of IMO draft and trim requirements of Regulation 18.2, and Regulation 18.12.
Having decided on the optimum arrangement of tanks to meet the above requirements, the
pumping and piping arrangements need to be considered. In most cases a cargo pump(s)
need to be dedicated to ballast handling purposes, thus removing them from cargo
handling duties.
For a system to be considered SBT, there must be no physical connection between the ballast system
and the cargo system.
In many cases it is possible to achieve an SBT system with minimal changes to the existing pumping
and piping systems. However, additional cargo/ballast piping and associated valves may need to be
installed to achieve a suitable SBT system which retains the required flexibility and efficiency for the
intended trading pattern of the vessel. A new addendum to the loading manual will be required.
While it is not explicit in the regulation, it would be prudent to isolate the designated tanks from the
cargo pumping and piping system by blank flanges. These tanks should also be isolated from the
cargo venting system.

A suitable means of draining these non-cargo carrying tanks must be provided, together with suitable
sounding and venting arrangements. Other than the fitting of blanks and providing suitable venting
arrangements, no other work should be required. However, the cargo handling system may require
some modification to the in-tank pumping and piping arrangements, in order to retain operational
efficiency and flexibility.
3.16 Regulations 29/31/32 - Retention of Oil on Board

The main requirements of Regulations 29/31/32, applicable to oil tankers of 150 gross tonnes and
above, are:
29.2
Slop Tanks
31
Oil Discharge Monitoring and Control System. (ODM System)
32
Oil/Water Interface Detector
31.4
Approved ODM Manual
Waivers are available from the requirements of these regulations for vessels engaged solely in short
coastal voyages. In such cases all dirty ballast and slops must be discharged to reception facilities.
3.17 Slop Tanks

An effective tank cleaning system is to be provided, and arrangements made to enable dirty tank
washings to be transferred to a slop tank or tanks.
The slop tank(s) should have a minimum capacity of 3% of the total cargo carrying capacity. A
reduction in this percentage is allowed if certain conditions are met.
2% if a re-circulation system can be effectively used for tank washing.
2% if SBT, DCBT or COW is provided, 1% if a re-circulation system for tank washing is

also provided.
1% in combination carriers with smooth walled tanks, 0.8% if a re-circulation system for
washing is provided.
New oil tankers of 70,000 dwt and above are to be provided with at least two slop tanks.
3.18 Oil Discharge Monitoring and Control Systems

An Oil Discharge Monitoring and Control System is a device that monitors the outflow of ballast being
discharged from cargo tanks and from slop tanks. The system monitors the outflow for oil content in
litres per mile and the total quantity of oil discharged, and must be of an approved type.
The IMO's Marine Environment Protection Committee (MEPC) introduced, in IMO Resolution
MEPC.108(49), important revisions to the Guidelines and Specifications for the type approval of this
equipment which entered into effect on 1 January 2005.
The Revised Guidelines and Specifications apply to equipment installed in oil tankers, the keels of
which are laid, or which are at a similar stage of construction, on or after 1 January 2005. The
previous Guidelines and Specifications adopted under resolutions A.393(X), A.496(XII), MEPC.13(19)
and A.586(14) are not applicable to oil tankers to which these new Guidelines and Specifications
apply.

Equipment installed in other oil tankers - the keels of which are laid, or are in a similar stage
of construction, before 1 January 2005 - should comply either with the requirements contained in
the Guidelines and Specifications adopted under resolutions A.393(X), A.496(XII), MEPC.13(19) and
A.586(14), as applicable, or
with the requirements contained in the new Guidelines and
Specifications.
For vessels to which A.586 (14) applies, there are two categories of tanker, A or B. Category A tankers
are those of 4,000 dwt and above, which must be fitted with a fully automatic system. Category B
tankers are those under 4,000 dwt which may be fitted with a manual system.
Vessels to which A.393(X) and A.496 (XII) apply are categorised as I, II III, IV (a), IV (b), V (a) or V (b).
The category is dependent upon the deadweight of the vessel, building date and when the equipment
is fitted. Each category details the complexity of the system. A category I vessel, for example, is
required to have a fully automatic system that includes stopping, input of speed and flow rate.
However, it should be noted that MEPC.108(49) requires the same equipment to be installed onto all
tankers of 150 gt and above, namely a control unit fitted with a starting interlock and automatic
overboard discharge control.
All Oil Discharge Monitoring Systems installed on oil tankers, the keels of which are laid on or after 1
January 2005, should be tested in accordance with MEPC.108(49) and be provided with a type
approval certificate issued by or on behalf of an Administration. In addition, if the equipment is to be
supplied to a ship flying the flag of a European Union member state, it must also be certified in
accordance with the MED.
Equipment currently in service, or fitted to oil tankers, the keels of which are laid prior to 1 January
2005, does not need retesting and can continue in operation under its current type approval
certification. Replacement equipment on such ships need only comply with the standard applicable at
the time of installation of the original equipment.
The system measures the oil content in the outflow in parts per million, and using inputs of ships
speed and output flow rate, calculates the litres per mile value, continuously updating the total quantity
of oil discharged.
Should the litre per mile value reach or exceed 30l/nm or the total amount of oil discharged exceed the
1/15000 or 1/30000 limit stipulated in regulation 9, the system will alarm and the discharge must be
stopped.
The usual method of stopping the discharge is for the overboard valves to automatically close and for
the valve to the slop tank to automatically open. The discharge is thus diverted from overboard to the
slop tank.
The lower the category, the less complex the system is required to be, and the fewer automatic
features are needed.
An automatic system should comprise a control unit, which receives automatic inputs of speed and
flow rate, starting interlock and overboard discharge control. A starting interlock is a device that
prevents the overboard discharge valve being opened before the ODM system is fully operational.
All systems must be capable of recording the litres per mile, ppm, total quantity of oil discharged, time
and date (GMT), ships speed, flow rate, alarms, discharge valve position (i.e. open or closed), oil type,
system failure and if the system is over riding.

3.19 Interface Detector
Prior to discharge of slops or ballast from a cargo tank, the oil/water interface must be determined to
ensure that the discharge is stopped prior to reaching the oil layer.
In its simplest form an interface detector consists of a steel tape with a brass, zinc tipped, weight on
the end, with a bonding wire between tape and weight to ensure electrical continuity. A milliammeter is
fixed to the body of the tape and the tape reel is equipped with an earthing wire, which is attached to
the ships steelwork.
When the zinc tip of the weight makes contact with the salt water beneath the oil, an electrolytic
couple is produced between the zinc and steel of the cargo tank. The current passes through the
earthing wire and causes the needle of the ammeter to deflect. By carefully adjusting the height of the
weight in the tank, the position of the oil/water interface can be established. An accuracy of + 5mm
can be obtained.
Modern interface detectors are more complex and are often able to carry out other functions such as
temperature measurement, however the principle for interface detection is basically the same.
By measuring the level of the top of the oil layer, the total contents of the tank can be obtained from
the vessel's 'ullage' tables. The amount of oil and water can then be obtained.
3.20 Regulation 30 - Pumping, Piping and Discharge Arrangements of Oil Tankers

Every oil tanker must be provided with a manifold for discharging dirty ballast ashore (the cargo
manifold satisfies this requirement in most cases).
In every oil tanker, pipelines above the deepest ballast waterline for the discharge of ballast to sea
must be provided. For existing oil tankers, the requirements for ballast discharges state that these
ships may discharge below water line, provided that a Part Flow System is fitted (this is in addition to
the requirement to monitor discharges with the ODM system). A part flow system pumps a sample of
the outflow to the deck through a sight glass in order that a visual observation of the ballast may be
made.
Every new oil tanker must be provided with a means of stopping the discharge above the open deck.
The means of stopping the discharge should be located so the manifold/discharge point can be
visually observed. This is not required if portable radio or telephone communication is available
between the two points.
Every new oil tanker provided with SBT or COW must have a piping system so that oil retention in the
lines is minimised.
Every tanker equipped with COW and/or SBT/DCBT should have a means provided to drain all pumps
and lines on completion of discharge via a connection to a stripping device if necessary. It should be
capable of being discharged both ashore and to a cargo or slop tank. For discharge ashore a special
small diameter line should be provided and connected outboard of the ship's manifold valves.

3.21 Regulation 39 - Special Requirements for Drilling Rigs and other Platforms
This Regulation applies to all vessels engaged in the exploration or exploitation of seabed mineral
resources, i.e. oil/gas exploration and production.
Any vessel in this category must comply with the requirements of Annex I applicable to non-tankers of
400 grt and above, with the exception that Regulations 12 and 14 should be complied with as far as
practicable. A record of all operations should be kept in a form approved by the Administration,
discharges of oil or oily mixtures into the sea being prohibited unless the oil content of the effluent is
less than 15ppm.
There are four categories of discharges associated with offshore platforms which are:
Machinery space drainage
Offshore processing drainage
Production water discharge
Displacement water discharge
Only the discharge of machinery space drainage should be subject to MARPOL 73/78. The remaining
discharges from processing etc. are not covered by these regulations but may be covered by national
regulations.
It should be noted that Floating Storage Units and Floating Production Units are considered as other
platforms.
It is always necessary to determine from both the Flag Administration and the government of the sea
area in which the vessel will be moored, the exact application of MARPOL since local regulations may
apply.
3.22 Requirements of Minimising Oil Pollution from Oil Tankers due to Side and
Bottom Damage
This group of Regulations, dealing with the requirements for minimising oil pollution from oil tankers
due to side and bottom damage, includes Regulations 24, 25, 26, 27 and 28.
Compliance with these regulations is verified in conjunction with structural and stability aspects at the
plan approval stage. A brief description of the regulations is as follows:
3.23 Regulation 24 - Damage Assumptions

This Regulation details the assumptions which may be made with respect to the extent of side and
bottom damage used in calculating the hypothetical outflow of oil.
3.24 Regulation 25 - Hypothetical Outflow of Oil

This Regulation states the formulae used for calculating the hypothetical outflow of oil with respect to
compartments breached by side and bottom damage to all conceivable locations along the length of
the ship, using the damage assumptions of Regulation 22.

3.25 Regulation 26 - Limitations of Size and Arrangement of Cargo Tanks
This Regulation gives details of the size and arrangements of cargo tanks to ensure that the
hypothetical outflow of oil calculated by Regulation 23 does not exceed certain limits.
3.26 Regulation 28 - Subdivision and Stability

This Regulation gives the requirements for the stability of the vessel in the event of side or bottom
damage, such that it is capable of surviving under certain damage conditions. For tankers over 20,000
dwt required to comply with Regulation 19 there are additional requirements regarding raking damage.
3.27 Regulation 27 - Intact Stability

This Regulation applies to all oil tankers of 5,000 dwt and above for which the building contract is
placed on or after 1 February 1999 or, in the absence of a building contract, whose keels are laid on or
after 1 August 1999, or which are delivered on or after 1 February 2002, or which have undergone a
major conversion after these dates.
Every oil tanker, whether at sea or in port, must comply with specific intact stability criteria for any
operating draught in the worst possible conditions of cargo and ballast loading, and which is consistent
with good operational practice, including intermediate stages of liquefied transfer operations. Under all
conditions, the ballast tanks are assumed slack. These requirements must be met through design
measures.
The worst possible conditions of cargo and ballast loading is interpreted as the vessel being loaded
with all cargo tanks filled to a level that corresponds to the maximum combined total of vertical
moment of volume, plus free surface inertia moment at 0 heel for each individual tank. Cargo density
should correspond to the available cargo deadweight at which transverse KM reaches a minimum
value, which assumes full departure consumables and 1% of the total water ballast capacity.
The maximum free surface moment should be assumed in all ballast tanks. For the purpose of
calculating GM, liquid free surface corrections should be based on the appropriate upright free surface
inertia moment. The righting lever curve may be corrected on the basis of liquid transfer moments.
Paragraph 3 permits combination carriers, which are unable to comply with the intact stability criteria
'by design', to resort to simple supplementary operational procedures. This information, which is given
to the Master in the Stability Manual, should include:
The MARPOL Reg. 27 text
Instructions on the simple operational procedures necessary to comply with the required
intact stability criteria in accordance with Paragraph 4
A statement that it is the Master's responsibility to ensure that any intended loading
condition or any stage of loading/ unloading sequence complies with the intact stability
criteria required by Reg. 27.

3.28 Ships other than oil tankers carrying oil in bulk
Regulation 2.2 is worthy of note because it is quite frequently applied, particularly to offshore supply
vessels. It is acknowledged that such vessels, due to their size and design characteristics, are not
able to comply fully with the requirements of Annex I for oil tankers. Certain of the provisions of Annex
I are still applied, such as the requirements for slop tanks, an ODM System, tanker piping systems,
and the maximum length of cargo tanks. If the aggregate capacity of the oil cargo is less than 1000m3
then a waiver is available from the slop tank and ODM System requirements.
3.29 Shipboard Marine Pollution Emergency Plan (SMPEP)

The International Maritime Organisation (IMO) has adopted a new Regulation 16 of MARPOL 73/78
Annex II, and amended Regulation 37 of MARPOL 73/78 Annex I. The new and amended regulations,
applicable to new and existing vessels, came into force on 1 January, 2001 and were to be complied
with by 1 January, 2003.
Regulation 16 of Annex II requires that any ship of 150 gt or over, which is certified to carry noxious
liquid substances, must carry onboard an approved 'Shipboard Marine Pollution Emergency Plan for
Noxious Liquid Substances'.
To assist, Guidelines for the Development of Shipboard Marine Pollution Emergency Plans for Oil
and/or Noxious Liquid Substances are published as MEPC.85(44). Note also that MEPC.54(32) has
been updated and is published as MEPC.86(44) entitled Amendments to the Guidelines for the
Development of Shipboard Oil Pollution Emergency Plans.
3.30 How the new requirements affect ships

Ships which carry noxious liquid substances (NLS) or Chemical Code (IBC or BCH) cargoes:
Tankers 150 gt and over and non-tankers of 400 gt and over already in possession of an
approved SOPEP: In order to comply with Regulation 37 of Annex I and Regulation 16 of Annex II,
vessels will require either an additional 'Shipboard Marine Pollution Emergency Plan for Noxious
Liquid Substances' (SMPEP-NLS), or to update the existing SOPEP to a 'Shipboard Marine Pollution
Emergency Plan'. (MEPC.85(44) states that a SMPEP-NLS should be combined with a SOPEP since
most of their contents are the same and one combined plan onboard is more practical than two
separate plans, in case of emergency).
Non-tankers of 150 gt and over, but below 400 gt: These too will require a SMPEP-NLS complying
with Regulation 16 of Annex II. The SMPEP-NLS should follow the requirements of MEPC.85(44). It
should be noted that non-tankers below 400 gt do not require a SOPEP. Other non-tankers such as
ORSVs, gas carriers and cargo ships with deep tanks that carry NLS or chemicals, are also subject to
these regulations.
Ships which do not carry NLS or Chemical Code (IBC or BCH) cargoes:
For ships with an approved SOPEP, there is no action required. The existing SOPEP does not need
amending or re-approval. However, it should be noted that when amending a SOPEP for any reason
after January 1 2003, the revised requirements of MEPC.54(32) as amended by MEPC.86(44) must
also be addressed. New or amended documents should be submitted to your local Lloyd's Register
Group office for approval, or the National Authority, if they have issued the NLS certificate.
MARPOL Annex III - The Prevention of Pollution by Harmful

Substances Carried by Sea in Packaged Form
Regulations for the Prevention of Pollution by Harmful Substances Carried by Sea in Packaged Form
are contained in Annex III of MARPOL 73/78.
The regulations were developed in order to identify marine pollutants so that they could be packed and
stowed on board ship in a way that minimised accidental pollution as well as to aid recovery by using
clear marks to distinguish them from other (less harmful) cargoes.
The rules on discharging harmful goods are straightforward: "Jettisoning of harmful substances carried
in packaged form shall be prohibited, except where necessary for the purpose of securing the safety of
the ship or saving life at sea". (MARPOL Annex III, Regulation 7 (1)).
The Annex states that "appropriate measures based on the physical, chemical and biological
properties of harmful substances shall be taken to regulate the washing of leakages overboard,
provided that compliance with such measures would not impair the safety of the ship and persons on
board." (MARPOL Annex III, Regulation 7 (1)).
The Annex applies to all ships carrying harmful substances in packaged form, or in freight containers,
portable tanks or road and rail tank wagons.
The regulations require the issuing of detailed standards on packaging, marking, labelling,
documentation, stowage, quantity limitations, exceptions and notifications, for preventing or minimising
pollution by harmful substances.
However, implementation of the Annex was initially hampered by the lack of a clear definition of
harmful substances carried in packaged form. This was remedied by amendments to the International
Maritime Dangerous Goods Code (IMDG Code) to include marine pollutants.
The IMDG Code was first adopted by the IMO in 1965 and lists hundreds of specific dangerous goods
together with detailed advice on storage, packaging and transportation. The amendments to the Code,
which entered into force in 1991, added the identifier "marine pollutant" to all substances classed as
such. All packages containing marine pollutants must be marked with a standard marine pollutant
mark.
Annex III of MARPOL was also amended at the same time, to make it clear that "harmful substances
are those substances which are identified as marine pollutants in the International Maritime
Dangerous Goods Code (IMDG Code)."
Annex III is optional, so that states who sign up to MARPOL 73/78 Annexes I and II are not required to
adopt the Annex at the same time. Annex III received sufficient ratifications by 1991 and entered into
force on 1 July 1992.
MARPOL Annex IV - The Prevention of Pollution by Sewage from

Ships
The discharge of raw sewage into the sea can create a health hazard, while in coastal areas, sewage
can also lead to oxygen depletion and an obvious visual pollution - a major problem for countries with
large tourist industries.
The main sources of human-produced sewage are land-based, such as municipal sewers or treatment
plants.

It is generally considered that on the high seas, the oceans are capable of assimilating and dealing
with raw sewage through natural bacterial action and therefore the regulations in Annex IV of
MARPOL 73/78 prohibit ships from discharging sewage within four miles of the nearest land, unless
they have in operation an approved treatment plant. Between four and 12 miles from land, sewage
must be comminuted and disinfected before discharge.
Governments are required to ensure the provision of adequate reception facilities at ports and
terminals for the reception of sewage.
In practice, many countries have already imposed their own regulations on ships visiting their
coastlines in order to prevent sewage discharge from damaging health and amenities. Evidence
suggests that all cruise ships and large passenger ships already have sewage treatment plants on
board, so that ships are not seen as a major source of sewage pollution.
Following concerns during the 1990s that Annex IV was not achieving sufficient ratifications to achieve
entry into force, the IMO's Marine Environment Protection Committee (MEPC) reviewed the Annex
and in March 2000, at its 44th session, approved a revised and updated Annex IV.
The revised Annex entered into force on 27 September 2003.
The obligation for Parties to provide reception facilities had been seen as one issue hampering
ratification, which could be resolved by requiring all or most ships to have sewage treatment plants.
As a result, the revised Annex IV requires ships to be equipped with an approved sewage system of
one of three types:
A sewage treatment plant
A sewage comminuting and disinfecting system for the temporary storage of sewage when
the ship is less than 3 nautical miles from the nearest land
A holding tank for the retention of all sewage, having regard to the operation of the ship,
the number of persons on board and other relevant factors
The revised Annex IV applies to the following ships engaged in international voyages:
new ships of 400 gross tonnage and above
new ships of less than 400 gross tonnage which are certified to carry more than 15 persons
existing ships of 400 gross tonnage and above, five years after the date of entry into force
of the Annex
existing ships of less than 400 gross tonnage which are certified to carry more than 15
persons, five years after the date of entry into force of the Annex
For the purposes of Annex IV, a new ship means a ship for which the building contract is placed, or in
the absence of a building contract, the keel of which is laid, or which is at a similar stage of
construction, on or after the date of entry into force of this Annex; or the delivery of which is three
years or more after the date of entry into force of this Annex. An existing ship means a ship which is
not a new ship.
Sewage means: drainage and other wastes from any form of toilets and urinals; drainage from medical
premises (dispensary, sick bay, etc.) via wash basins, wash tubs and scuppers located in such
premises; drainage from spaces containing live animals; or other waste waters when mixed with the
drainages from the arrangements described above.
Different systems for the disposal of sewage may be found on ships and the following is a brief
summary of the systems which could be provided:
Discharges for the toilet bowls into common sewage mains which are led to the ship's side
and overboard through storm valves.
Discharges to collecting and storage tanks, with or without aeration facilities, in which the
sewage is retained for disposal ashore or at sea.
Sewage treatment systems incorporating a combination of collecting and treatment tanks,

with processes designed to break down the sewage into effluent suitable for discharge into
the sea without harmful effects.
Vacuum collecting systems where sewage, air and water are drawn through piping to the
holding/treatment tanks.
Sewage flushed from the toilet bowls enters the sewage mains and storage tanks where it is broken
down by naturally occurring bacteria. This is an aerobic process which strips oxygen from the water
producing more water, carbon dioxide and new bacteria. If insufficient oxygen is present, alternative
bacteria become dominant and the process becomes anaerobic with the production of gases,
including hydrogen sulphide, methane, ammonia, etc. These gases have highly toxic and flammable
properties, in particular hydrogen sulphide is toxic to humans in concentrations as low as 10 parts per
million and its flammable vapours are heavier than air so that potentially lethal pockets of gas may
accumulate in enclosed spaces.
The generation of toxic and explosive gases in the event of anaerobic conditions is present to varying
degrees in each system. It is evident from the foregoing that an anaerobic condition in sewage
systems leading to the production of toxic and flammable gases is an unacceptable hazard within the
confined boundaries of ship.
In general sewage systems should be of a design which will avoid these problems. The primary safety
features should be incorporated in the design and operation of a sewage system and the barriers
between the sewage gases such as water traps of the toilet bowls, ventilation of the pipework and
tanks should only be considered a secondary means of protection. The primary objective should be in
the prevention of the production of hazardous gases within the systems.
With regard to the capacity of any system provided, different Administrations have suggested different
quantities of effluent from 'black water' toilet drains which vary widely. A reasonable average seems to
be in the order of:
115 litres/person/day for a conventional flushing system.
10 litres/person/day for a vacuum system.
Requirements for other systems may vary between or be less than those stated above.
The quantities given above presume that no 'grey water' from showers, galleys, etc., is
introduced to the system.
Length of voyage - in the absence of precise data a figure of 30 days should be used.
It is stressed that these quantities are an approximation and should in no circumstances be taken as a
Rule requirement, the estimated 'black water' discharge quantities should be determined by the
Builder and equipment manufacturer dependent on the Owners requirements (it is the Owners
responsibility to discharge sewage in accordance with the operational provisions of the Annex) and the
sanitation devices and holding tanks sized accordingly.
5.1 Surveys
Every ship that needs to comply with the provisions of Annex IV and is engaged in voyages to ports or
offshore terminals under the jurisdiction of other Parties to the Convention, is subject to an initial
survey before going into service. A survey is also needed before the International Sewage Pollution
Prevention (ISPP) Certificate can be issued for the first time. This is to ensure:
that shipboard sewage treatment plants meet operational requirements based on

MEPC.2(VI);
that systems to comminute and disinfect the sewage are of a type approved by the
Administration;
that the Administration is satisfied that the holding tank capacity for all sewage, is
appropriate for the ship's operation, the number of people on board, plus other relevant
factors. (The holding tank should have a means to visually indicate the amount of its
contents); and
that the ship is equipped with a pipeline leading to the exterior convenient for the discharge
of sewage to a reception facility and that such a pipeline is fitted with a standard shore
connection in compliance with regulation 11 of Annex IV. This survey should ensure that
the equipment, fittings, arrangements and material fully comply with the applicable
requirements of Annex IV.
Periodical surveys should also be carried out at intervals specified by the Administration, but not
exceeding five years, ensuring that the equipment, fittings, arrangements and material fully comply
with the applicable requirements of Annex IV.
Annual and intermediate surveys are not a requirement.
5.2 Standard discharge connections

To enable reception facility pipes to be connected with the ship's discharge pipeline, both lines should
be fitted with a standard discharge connection in accordance with the following table:
Outside diameter:
210mm
Inner diameter:
According to pipe outside diameter
Bolt circle diameter:
170mm
Slots in flange:
Four holes, 18mm in diameter equidistantly placed on a bolt circle of the

above diameter, slotted to the flange periphery. The slot width to be
18mm.
Flange thickness:
16mm
Bolts and nuts: quantity

and diameter:
Four, each of 16mm in diameter and of suitable length.
The flange should be designed to accept pipes up to a maximum internal diameter of 100mm.
The flange should be of steel or other equivalent material having a flat face.
The flange, together with a suitable gasket, should be suitable for a service pressure of 6 kg/cm2.
NOTES:
For ships having a moulded depth of 5 metres and less, the inner diameter of the discharge
connection may be 38mm.
For ships in dedicated trades, i.e. passenger ferries, alternatively the ship's discharge pipeline may
be fitted with a discharge connection which can be accepted by the Administration, such as quickconnection couplings.

5.3 MSC/Circular.648 - Guidelines for the Operation, Inspection and Maintenance
of Ship Sewage Systems
In 1992, two children travelling the Celtic Pride ferry between Swansea and Cork were tragically killed,
when they were overcome in their by toxic fumes from the ship's sewage system, which had come
through the cabin toilet. The subsequent investigation highlighted the potential dangers associated
with the operation of shipboard sewage systems if they are not properly installed, operated and
maintained.
It also led to the drafting of by the IMO of MSC/Circular.648, which contains the following safety
factors to be taken into account:
Storage and treatment tanks
Sewage may be collected into storage tanks, either for holding prior to transfer to a treatment unit, or
for later discharge. Any tank used for holding sewage is a potential source of anaerobic activity, and
the resultant production of toxic and flammable gas. The design of a tank may therefore include
features to maintain an adequate oxygen level in the liquid, thereby eliminating anaerobic conditions.
This can be achieved by direct air injection, or by air entrainment into the liquid while pumping through
an ejector nozzle.
When not equipped with an active aeration feature, the conditions within the storage tanks should be
especially monitored. These tanks should be completely emptied and flushed through at intervals that
ensure satisfactory conditions are maintained. Their design and configuration should facilitate effective
drainage and flushing.
Treatment systems may use the aerobic digestion process, or may use other means to purify the
effluent. The manufacturer's recommendations for the operation and maintenance should be followed
so that satisfactory operation can be maintained at all times. All tanks and associated systems should
also be subjected to a thorough inspection at least every year or whenever unsatisfactory conditions
are detected. Such inspections should include the following:
Removal of tank inspection covers, and the cleaning out of any deposits, paying particular
attention to areas behind internal tank divisions.
Inspections of the tank structure, internal divisions, pipework, etc.
Checking of sensing instruments, level measuring devices and valves.
Confirmation that air distribution systems are free from leaks, and any nozzles or diffuser
elements used to introduce air are in satisfactory condition.
Checking that any internal systems used to transfer tank contents are in a satisfactory
condition.
Inspecting air blowers to check discharge pressure is within allowable limits.
It is recommended that any alarms fitted to air blower systems sense unsatisfactory air pressure,
rather than just monitoring the fans and their prime movers.
Tank ventilation arrangements
Ventilation pipes to collection, storage and treatment tanks should be in good condition, clear from
internal obstruction, and of adequate size to minimize pressure drop and to ensure satisfactory
clearance of gases. The size of the vent pipes should also be sufficient to vent any air from blowers or
from vacuum collection system discharges.
Ventilation pipes should be arranged for self-draining at all angles of heel and trim in order to eliminate
any water traps that may otherwise form and cause blockage. Such pipes should not terminate in
areas where personnel have frequent access and should be clear of any sources of ignition. Any flame
gauze or other fittings on the vent terminal should be checked for cleanliness.

Toilets, showers and washbasins
To prevent backflow of sewage gases into the toilet compartments, check all drain pipes for
satisfactory water/gas tightness, plus adequate water seals and traps. Check that all sanitary fittings
are securely fastened to prevent relative movement at pipe joints. Toilet bowls incorporate a water trap
and are often fitted with vacuum breaking arrangements at the back of the trap such as individual air
pipes or patented backflow prevention valves. Such items should be checked for satisfactory condition
and operation. There should be an adequate supply of flushing water to clear the toilet blow and to
replenish the water seal.
Drainage and ventilation pipe systems
Check that drains and their air vents are clear of obstruction and are in sound water/gas tight condition
throughout their length and are self-draining at all expected angles of heel or trim. Adequate air vents
should be fitted to the piping network, paying special attention to the extremities of the system. These
should ensure an adequate supply of air and prevent plugs of water from forming within the system by
siphoning or creating vacuums to remove water seals, especially in violent rolling or pitching
conditions.
Accommodation ventilation arrangements
Particular attention should be paid to the exhaust and supply systems in toilet and washing areas.
Ventilation systems to all compartments of a ship should be designed, installed and balanced to
ensure satisfactory distribution of air. They should be maintained in a clean and efficient condition to
achieve the designed air changes throughout the service life of the vessel. In general, attention should
be paid to the following:
Examination of extraction grills, louvres, ducts, etc., in order to ensure that they are clear
and free of accumulations of dirt, fluff, etc.
Checking the adjustment of extraction louvres or cones to ensure an even extraction rate
from all spaces. However, when satisfactorily adjusted, there should be no interference
with these units, since the adjustment of one unit can seriously affect the rate of extraction
through other units. The design of these fittings should not be capable of manual
adjustment without the use of special tools or equipment. Ensure that extraction units are
never blocked off for any reason.
Ensuring that air extraction from alleyways is operating efficiently and that essential airgaps under cabin doors, etc., have not been blocked off.
Ensuring that the forced ventilation of cabin spaces is operating efficiently.
Inspecting the associated elements of ventilating systems, including:

Fans: Checking the direction of rotation, condition of impellers, etc.
Flaps and dampers: Ensuring that they have not become detached from the operating
mechanisms and that they are actually open when indicated as such.
Goosenecks and vents: Ensuring that they are clear of any obstructions, that grilles or
meshes are not painted over, etc.
Piping or ducting: Ensuring that these are intact and free from leaks throughout their
length, especially where they pass through accommodation areas.
Operational aspects
The use of large quantities of disinfectant toilet cleaners may destroy the bacteria that are essential to
the operation of aerobic sewage treatment plants. The manufacturer's recommendations should be
followed in relation to the type and quantities of cleaners to be used.
All officers and crew should be informed of the dangers of sewage gases being generated and finding
their way into working and living spaces. There attention should be drawn to the hazards identified in

these guidelines. There should be an operational procedure on board ship for reporting and recording
the inspection and maintenance of sewage systems and the action taken to deal with complaints of
foul or musty smells, which may be due to toxic, flammable or oxygen-depleted gases.
Communications
All personnel engaged in maintenance work on sewage systems should be drawn to the hazards of
encountering oxygen-depleted, toxic and flammable gases, when entering sewage tanks or working
on the system. Appropriate safety procedures should be observed before entering enclosed,
hazardous or suspect spaces.
MARPOL Annex V - The Prevention of Pollution by Garbage from

Ships
Garbage from ships can be just as deadly to marine life as oil or chemicals. The greatest danger
comes from plastic, which can float for years. Fish and marine mammals can in some cases mistake
plastics for food and can also become trapped in plastic ropes, nets, bags and other items - even such
innocuous things as the plastic rings used to hold cans of beer and drinks together.
It is clear that a good deal of the garbage washed up on beaches comes from people on shore such
holiday makers who leave their rubbish on the beach, or refuse from towns and cities. But in some
areas most of the rubbish found comes from passing ships which find it convenient to throw rubbish
overboard rather than dispose of it in ports, or from fishermen who simply throw unwanted refuse over
the side.
For a long while, many people believed that the oceans could absorb anything that was thrown into
them, but this attitude has changed along with greater awareness of the environment. Many items can
be degraded by the seas but this process can take months or years, as the following table shows:
Time taken for objects to dissolve at sea
Item
Duration
Paper bus ticket

Cotton cloth
Rope
Woollen cloth
2-4 weeks
1-5 months
3-14 months
1 year
Painted wood
Tin can
Aluminium can
Plastic bottle
13 years
100 years
200-500 years
450 years
Source: Hellenic Marine Environment Protection Association (HELMEPA)

The 1973 MARPOL Convention sought to eliminate and reduce the amount of garbage being dumped
into the sea from ships.
Under Annex V of the Convention, garbage includes all kinds of food, domestic and operational waste,
excluding fresh fish, generated during the normal operation of the vessel and liable to be disposed of
continuously or periodically.
Annex V totally prohibits the disposal of plastics anywhere into the sea, and severely restricts
discharges of other garbage from ships into coastal waters and Special Areas.
The Annex also obliges governments to ensure the provision of facilities at ports and terminals for the
reception of garbage.

The Special Areas established under the Annex are:
the Mediterranean Sea
the Baltic Sea Area
the Black Sea area
the Red Sea Area
the Gulfs area
the North Sea
the Wider Caribbean Region and
the Antarctic Area
These are areas that have particular problems because of heavy maritime traffic or low water
exchange caused by the land-locked nature of the sea concerned.
Although the Annex was optional, it did receive a sufficient number of ratifications to enter into force
on 31 December 1988. Provisions to extend Port State Control (PSC) to cover operational
requirements for the prevention of marine pollution, were adopted as a new Regulation 8 to the Annex
in 1994 (entering into force on 3 March 1996).
Like similar amendments adopted to the other MARPOL Annexes, the regulation makes it clear that
PSC officers can inspect a foreign-flagged vessel "where there are clear grounds for believing that the
master or crew are not familiar with essential shipboard procedures relating to the prevention of
pollution by garbage".
Implementation, and enforcement, was also the focus of Regulation 9, adopted in 1995, which
requires all ships of 400 gt and above; every ship certified to carry 15 persons or more; and every
fixed or floating platform engaged in exploration and exploitation of the seabed, to provide a Garbage
Record Book, to record all disposal and incineration operations.
The date, time, position of ship, description of the garbage and the estimated amount incinerated or
discharged must be logged and signed. The books must be kept for a period of two years after the
date of the last entry. This regulation does not in itself impose stricter requirements, but makes it
easier to check that the regulations on garbage are being adhered to because it means ship personnel
must keep track of and what happens to the garbage.
It may also prove an advantage to a ship when local officials are checking the origin of dumped
garbage: if ship personnel can adequately account for all their garbage, they are unlikely to be wrongly
penalised for dumping.
Regulation 9 came into force for new ships from 1 July 1997, although exactly a year later it applied to
all applicable ships built before 1 July 1997: all ships of 400 gt and above; every ship certified to carry
15 persons or more; and every fixed or floating platform engaged in exploration and exploitation of the
seabed.
The Regulation also requires every ship of 12 metres or more in length to display placards notifying
passengers and crew of disposal requirements; the placards being in the Flag State's official language
and also in English or French for ships travelling to other states' ports or offshore terminals.
Despite the entry into force of Annex V in 1988, even recent surveys carried out in the United States
each year have produced up to 10 tonnes of garbage per mile of coastline, a record that can probably
be matched in many other parts of the world. Plastic forms the biggest single item found.
Persuading people not to use the oceans as a rubbish tip is a matter of education - the old idea that
the sea can cope with anything still prevails to some extent but it also involves much more vigorous
enforcement of regulations such as Annex V.
6.1 Garbage Management Plans

All ships of 400 gt and above and every ship certified to carry 15 persons or more will have to carry a
Garbage Management Plan, to include written procedures for collecting, storing, processing and
disposing of garbage, including the use of equipment on board. The Garbage Management Plan
should designate the person responsible for carrying out the plan and should be in the working
language of the crew.
The regulation is important because it requires ship operators to track their garbage and take notice of
what happens to it.
This Garbage Management Plan, unlike many other statutory manuals, is not required to be approved
by the Administration.
In accordance with Regulation 9 of Annex V, these ships, plus fixed or floating platform engaged in
exploration and exploitation of the seabed, must provide a Garbage Record Book, to record all
disposal and incineration operations. The date, time, position of ship, description of the garbage and
the estimated amount incinerated or discharged must be logged and signed. The books must be kept
for a period of two years after the date of the last entry.
Administrations may exempt fixed or floating platforms while engaged in exploration and exploitation
of the seabed from providing a Garbage Record Book.
MEPC/Circ.317 gives Guidelines for the development of garbage management plans and an Appendix
to Annex V of MARPOL gives a standard form for a Garbage Record Book.
6.2 Shipboard incinerators

The Marine Environment Protection Committee's 40th Session in September 1997 adopted a
Standard Specification for Shipboard Incinerators. The specification covers the design, manufacture,
performance, operation and testing of incinerators designed to incinerate garbage and other shipboard
waste.
The disposal of materials at sea is controlled as summarised below.
Garbage type
Outside Special Areas
Within Special Areas
Plastics, synthetic ropes,

fishing nets, and plastic
bags
Disposal not permitted under

any circumstances
Disposal not permitted under any

circumstances
Floating dunnage, lining

and packing materials
Disposal permitted more than

25 miles offshore

circumstances
Paper, rags, glass metal,

bottles, crockery and
similar refuse

12 miles offshore

circumstances
All other garbage, paper,

rags, glass comminuted*
or ground

3 miles offshore

circumstances
Food waste not

comminuted or ground

12 miles offshore

circumstances
Food waste comminuted

or ground

3 miles offshore
Disposal permitted more than 12

miles offshore**

Mixed refuse
Disposal is controlled in
accordance with the most
stringent requirements of the
components of the garbage.
i.e. If plastic waste is mixed
with other garbage, the entire
container must be treated as
plastic and disposed to shore
reception.
Disposal is controlled in
accordance with the most
stringent requirements of the
components of the garbage. i.e.
If plastic waste is mixed with other
garbage, the entire container must
be treated as plastic and disposed
to shore reception.
*Garbage that is ground or comminuted must be able to pass through a screen having a mesh size no
greater than 25mm.
** Disposal of ground food waste is permitted more than 3 miles offshore in the West Caribbean
Special Area.
MARPOL Annex VI - The Prevention of Air Pollution From Ships
Regulations for the Prevention of Air Pollution from Ships were adopted in the 1997 Protocol to
MARPOL 73/78, and are included in Annex VI of the Convention.
In November 2003, the IMO adopted resolution A.963(23) IMO Policies and Practices related to the
reduction of greenhouse gas emissions from ships. The regulations entered into force on 19 May
2005.
7.1 Background on air pollution

The issue of controlling air pollution from ships - in particular, noxious gases from exhausts - was
discussed in the lead up to the adoption of the 1973 MARPOL Convention. However, at the time it was
decided not to include regulations concerning air pollution.
Meanwhile, air pollution was being discussed in other arenas. The 1972 United Nations Conference
on the Human Environment in Stockholm marked the start of active international cooperation in
combating acidification, or acid rain. Between 1972 and 1977, several studies confirmed the
hypothesis that air pollutants could travel several thousand kilometres before deposition and damage
occurred. This damage includes effects on crops and forests.
Most acid rain is caused by airborne deposits of sulphur dioxides and nitrogen oxides. Coal and oilburning power plants are the biggest source of sulphur dioxides, while nitrogen oxides come from car,
truck - and ship - exhausts.
In 1979, a ministerial meeting in Geneva on the protection of the environment, resulted in the signing
of the Convention on long-range Transboundary Air Pollution by 34 governments and the European
Community. This was the first international legally binding instrument to deal with problems of air
pollution on a broad regional basis.
Protocols to this Convention were later signed on reducing sulphur emissions (1985); controlling
emissions of nitrogen oxides (1988); controlling emissions of volatile organic compounds (1991) and
further reductions of sulphur emissions (1994).
During the 1980s, concern over air pollution, such as global warming and the depleting of the ozone
layer, continued to grow, and in 1987 the Montreal Protocol on substances that Deplete the Ozone
Layer was signed.
The Montreal Protocol is an international environmental treaty, drawn up under the auspices of the
United Nations, under which nations agreed to cut the consumption and production of ozone-depleting
substances, including chlorofluorocarbons (CFCs) and halons to protect the ozone layer.

In 1990, a Protocol was adopted in London that amended the original protocol and set the year 2000
as the target completion date for phasing out of halons and ozone-depleting CFCs. A second Protocol
was adopted in Copenhagen in 1992, which introduced accelerated phase-out dates for controlled
substances, cutting short the use of transitional substances and the introduction of phase-out dates for
HCFCs and methyl bromide (a pesticidal gas that depletes the ozone layer).
CFCs have been in widespread use since the 1950s as refrigerants, aerosol propellants, solvents,
foam blowing agents and insulants. In shipping, CFCs are used to refrigerate ship and container
cargo; insulate cargo holds and containers; air condition crew quarters and occupied areas; and
refrigerate domestic food storage compartments.
Halons, manufactured from CFCs, are effective fire extinguishers used in portable fire extinguishers
and fixed fire prevention systems.
7.2 IMO begins work on air pollution

In the mid-1980s, the IMO's Marine Environment Protection Committee (MEPC) had been reviewing
the quality of fuel oils in relation to discharge requirements in Annex I and the issue of air pollution had
been discussed.
In 1988, the MEPC agreed to include the issue of air pollution in its work programme following a
submission from Norway on the scale of the problem. In addition, the Second International Conference
on the Protection of the North Sea, held in November 1987, had issued a declaration in which the
ministers of North Sea states agreed to initiate actions within appropriate bodies, such as IMO,
"leading to improved quality standards of heavy fuels and to actively support this work aimed at
reducing marine and atmospheric pollution."
At the next MEPC session, in March 1989, various countries submitted papers referring to fuel oil
quality and atmospheric pollution, and it was agreed to look at the prevention of air pollution from
ships - as well as fuel oil quality - as part of the committee's long-term work programme, starting in
March 1990.
In 1990, Norway submitted a number of papers to the MEPC giving an overview on air pollution from
ships. The papers noted:
Sulphur emissions from ships' exhausts were estimated at 4.5-6.5 million tonnes per year - about 4%
of total global sulphur emissions. Emissions over open seas are spread out and effects moderate but
on certain routes, including the English Channel, South China Sea and Strait of Malacca, the
emissions create environmental problems.
Nitrogen oxide emissions from ships were put at around 5 million tons per year - about 7% of total
global emissions. Nitrogen oxide emissions cause or add to regional problems, including acid rain and
health problems in local areas such as harbours.
Emissions of CFCs from the world shipping fleet was estimated at 3,000-6,000 tonnes approximately 1-3% of yearly global emissions.
Halon emissions from shipping were put at 300-400 tonnes, or around 10%of the world total.
Adoption of the Resolution
Discussions in the MEPC and drafting work by a working group, led to the adoption in 1991, of an IMO
Assembly Resolution A.719(17) on Prevention of Air Pollution from Ships.
The Resolution called on the MEPC to prepare a new draft Annex to MARPOL 73/78 on prevention of
air pollution.

The new draft Annex was developed over the next six years and was finally adopted at a Conference
in September 1997. It was agreed to adopt the new Annex by adding a Protocol to the MARPOL 73/78
Convention, which included the new Annex. This enabled specific entry into force conditions to be set
out in the protocol.
7.3 The Protocol of 1997 (MARPOL Annex VI)

The Protocol and new Annex VI to MARPOL 73/78 entered into force on 19 May 2005.
MARPOL Annex VI on Regulations for the Prevention of Air Pollution from Ships sets limits on sulphur
oxide and nitrogen oxide emissions from ship exhausts and prohibits deliberate emissions of ozone
depleting substances.
The annex includes a global cap of 4.5% on the sulphur content of fuel oil and calls on the IMO to
monitor the worldwide average sulphur content of fuel.
Annex VI contains provisions allowing for special SOx Emission Control Areas to be established with
more stringent controls on sulphur emissions. In these areas, the sulphur content of fuel oil used
onboard ships must not exceed 1.5%. Alternatively, ships must fit an exhaust gas cleaning system or
use any other technological method to limit SOx emissions. The Baltic Sea Area is designated as a
SOx Emission Control area in the Protocol.
In March 2000, the MEPC approved a proposed amendment to Annex VI to also include the North
Sea as a SOx Emission Control Area, entering into force a year on from the Baltic Sea SOx Emission
Control Area.
Annex VI prohibits deliberate emissions of ozone depleting substances that include halons and
chlorofluorocarbons (CFCs). New installations containing ozone-depleting substances are prohibited
on all ships. But new installations containing hydro-chlorofluorocarbons (HCFCs) are permitted until
1 January 2020.
Annex VI also sets limits on emissions of nitrogen oxides (NOx) from diesel engines. A mandatory
NOx Technical Code, which defines how this shall be done, was adopted by the Conference under the
cover of Resolution 2.
The Annex also prohibits the incineration onboard ship of certain products, such as contaminated
packaging materials and polychlorinated biphenyls (PCBs).
Ships are required to undergo surveys and be issued with a certificate. The survey and certification
procedures are similar to the requirements in MARPOL 73/78 Annex I and II.
The NOx emission requirements apply to all engines, main and auxiliary (except those for emergency
use) with a power output of 130 kW or more. Engines must be tested in accordance with the NOx
Technical Code and be issued with a certificate.
Incinerators are required to be type tested in accordance with the revised IMO Specification for
Shipboard Incinerators. Cargo Vapour Emissions from tankers when loading are also controlled, with
tankers are required to be fitted with a cargo vapour return system.
MARPOL Annex VI and the NOx Technical Code apply to ships constructed1 on or after the date that
the acceptance criteria are met. For ships constructed before entry into force, Annex VI and the Code
apply at the first scheduled dry docking but no later than three years after the introduction of Annex VI
Ship constructed means ships the keels of which are laid or which are at a similar
stage of construction. See also IACS interpretation MEPC 8.
1

and the Code. Annex VI applies to all ships2, fixed and floating drilling rigs and other platforms. The
Code applies to all diesel engines with a power output of more than 130 kW, except those intended
solely for emergency use.
The IMO has adopted a circular (MEPC/Circ.344), which states:
"1: Each engine which will become, retrospectively3, subject to the provisions of regulation 13 of
Annex VI of MARPOL 73/78 upon its entry into force, should be certified in accordance with the
requirements of the NOx Technical Code.
"2: Pending entry into force of Annex VI and upon satisfactory compliance with the Code
requirements, a 'Statement of Compliance' with the NOx Technical Code should be issued by the Flag
State Administration, or an organisation acting on behalf of that Administration. Such a Statement of
Compliance should contain as a minimum, the information as required by appendix 1 of the NOx
Technical Code."
7.4 MARPOL Annex VI - General Surveys and Certification Requirements

Surveys and certification are required in a similar manner to the requirements for the familiar MARPOL
Annex I and the IOPP certificate.
Annex VI Regulations require that ships of 400 gt or above, plus fixed and floating drilling rigs or other
platforms, are surveyed and issued with an International Air Pollution Prevention (IAPP) certificate.
The survey and certification procedures will generally follow the same format as those for MARPOL
Annex I, IOPP certificates.
For ships under 400 gt, the Flag Administration may establish alternative requirements, for complying
with the provisions of Annex VI.
An IAPP certificate is valid for five years from the date of the initial survey, while its continued validity
will be maintained by annual, intermediate and renewal surveys. The surveys follow the IMO
Harmonised System of Surveys and Certification (HSSC)4.
Surveyors should consult the Country File prior to commencement of a survey to identify any
additional or specific requirements of the flag Administration.
A ship is defined in Article 2 of the International Convention for the Prevention

of Pollution from Ships, 1973 as vessel of any type whatsoever operating in the
marine environment and includes hydrofoil boats, air cushion vehicles, submersibles,
floating craft and fixed or floating platforms.
2
Applies to diesel engines installed on ships constructed, or engines that undergo a

major conversion on or after January 2000.
4 Conference Resolution.6 of MP/conf.3/35 invites the MEPC to develop the
harmonised system of survey and certification to replace the existing regulations 5 &
6 of Annex VI if MARPOL 73/78 and initiate action to amend it immediately upon
entry into force.
3

7.5 MARPOL Annex VI Surveys - general requirements
A survey is conducted to confirm that the arrangements and equipment will, with proper maintenance,
be expected to remain in good condition and working order until the next survey.
MARPOL Annex VI surveys will normally be dealt with in their entirety and not as part surveys. Only
on those occasions where the required service facilities or necessary replacement equipment is not
available locally, would items be considered for deferment.
Surveys should only be held within the permitted range dates, with a certificate ceasing to be valid if
the periodical, intermediate or annual survey, as appropriate, is not completed within the periods
specified in the relevant regulations.
Carrying out the appropriate survey will restore the validity of the certificate. The thoroughness and
stringency of this survey will depend on the time the survey was allowed to lapse.
If an owner requests a survey after the range dates have expired, then they should be informed in
writing that the certificate is considered invalid from the date of expiry until the date the survey was
held.
Renewal surveys should be completed before or by the expiry date of the certificate.
The surveyor will recommend repairs if the condition of the ship or its equipment does not correspond
with the particulars of any of the statutory certificates, or makes it unfit to sail without danger to the
ship, persons on board or the marine environment.
If the surveyor's recommendations are not carried out, the certificate will be withdrawn in accordance
with the regulations of the appropriate Convention. The master will be advised in writing that the
certificate is to be surrendered and that the certificate is invalid from the date of the letter. A copy of
the letter will be forwarded immediately to the flag administration and, when appropriate, the port state
authority.
During the survey, operational tests are required on some items of equipment. Trained personnel who
are familiar with the equipment's operation should be available to assist during the required tests.
The IAPP Initial Survey is to ensure that the working drawings used by the builders do not differ from
the approved plans. The survey shall be such as to ensure that the equipment, system, fittings,
arrangements and materials fully comply with the applicable requirements of MARPOL Annex VI.
Periodical or Renewal Surveys will, in addition to the requirements of an annual and intermediate
survey, ensure that the equipment, system, fittings, arrangements and materials fully comply with the
applicable requirements of MARPOL Annex VI.
An annual surveys will consist of:
verification that the certificate on board is in order;
an examination of the various items of equipment, together with necessary tests, which, in
the surveyor's judgement, indicates adequate condition and standard of maintenance
sufficient until the next due survey;
An Intermediate Survey will consist of:
an Annual Survey; plus
a thorough examination to ensure that the equipment complies with the Regulations and is
in good working order sufficient until the next Survey.
To assist in completing the survey a draft provisional survey checklist has been developed.

Reporting and certification
The surveyor will complete the checklist during the survey to ensure all relevant aspects are verified.
Where necessary, supplementary sheets listing specific information on the systems accepted are
appended to the checklist report.
On completion of the Initial Survey, the surveyor completes the report and issues the appropriate
certificate or Statement of Compliance.
A copy of the survey report and certificate is then exported to the central database. This ensures the
information is available to surveyors undertaking subsequent surveys.
A copy of the report and any certificate issued will be made available to the flag administration as and
when required.
On satisfactory completion of the Intermediate/annual survey, the IAPP certificate on board is
endorsed to show that the annual or intermediate survey has been completed. A copy of the survey
report is exported to the central database.
On satisfactory completion of a Renewal Survey a new certificate valid for a maximum of five years
(taking into account the requirements of the HSSC where appropriate) is issued, with a copy of the
survey report and certificate exported to the central database.
7.6 Requirements for control of emissions from ships

Regulations 12 through to 18 govern the control of emissions. Compliance is verified through plan
approval, initial survey and in service surveys.
7.7 Regulation 12 - Ozone Depleting Substances

The Regulations prohibit the installation of systems containing, or the deliberate release of, CFCs,
halons and other ozone-depleting substances. When removing these substances from a ship they
should be disposed of at appropriate reception facilities (ref. Reg. 17). This reflects existing SOLAS
requirements, the Montreal Protocol and other international agreements. Some flag administrations
have additional requirements.
Another requirement is that no fire-fighting system or other equipment such as refrigeration units
should contain Halons or other ozone-depleting substances.
For new buildings, SOLAS II-2 Regulation 5-3 prohibits the installation of systems using Halons. On
existing ships, systems containing Halons can remain in service until replaced or required to be
removed by international or national regulations.
Plan appraisal
Fire fighting systems: Fire plans should be examined for compliance with the requirements of
MARPOL Annex VI when they are examined for SOLAS and class requirements.
Refrigeration systems: Plans are only required to be submitted where an RMC (Refrigeration cargo
installation) or EP (environmental protection) notation is requested. Where plans are appraised for
compliance with class requirements, compliance with the requirements of MARPOL Annex VI should
also be addressed.
For all other systems using refrigerants, such as domestic refrigeration systems, air conditioning
systems, control air dryers, ice water machines, the attending surveyor will be required to verify that

the media used is acceptable and in compliance with the requirements. These systems should be
documented and attached to the initial survey report.
The Design Appraisal Document (DAD) will clearly indicate for which Regulations the plans have be
examined.
Initial survey requirements
The surveyor attending the initial SOLAS survey will confirm that the equipment and media are in
accordance with the approved fire control plans and are suitable for use.
It should be verified that no system contains CFCs, by reviewing the relevant documentation and
certificates.
The refrigeration media requirements are verified during the initial survey on the ship, the information
being obtained from the manufacturer and installer's information. Systems verified on board should be
documented, with a copy attached to the initial survey report.
Some countries are known to have banned their manufacturers from supplying systems with
certain refrigerants though they may be acceptable to the Flag Administration. In such
instances, installers may supply on site, different gasses to those recommended by the
manufacturer.
The information for the surveys carried out may be used for completing the MARPOL Annex VI survey
without further examination. Where there is any concern regarding the acceptability of the media used
in any of the systems, then advice should be obtained from the appropriate Plan Appraisal Centre or
London.
In service survey requirements
Once the systems have been established at the initial survey, it should be sufficient to verify that no
changes or additions have been made at all subsequent surveys. This ensures continued compliance
with the Regulation.
Where changes have been made or the transitional expiry date for the media reached and there is
concern over the action to take, advice should be obtained from the appropriate Plan Appraisal Centre
or London.
7.8 Regulation 13 - Nitrogen Oxides (NOX)

MARPOL Annex VI requires all diesel engines with a power output of more than 130 kW to be tested
and issued with an Engine International Air Pollution Prevention (EIAPP) certificate and an approved
NOx Technical File. This EIAPP certificate and approved Technical File stays with the engine and
remains valid for its marine life. Periodic verification surveys are carried out to confirm the engine
continues to operate within the onboard NOx emission limits.
Emergency diesel engines, lifeboat engines or any other engines installed in equipment intended
solely for emergency use do not have to comply with Regulation 13 of MARPOL Annex VI.
Engines installed on ships between 1 January 2000 and 19 May 2005 (when the regulation entered
into force) need to comply with the NOx technical code but are not subjected to the certification
procedures. However, if the engine undergoes a major conversion, they will need to be re-certified.
There is a grace period for existing ships of three years from entry into force.
The approved Technical File provides details of the allowable engine, components, settings, operating
values and allowable adjustments that ensure the engine will continue to operate within the acceptable
NOx emission limits.

Each EIAPP certified engine is subject to an on-board verification survey after installation as part of
the initial IAPP survey. This verification procedure, contained in the Technical File, is approved from
the following available methods:
Engine parameter method
Simplified measurement method
The direct measurement and monitoring method
Where an engine has no EIAPP certificate, (i.e. not pre-certified) certification will be required prior to
issue of the ship's IAPP certificate. Normally this will entail emission testing of the engine on-board, in
accordance with the full test bed requirements or in extreme circumstances removal to a test bed.
It is the shipowner who nominates the method to be used in order to demonstrate compliance,
not the Flag State authority. The Flag State is responsible for the acceptance and approval of
the method. The engine builder will need to supply the necessary supporting equipment,
facilities and information from the outset.
Initial on-board verification survey

The survey will identify which engines need to be certified, which have an approved NOx Technical
File, and that they all have NOx Emission pre-certification (EIAPP). It will also review the engine
certificates and NOx Technical Files to ensure that the NOx Technical files have been approved.
It verifies:
the engine, its components, settings, and operating values remain within the limits
specified in the approved NOx Technical File by performing the on-board verification
procedure;
the duty stated on the EIAPP certificate equates to the installed duty (e.g. D2 = constantspeed auxiliary application, etc.);
that the cooling system is in line with that approved for the installation;
that an Engine Parameter Book is provided for each engine. This is used to record all
modifications and adjustments to an engine that affect its emission characteristics,
including details of the replacement of parts;
that the engine data logging systems are in place and operational. The data logging system
will vary from ship to ship and engine to engine, but may consist of the engine room
logbook, telegraph records both from the engine room and bridge, and any automatic
recording devices fitted to a particular engine;
the on-board engine verification should take advantage of the engine installation and
commissioning periods to check the component marking and settings in order to minimise
the degree of inspection required later; and
that the exhaust cleaning or other NOx reduction system, where fitted, is operational.
In service surveys
These will form part of the MARPOL Annex VI annual, intermediate and renewal surveys. On
satisfactory completion of the survey, the IAPP certificate is endorsed to show that the annual or
intermediate survey has been completed. In the case of a renewal survey, a new certificate valid for a
maximum of five years is issued.
The surveys consist of:
Identifying which engines are required to be certified and have an approved NOx Technical
File.
A review of the engine certificates (EIAPP) and NOx Technical Files, ensuring that the NOx
Technical Files have been approved.
Verifying that the Engine Parameter Book for each engine exists and is up to date and
relevant entries are correctly completed. It should contain records of: work carried out on
the engine, such as modifications; setting adjustments; component replacements; and
details of engine manufacturers technical notices appertaining to the engine, details of
approved modifications, which are properly entered and signed by either the Chief or
Second Engineer or Manufacturer's Representative as appropriate and dated.
Verifying that any modification, adjustments, or replaced parts conform to the engine
specification and parameters in the NOx Technical file.
Verification that the engine data logging systems are operational and that the data records
are current. Review engine data for trends, which may indicate possible engine problems
relating to NOx emission non-compliance.
Verifying that the engine, components and settings are as detailed in the NOx Technical
File, i.e. that no modifications or adjustments have been made, by a survey in accordance
with the on-board engine verification method specified in the approved NOx Technical File
for the engine.
At this time the engine parameter method is the preferred route for verification surveys, as selected
by the engine manufacturer and is the one currently provided for in the Technical File.
The simplified method of on-board verification could be problematic since it is difficult to obtain
steady state conditions for each mode of the appropriate test cycle. The test equipment must be
calibrated in strict accordance with the NOx Technical Code.
The on-board direct measurement and monitoring method of onboard verification is not yet available
since the criteria for the recording equipment and its sensitivity have still to be documented by the
IMO.
Where fitted, the direct NOx measurement system's calibration is verified as well as its operation in
accordance with the manufacturer's recommendations. The survey will also check that the records are
available. The same applies to exhaust cleaning or other NOx reduction systems, where they are
fitted.
7.9 Regulation 14 - Sulphur Oxides (SOX)

General
The sulphur oxide (SOx) emissions from ships is controlled by a limit on the sulphur content of marine
fuel oils. This limit is currently set at 4.5%. In addition a further limit for the sulphur content of fuel oil,
of 1.5%, will exist in SOx Emission Control Areas. The Baltic Sea is the first of these areas. Ships
operating both inside and outside these Areas are required to have separate storage arrangements for
two grades of fuel oil and be provided with a means to change from one grade to the other.
When approaching a SOx Emission Control Area, the fuel must be changed over to the 1.5% sulphur
content fuel. The change over must completed before entering the control area. The times and the
ship's positions at the start and finish of each change over to and from the 1.5% fuel oil must be
recorded in a logbook, together with details of the bunker tanks and fuel used.
As an alternative to using fuel oil with a 1.5% sulphur content an, exhaust gas cleaning system or
other equivalent system may be used. The cleaning system must be capable of reducing the total
emissions to within permitted limits (SOx to 6.0g SOx/ kWh or less).
Surveys
Though this Regulation is operational, the following initial and periodical verifications surveys should
be made.

Initial survey
The surveyor will confirm the approved arrangement for compliance with this requirement and verify it
has been installed and commissioned.
This could be:
Separate fuel tanks for the two sulphur grades of fuel (4.5% and 1.5%).
An approved exhaust gas cleaning system.
An alternative equivalent approved system.
The official shipboard log book will also be verified for record purposes.
In service survey
The surveyor will confirm the approved arrangements for compliance with this requirement remain
operational and the same as when installed.
The surveyor will also verify that records of fuel change over (times, position and fuel tank capacity)
are recorded in the official log book. The bunker notes will also be reviewed to verify that the quality of
fuel carried onboard is in compliance with the requirements for sulphur content (see Reg. 18).
7.10 Regulation 15 - Volatile Organic Compounds

General
A Vapour Emission Control (VEC) System is an arrangement of piping and hoses used to collect the
vapours emitted from a tanker's cargo tanks during loading or ballasting operations for transmission
ashore to a vapour processing unit.
The Regulations themselves do not require VEC systems to be installed or utilised, but rather to
control the standard that the VEC system must comply with, and the actions required by countries,
which use VEC systems.
A vapour emission control system is only needed where local regulations require controlled discharge
of volatile organic compounds. This regulation only applies to tankers.
Plan Approval
If a Vapour Emission Control system is fitted, plan approval and a survey should be carried out to
verify its compliance with IMO MSC/Circ.585 in accordance with the requirements of the
Administration. This would be done in conjunction with verification of the VEC system for the US Coast
Guard's requirements. A VEC system consists of the following main components:
A vapour recovery line
Vapour manifolds
A closed gauging system
High level and over fill alarms
Initial and Periodical (In Service) Survey

This verifies that the ship has a Vapour Emission Control system manual or an approved tanker
transfer procedure, which contains information on the tanker's vapour collection system and pressure
drop calculations approved for compliance with MSC/ Circ 585.

An inspection of the system ensures that it remains as detailed in the approved plans of the system as
shown in the operations manual or transfer system and that the alarms and safety features are
operational.
The vapour collection system will be verified to show that the piping is electrically continuous and
bonded to the hull. The pipe discharge end is also checked to see whether it is readily identifiable in
order to prevent misconnection, and whether it has been fitted with an isolating valve capable of
manual operation.
7.11 Regulation 16 - Shipboard Incineration

General
The regulations do not require that an incinerator is fitted or that wastes must be incinerated, but
rather to control emission standards when an incinerator is installed on board a ship.
Incinerators installed on or after 1 January 2000 are to be approved according to IMO's 'Standard
Specification for Shipboard Incinerators' in MEPC76 (40).
The incineration of certain materials, which could result in toxic emissions, is prohibited. This includes
cargo residues from MARPOL Annex I, II and III, and any related contaminated packaging,
polychlorinated biphenyl's (PCBs), garbage containing traces of heavy metals and refined petroleum
products. Other aspects of incineration controls already exist in MARPOL 73/78 Annex V and the
associated guidelines for the implementation of that Annex.
Initial Survey
The survey of the installed incinerator(s) consist of:
A review of the type approval certificate and verification that a copy of the manufacturer's
operating manual is on board.
An inspection of the general condition of the incinerator and tests of the safety systems.
In Service (Periodical) survey

This consists of a visual inspection and operational test, with verification of the safety functions. The
surveyor will verify that records are maintained of sludge, waste etc., and that the incinerator outlet
temperature is monitored.
Personnel training documentation/records are also checked to confirm that operating staff are trained
to operate the incinerator.

7.12 Regulation 17 - Reception Facilities
There are no survey requirements for surveyors. It is the sole jurisdiction of the Administration to
provide suitable facilities at various port locations.
Where an owner reports details of inadequate facilities at a location to a Flag Administration surveyor,
the owner's representative should be requested to provide a report detailing their concern.
7.13 Regulation 18 - Fuel Oil Quality

General
In addition to limiting the sulphur content of oil fuel, there are controls to prevent the incorporation of
potentially harmful substances, particularly waste chemicals, into marine fuel oil. Bunkers must be free
from inorganic acids, or chemical wastes that could jeopardise the safety of the ship, be harmful to
ships' personnel, or which would contribute additional air pollution. The addition of small amounts of
additives intended to improve performance is permitted.
Bunker suppliers are required to provide ships with a bunker delivery note, giving details of the fuel
supplied, including the product name, density, quantity, its sulphur content, and a declaration that the
fuel meets the requirements of Annex VI. The bunker supplier must also provide a truly representative
sample of fuel delivered in serviceable containers. The sample must be taken in a proper manner,
sealed and signed by the supplier and the ships' officer in charge of bunkering operations.
Bunker delivery notes need to be retained on board for at least three years, and the fuel sample
retained until the fuel is either completely used or not less than 12 months.
The onus is on the bunker supplier to provide fuel of the correct quality and supply proper samples
and documentation. Owners who require their own checks on the fuel supplied can use services such
as Lloyds Registers 'Fuel Oil Bunker Analysis and Advisory Service' (FOBAS).
Survey
The survey consist of:
Verification that the bunker delivery notes are on board and retained for at least the
previous three years (refer also to Regulation 14).
Verification that bunker samples are being retained onboard for a period of at least 12
months.
7.14 Regulation 19 - Requirements For Platforms And Drilling Rigs

Annex VI applies to platforms and drilling rigs unless subject to the above exemptions. Surveys follow
the format and philosophy of those for ships, taking into account the different systems and media
employed.
7.15 Guidance on marine engine on-board verification survey

Introduction
This survey is carried out after installation on board the ship to verify that the engine's components,
settings and adjustments remain within the limits established at the NOx emission test bed trial (Pre-

certification) as recorded in the approved Technical File. Provided these conditions are maintained,
the engine will be considered as remaining within the NOx Emission limit for its category. It is now
accepted that if the NOx sensitive components and settings remain the same, then the engine remains
compliant with the NOx emission limits and therefore it is not necessary to carry out another NOx
emission test.
A verification survey of the engine is required where modifications or adjustments to the designated
components and adjustable features have been carried out since the last survey. This information
should be available in the engine parameters record book, where all modifications, repairs,
adjustments, component replacements and so on are recorded.
The engine parameters record book is supplied by the owner, in which the owner's
representative records details of engine maintenance, modification and updates to the engines
received from makers.
At each survey the engine is inspected according to the approved procedure in the Technical File. The
degree of stripping down should be sufficient to allow the NOx sensitive components, settings and
adjustments to be verified.
The surveyor will have the option of checking one or all of the identified components, settings or
operating values so as to ensure that the engine with no or minor, adjustments or modifications,
complies with the applicable emission limits, and that only components of the current specification are
being used. Where adjustments and/or modifications in a specification are referenced in the Technical
File, they must fall within the range recommended by the manufacturer and approved by the
Administration.
Where a combination of methods are used to verify compliance, such methods should be applied with
due care and diligence and only by surveyors, who through experience, understand the techniques
along with their limitations.
While looking at possible survey methods available, it is equally important to understand the variations
in components and settings that affect the engine emissions in order to appreciate their limitations,
while maintaining full confidence in the surveys undertaken.
Survey methods
The following is not a list of acceptable alternatives to direct survey, but methods which may be
utilised periodically in conjunction with the direct surveys while still maintaining confidence in the
engine's compliance.
The Technical Code Procedure
This will always be the preferred method and specifies requirements for the shipboard verification
survey.
A review of the documentation for each engine, including the engine parameter book, to
ensure the components, settings and adjustments recorded remain within the designated
limits. This may be supported by the engine log book.
Carry out the shipboard verification survey according to the procedure provided in the
engine's NOx Technical File.
Where an engine is provided with an after treatment device, such as an SCR (Selective
Catalytic Reduction) system, a check of its operation forms part of the survey. This holds
true for other NOx abatement systems, such as water injection and steam into the cylinder
or fuel, to aid combustion.

Additional survey tools
These may be used in conjunction with the direct survey procedure to limit the degree of opening up at
intermediate surveys. For renewal surveys, it is recommended that the full survey is conducted.
Classification survey: Allows verification inspection of NOx sensitive components, while

the engine is open (dismantled) for survey. This can be a very useful tool provided the
verification is thorough and the information properly recorded in the survey report such that
it is available for use at future surveys.
Operational test under load: Allows comparison and assessment of the engine operating
parameters against those in the approved NOx Technical File. This could be used to limit
the degree of opening up required after confirming the easily accessible components and
settings are acceptable. Useful for the smaller engines. driving pumps, etc. Also for
generators that are in operation, where it is not feasible to carry out the full direct
inspection.
Engine Log Book: Reviewing the engine log book data for the past few months, can
provide an insight into the engine condition through trends or variations in temperature and
pressure records of coolants, exhaust gas, fuel and lubricating oils and scavenge air.
Similarly, with reviewing records of indicator cards or peak pressures, etc., taken from the
engine. From these sources, gradual or rapid changes in the operating conditions can be
identified to provide an indication of deteriorating conditions or changes in settings or
adjustments, which could result in the engine operating without the emission limits.
On-board verification survey

The system considered here is the Engine Parameter Check Method (verification of the NOx sensitive
components), which currently the Technical Files are documenting as the most likely system to be
operated by the Owner.
The following provides a general guide for some of the main components, settings and adjustments,
which may be encountered during a survey. It is for guidance only and does not provide details of all
types of engines. When carrying out the survey, the surveyor will use the on-board NOx verification
survey procedure provided in the approved NOx Technical File, which lists the specific information and
data for the engine under survey.
Combustion chamber and compression ratio
The approved on-board survey method will define how to carry out the inspection/verification of the
various parameters or parts, and can vary between manufacturers. The following are guidelines,
where this is not clear or alternatives may be considered.
Verifying the cylinder head, piston, piston rod and shims, where relevant, is the normal method used.
However, the compression ration may be checked by taking readings for each or selected cylinders.
Other means are to check the travel of the piston and to verify that the correct shims have been used
where applicable. Care must be taken, since the wrong type of cylinder head or piston could alter the
combustion space characteristic geometry, i.e. flow/ swrill. This may not be easily observed from travel
measurements only. Variations in the combustion space/ geometry can have an effect on the NOx
emissions produced due to changes in the combustion process.
Cylinder head
Normally identified by its identification number (ID), which is usually in an accessible position without
opening up.
The NOx emissions may be altered if the combustion chamber geometry of the cylinder head is
modified, affecting NOx formation mechanism and therefore emission characteristics.

Piston and Piston Rods
Normally verified from the identification number on the piston head and connecting rod. It is possible
on some engines to verify the piston through the scavenge ports, as described in the approved
procedure or by using a boroscope where provided. Otherwise the cylinder head must be removed to
view the ID marking. In some cases, the ID is on the side of the piston or at the lower end of the piston
skirt. The connecting rod can usually be viewed from the crankcase by turning the engine.
Turbo-chargers
Turbo-chargers are sized to suit the engine power and operating characteristics. Therefore changes to
their component parts (impellers, diffuser, etc.) will affect the combustion and hence the NOx
emissions. Each major component is marked and at classification surveys their NOx identification
number should be verified. Then at periodical Annex VI surveys it would be sufficient to verify that the
correct type of turbo-charger is fitted, provided that no modification had been carried out. Modification
details can be confirmed from the records in the engine book of engine parameters.
Charge air cooler and cooling system
The temperature of the cooling water, controls the temperature of the combustion air, which has a
controlling effect on the engine combustion and thus the products of combustion. The charge air
cooler is therefore sized to ensure optimum engine operating parameters with a sea water
temperature of 250 C. Hence the importance of verifying that the cooler is the correct one for the
engine. This can be checked by the ID on the cooler nameplate. The cooler should be maintained in
good condition, with effective sealing between the two media.
The Technical File is approved for a particular cooling system and associated temperature set
points. Always consult the approved survey procedures for that engine.
Fuel injection, timing and timing control system

The injection timing, injector nozzle, injection pump or the fuel cam affect the NOx emission
characteristics or an engine.
The injector nozzle has an ID on the nozzle, which is easy to remove and check. It is important
because a different number and/or size of holes in the nozzle can affect the combustion and hence the
NOx emissions. Also, an incorrectly set injector opening pressure can affect the combustion. This may
be identified from the exhaust temperatures and indicator cards. With regular maintenance this should
not present a problem.
The fuel pumps may be in a block or individual, depending on the engine type and configuration. The
fuel may be delivered via a common rail or by individual pumps to each injector, with the injector
opening and closing by either electronic or mechanical control. The fuel pumps are marked with an
identifier and type designation, which may be checked without completely dismantling, depending on
the type fitted. For some pumps, the plunger travel is measured by a special tool after removal of the
discharge pipe, while for others it is possible to verify by removal of the side plugs and turning the
engine over to note the discharge and cut-off points in relation to the camshaft markings. Electronic
control units have an ID number and are normally sealed. Where adjustments are required, these may
only be made by an authorised manufacturer's representative.
Fuel Pumps in the common rail system are not defined as NOx sensitive components.
Injection timing depends on the system employed. Many of the smaller engines (member's of an
engine family) use pre-set electronic timing, which cannot be adjusted by the ship's staff.
In other engines (such as members of an engine group) the timing can be altered by re-positioning the
camshaft, the timing chain, drive wheels or fuel cam or its profile or software parameters in common
rail applications. These items are all marked with an identifier, plus the original settings to facilitate
verification checks. They can normally be reviewed by the removal of a cover and turning the engine
to the correct position according to the approved procedure.

7.16 Frequently Asked Questions - MARPOL Annex VI And The NOx Technical
Code
Frequently asked questions relating to Regulation 13, Certification of Marine Diesel Engines for
compliance with the NOx Emission limits, are contained in a separate document, Emissions of
Nitrogen Oxides from Marine Diesel Engines Questions and Answers, Sept 2001, available on
www.cdlive.org.
Q
Which regulations are required to be complied with?
If a statement of fact is requested then it is the owner's option which regulations are complied
with.
If an IAPP certificate or statement of compliance is requested then all the regulations as
applicable for the ship type and equipment fitted are required to be complied with:
Regulation 12
Regulation 13 (if diesel engine > 130kW are fitted)
Regulation 14
Regulation 15 (tankers only and if VEC system fitted)
Regulation 16 (if incinerator fitted)
Regulation 18
How is air pollution from ships controlled?
Annex VI controls six areas of air pollution from ships:

A prohibition on the discharge of ozone depleting substances
Emissions of nitrogen oxides -NOx
Emissions of sulphur oxides - SOx.
Volatile organic compound emissions from tankers
Incinerators emission controls
Fuel quality
What certification can Lloyd's Register offer?
If requested by a shipbuilder or an owner, Lloyd's Register can offer the following certification
and surveys:
A statement indicating the degree to which a ship complies with the MARPOL Annex VI
Regulations, which were verified at the owners' request. This would be a statement of
fact that the ship had been surveyed, with details of the regulations it complies with at the
time of survey. The statement would have no period of validity and no further surveys
would be required.
A certificate or statement of compliance with MARPOL Annex VI. This is a certificate

or statement issued in the same format as an IAPP certificate and valid for five years. To
maintain its validity, annual and intermediate surveys are required. At the end of the fiveyear period of validity, a renewal survey is required for a new certificate or statement to
be issued. The surveys required can be shown on the ships survey status on
ClassDirectLive.
Can Lloyd's Register issue certification on behalf of National Administrations?

A
Most administrations have indicated that Lloyd's Register can issue Annex VI certification on
their behalf. Other administrations have indicated that an Lloyd's Register certificate or
statement of compliance would be sufficient evidence of compliance to issue an IAPP
certificate once Annex VI comes into force. This would be issued either by the Administration
or on their behalf by an authorised representative. Surveyors should consult the Country File
requirements of the Flag Administration.
Can Lloyd's Register certify diesel engines for compliance with the NOx Technical
Code?
Yes. However, procedures for NOx code certification are not dealt with in these guidelines.
7.17 ANNEX VI Survey Requirement Map
Recycling Of Ships
The IMO adopted Guidelines on Ship Recycling at the 23rd Assembly in November-December 2003.
Resolution A.962(23) IMO Guidelines on ship recycling have been developed to give advice to all
stakeholders in the recycling process, including administrations of ship building and maritime
equipment supplying countries, flag, port and recycling states, as well as inter-governmental
organisations and commercial bodies such as shipowners, ship builders, repairers and recycling
yards.

The guidelines note that, in the process of recycling ships, virtually nothing goes to waste. The
materials and equipment are almost entirely reused. Steel is reprocessed to become, for instance,
reinforcing rods for use in the construction industry or as corner castings and hinges for containers.
Ships' generators are reused ashore; batteries find their way into the local economy; hydrocarbons on
board become reclaimed oil products to be used as fuel in rolling mills or brick kilns; and light fittings
find further use on land.
Furthermore, new steel production from recycled steel requires only one third of the energy used for
steel production from raw materials. Recycling thus makes a positive contribution to the global
conservation of energy and resources and, in the process, employs a large, if predominantly unskilled,
workforce. Properly handled, ship recycling is, without question, a 'green' industry.
However, ships sold for scrapping may contain environmentally hazardous substances such as
asbestos, heavy metals, hydrocarbons, and ozone depleting substances and others. Concerns have
been raised about the working and environmental conditions at many of the world's ship scrapping
locations and the guidelines recognise that, although the principle of ship recycling may be sound, the
working practices and environmental standards in the yards often leave much to be desired. While
ultimate responsibility for conditions in the yards has to lie with the countries in which they are
situated, other stakeholders must be encouraged to contribute towards minimising potential problems
in the yards.
The Green Passport
The concept of a 'Green Passport' for ships is included in the guidelines. It is envisaged that this
document, containing an inventory of all materials potentially hazardous to human health or the
environment, used in the construction of a ship, would accompany the ship throughout its working life.
Produced by the shipyard at the construction stage and passed to the purchaser of the vessel, the
document would be in a format that would enable any subsequent changes in materials or equipment
to be recorded. Successive owners of the ship would maintain the accuracy of the Green Passport
and incorporate into it all relevant design and equipment changes, with the final owner delivering it,
with the vessel, to the recycling yard.
The IMO's role in the recycling of ships, the terminology used to refer to ship scrapping, was first
raised at the 44th MEPC session in March 2000 after which a correspondence group was established
to research the issue, provide a range of information about current ship recycling practices and
suggestions on the IMO's role. The guidelines were developed by the Marine Environment Protection
Committee (MEPC) and finalised at the MEPC 49th session in July 2003.
Vapour Emission Control Systems (VECS)
Vapour emission control systems are required under United States Coast Guard (USCG) regulations
and MARPOL Annex VI. The IMO has published requirements for VEC systems in IMO circular
MSC/circ.585, which closely follows existing USCG requirements.
Under US Federal Law each state is required to implement 'Clean Air' legislation, which may include
requirements to control emissions of cargo vapours.
The USCG has developed Vapour Emission Control Systems regulations that are used as a standard
by individual states to ensure all ship and shore VEC facilities are compatible. The USCG VECS
Regulations for tankers are contained in the Code of Federal Regulations Part 46, Section 39 (46 CFR
39).
The Regulations apply to all tanker operations where cargo vapours can be released to the
atmosphere. The Regulations are applicable to Crude Oils, Gasoline Blends and Benzenes. The
USCG has published a list of cargoes that have been evaluated for use with VEC systems. When
'chemical' cargoes are involved there are a number of additional requirements.
Loyd's Register can undertake plan approval surveys and issue certificates of compliance with the
USCG regulations. Statements are not issued on behalf of the USCG or the flag authority, the USCG
may require further surveys.
SCHEMATIC OF A VECS SYSTEM

MAST RISER
HIGH & LOW PRESSURE
ALARMS
TANK LEVEL
ALARMS
LEVEL
GAUGE
hh
P/V VALVE
VAPOUR MANIFOLD
VAPOUR
OIL
Ballast Water Exchange
A diplomatic conference on 9-13 February 2004 adopted the International Convention for the Control
and Management of Ships' Ballast Water and Sediments, a new international convention to prevent
the potentially devastating effects of the spread of harmful aquatic organisms carried by ships' ballast
water.
The Convention will require all ships to implement a Ballast Water and Sediments Management Plan.
All ships will have to carry a Ballast Water Record Book and carry out ballast water management
procedures to a given standard. Existing ships will be required to do the same, but after a phase-in
period.
Parties to the Convention are given the option to take additional measures that are subject to criteria
set out in the Convention and to IMO guidelines. The problem of harmful aquatic organisms in ballast
water was first raised at the IMO in 1988 and since then the MEPC, together with MSC and technical
sub-committees, has been dealing with the issue.

The problem of invasive species is largely due to the expanded trade and traffic volume over the past
few decades. The effects in many areas of the world have been devastating. Quantitative data show
the rate of bio-invasions is continuing to increase at an alarming rate, in many cases exponentially,
and new areas are being invaded all the time. Volumes of seaborne trade continue overall to increase
and the problem may not yet have reached its peak.
It is estimated that somewhere in the region of between 3-10 billion tonnes are transferred globally
each year, potentially transferring from one location to another, species of sea life that may prove
ecologically harmful when released into a non-native environment.
Background
Scientists first recognised the signs of an alien species introduction after a mass occurrence of the
Asian phytoplankton algae Odontella (Biddulphia sinensis) in the North Sea in 1903.
But it was not until the 1970s that the scientific community began reviewing the problem in detail. In
the late 1980s, Canada and Australia were among countries experiencing particular problems with
unwanted species, and they brought their concerns to the attention of the IMO's Marine Environment
Protection Committee (MEPC).
In 1991 the MEPC adopted MEPC resolution 50(31) - Guidelines for Preventing the Introduction of
Unwanted Organisms and Pathogens from Ships' Ballast Water and Sediment Discharges; while the
United Nations Conference on Environment and Development (UNCED), held in Rio de Janeiro in
1992, recognised the issue as a major international concern.
In November 1993, the IMO Assembly adopted resolution A.774(18) - 'Guidelines for Preventing the
Introduction of Unwanted Organisms and Pathogens from Ships' Ballast Water and Sediment
Discharges', based on the Guidelines adopted in 1991. The resolution requested the MEPC and the
MSC to keep the Guidelines under review with a view to developing internationally applicable, legallybinding provisions.
Some examples of aquatic bio-invasions causing major impact are listed in the table, but there are
hundreds of other serious invasions that have been recorded around the world:
Name
Native to
Introduced to
Impact
Cholera
Vibrio cholerae
(various strains)
Various strains South America,

with broad
Gulf of Mexico and
ranges
other areas
Some cholera epidemics appear to be directly

associated with ballast water.
Cladoceran Water
Flea
Cercopagis pengoi
Black and
Caspian Seas
Baltic Sea
Reproduces to form very large populations that

dominate the zooplankton community and clog
fishing nets and trawls, with associated economic
impacts.
Mitten Crab
Eiocheir sinensis
Northern Asia
Western Europe,
Baltic Sea and
West Coast North
America
Undergoes mass migrations for reproductive

purposes. Burrows into river banks and dykes
causing erosion and siltation. Preys on native fish
and invertebrate species, causing local extinction
during population outbreaks. Interferes with
fishing activities.
Toxic
Algae(Red/Brown/
Green Tides)
Various species
Various
species with
broad ranges
Several species
have been
transferred to new
areas in ships'
ballast water
May form Harmful Algae Blooms. Depending on

the species, can cause massive kills of marine life
through oxygen depletion, release of toxins and/or
mucus. Can foul beaches and impact on tourism
and recreation. Some species may contaminate
filter-feeding shellfish and cause fisheries to be
closed. Consumption of contaminated shellfish by
humans may cause severe illness and death.

Name
Native to
Introduced to
Impact
Round Goby
Neogobius
melanostomus
Black, Asov
and Caspian
Seas
Baltic Sea and

North America
Highly adaptable and invasive. Increases in

numbers and spreads quickly. Competes for food
and habitat with native fishes including
commercially important species, and preys on
their eggs and young. Spawns multiple times per
season and survives in poor water quality.
North American
Comb Jelly
Mnemiopsis leidyi
Eastern
Seaboard of
the Americas
Black, Azov and

Caspian Seas
Reproduces rapidly (self fertilising hermaphrodite)

under favourable conditions. Feeds excessively
on zooplankton. Depletes zooplankton stocks;
altering food web and ecosystem function.
Contributed significantly to collapse of Black and
Asov Sea fisheries in 1990s, with massive
economic and social impact. Now threatens
similar impact in Caspian Sea.
North Pacific
Seastar
Asterias amurensis
Northern
Pacific
Southern Australia
Reproduces in large numbers, reaching 'plague'

proportions rapidly in invaded environments.
Feeds on shellfish, including commercially
valuable scallop, oyster and clam species.
Zebra Mussel
Dreissena
polymorpha
Eastern
Europe (Black
Sea)
Introduced to:
Western and
northern Europe,
including Ireland
and Baltic
Sea;eastern half of
North America
Fouls all available hard surfaces in mass

numbers. Displaces native aquatic life. Alters
habitat, ecosystem and food web. Causes severe
fouling problems on infrastructure and vessels.
Blocks water intake pipes, sluices and irrigation
ditches. Economic costs to USA alone of around
US$750 million to $1 billion between 1989 and
2000.
Asian Kelp
Undaria pinnatifida
Northern Asia
Southern Australia,
New Zealand, West
Coast of the United
States, Europe and
Argentina
Grows and spreads rapidly, both vegetatively and

through dispersal of spores. Displaces native
algae and marine life. Alters habitat, ecosystem
and food web. May affect commercial shellfish
stocks through space competition and alteration of
habitat.
European Green
Crab
Carcinus maenus
European
Atlantic Coast
Southern Australia,
South Africa, the
United States and
Japan
Highly adaptable and invasive. Resistant to

predation due to hard shell. Competes with and
displaces native crabs and becomes a dominant
species in invaded areas. Consumes and
depletes wide range of prey species. Alters intertidal rocky shore ecosystem.
One way to control the problem is for ships to exchange ballast mid-voyage in deep water. There are a
number of considerations associated with ballast exchange including stress, stability and sloshing
considerations.
Ballast water exchange
The IMO realised that ballast water exchange would involve ships in operations, which could be
hazardous and developed 'Guidelines for the Control and Management of Ships Ballast Water to
Minimise the Transfer of Harmful Aquatic Organisms and Pathogens', the most recent being
Resolution A.868(20). These Guidelines are intended to assist governments and ships in minimising
the introduction of harmful aquatic species while protecting ship safety.
When undertaking ballast water exchange, a ship has two recognised options: complete exchange,
i.e. emptying a tank and refilling it; or a 'flow-through' method i.e. pumping water into a tank and overflowing it until at least three times the tank volume has been exchanged.
Whichever method is used, an existing ship may need some modification to the ballast pumping and
piping system, particularly if the flow-through method is used. For new ships, the designer will need to
consider the requirements of ballast water exchange at the design stage of the ballast system.

Alternatives to ballast water exchange are under consideration. These involve the treatment of water
on passage or while discharging it. The alternatives include heating, filtration, hydrocyclones,
ultraviolet irradiation, chemical treatment and combinations of these methods. Standards are being
discussed at the IMO for the approval of such systems.
Carrying out ballast water exchange at sea involves carefully planning since there are a number of
hazards involved, which have the potential to seriously affect the safety of the ship.
Potential problems associated with ballast water exchange
In deciding what method to adopt, careful consideration must be given to the potential hazards and
limitations of the operation, which include the following:
Where the topside and hopper side tanks are interconnected, emptying of fore or aft water
ballast spaces could present operational difficulties in maintaining the forward draught
within allowable limits.
Emptying and filling of the ballast holds of bulk carriers and ballast tanks in other ships
may require consideration of sloshing loads on the ballast hold/tank boundaries. On
existing bulk carriers in particular substantial structural reinforcement may be required
The structure of topside and hopper tanks adjacent to the ballast hold may require
enhancement and reinforcement if it was proposed to empty and fill these spaces whilst
maintaining a full ballast hold.
The bending moments and sheer forces must be kept within the approved limits and on
some ship designs torsional stresses may also need to be considered.
A ship must be operated within its allowable stability margins, to meet both intact and
damage stability criteria. The main effects on stability will be free surface effects from
slack tanks and with the 'flow-through', from free water on deck. The effects of free surface
must be carefully considered as it can easily be underestimated.
When using 'flow through', water on deck poses additional hazards particularly for ships
with deck cargoes. Additional top weight can be added from water on deck, water can be
absorbed by deck cargo, and in cold weather by ice formation. Adequate arrangements
must be made to ensure crew safety when working on deck where free water exists.
The dangers of having to stop the complete exchange of ballast water before completion,
due to unfavourable weather conditions or other factors, must also be taken into account.
An adequate draft and propeller immersion must be maintained for the intended voyage
and the prevailing and expected weather conditions. The trim must also be maintained to
ensure bridge visibility is not affected and such that slamming is avoided.
An existing ship may need some modification to the ballast pumping and piping system,
particularly if flow- through is used. For new ships the requirements of ballast water
exchange must be considered at the design stage of the ballast system.
The ship must at all times be operated within its allowable stability margins, both intact and
damage stability criteria.
On some ship designs tensional stresses may need to be considered.
Other factors include the prevailing and predicted weather and crew safety when working
on wet decks.
To ensure that ballast exchange can be carried out safely, each ship is required to have a 'Ballast
Water Management Plan' which details the procedures for the ship, the hazards, limitation and
contingency measures.
It can be seen that ballast water exchange needs to be very carefully considered by owners and the
ships staff so as to ensure the safety of the ship. This includes the need for proper training. Carrying
out ballast water management practice at sea should not result in placing the ship and its crew in
hazardous situations. Operationally ballast water management practice will require ship staff to

undertake procedures which they may well not be familiar with. It is therefore very important that those
involved in ballast water management receive proper training and that sufficient guidance is provided
onboard concerning the possible hazards involved and the safe practices to be followed to ensure the
safety of the Ship and its crew.
The International Association of Classification Societies (IACS) is concerned about the safety aspect
of ballast water exchange and has undertaken a study to investigate the possible problems that can
be associated with ballast water exchange. The first stage of this was presented to the IMO in 1998
and IACS will continue to monitor the progress of the regulations, advising the IMO on safety issues.
Lloyds Register has also been investigating the safety aspects of ballast water exchange and has
been working closely with IACS.
10 Anti-fouling systems on ships

A new IMO Convention will prohibit the use of harmful organotins in anti-fouling paints used on ships
and will establish a mechanism to prevent the potential future use of other harmful substances in antifouling systems.
The 'International Convention on the Control of Harmful Anti-fouling Systems on Ships' was adopted
on 5 October 2001 at the end of a five-day diplomatic conference held at IMO headquarters in London.
Under the terms of the new Convention, Parties to the Convention are required to prohibit and/or
restrict the use of harmful anti-fouling systems on ships flying their flag, as well as ships not entitled to
fly their flag but which operate under their authority and all ships that enter a port, shipyard or offshore
terminal of a arty.
Ships of 400 gt and above engaged in international voyages (excluding fixed or floating platforms,
FSUs and FPSOs) will be required to undergo an initial survey before the ship is put into service or
before the International Anti-fouling System Certificate is issued for the first time; and a survey when
the anti-fouling systems are changed or replaced.
Ships of 24 metres or more in length but less than 400 gt engaged in international voyages (excluding
fixed or floating platforms, FSUs and FPSOs) will have to carry a Declaration on Anti-fouling Systems
signed by the owner or authorised agent. The Declaration will have to be accompanied by appropriate
documentation such as a paint receipt or contractor invoice.
Anti-fouling systems to be prohibited or controlled will be listed in Annex 1 of the Convention, which
will be updated as and when necessary.
The harmful environmental effects of organotin compounds were recognised by IMO in 1989. In 1990,
the IMO's Marine Environment Protection Committee (MEPC) adopted a resolution that recommended
the governments adopt measures to eliminate the use of anti-fouling paint containing TBT on nonaluminium hulled vessels of less than 25 metres in length and eliminate the use of anti-fouling paints
with a leaching rate of more than four microgrammes of TBT per day.
In November 1999, the IMO adopted an Assembly resolution that called on the MEPC to develop an
instrument, legally binding throughout the world, to address the harmful effects of anti-fouling systems
used on ships. The resolution called for a global prohibition on the application of organotin compounds
which act as biocides in anti-fouling systems on ships by 1 January 2003, and a complete prohibition
by 1 January 2008.
The new convention will enter into force 12 months after 25 states, representing 25% of the world's
merchant shipping tonnage have ratified it.
Annex I attached to the Convention and adopted by the Conference, states that by an effective date of
1 January 2003, all ships shall not apply or re-apply organotins compounds that act as biocides in antifouling systems.
By 1 January 2008 (effective date), ships either:

(a)
shall not bear such compounds on their hulls or external parts or surfaces; or
(b)
shall bear a coating that forms a barrier to such compounds leaching from the underlying noncompliant anti-fouling systems.
This applies to all ships (excluding fixed and floating platforms, floating storage units (FSUs), and
Floating Production, Storage and Offloading units (FPSOs).
The Convention includes a clause in Article 12, which states that a ship shall be entitled to
compensation if it is unduly detained or delayed while undergoing inspection for possible violations of
the Convention.
The Convention provides for the establishment of a 'technical group', to include people with relevant
expertise, to review proposals for other substances used in anti-fouling systems to be prohibited or
restricted. Article 6 on Process for Proposing Amendments to controls on Anti-fouling systems sets out
how the evaluation of an anti-fouling system should be carried out.
The Conference adopted four Resolutions:
Resolution 2: Future work of the organisation pertaining to the Convention. The resolution invites the
IMO to develop guidelines for brief sampling of anti-fouling systems; guidelines for inspection of ships;
and guidelines for surveys of ships. The guidelines are needed in order to ensure global and uniform
application of the articles of the Convention that require sampling, inspection and surveys.
Resolution 3: Approval and Test Methodologies for Anti-Fouling Systems on Ships. This resolution
invites states to approve, register or license anti-fouling systems applied in their territories. It also
urges them to continue the work, in appropriate international fora, for the harmonisation of test
methods and performance standards for anti-fouling systems containing biocides.
Resolution 4: Promotion of Technical Co-operation - The resolution requests IMO Member States, in
co-operation with the IMO, other interested States, competent international or regional organisations
and industry programmes, to promote and provide directly, or through the IMO, support to States in
particular developing States that request technical assistance for:
(a)
the assessment of the implications of ratifying, accepting, approving, or acceding to and complying
with the Convention;
(b)
the development of national legislation to give effect to the Convention; and
(c)
the introduction of other measures, including the training of personnel, for the effective
implementation and enforcement of the Convention.
It also requests Member States, in co-operation with the IMO, other interested states, competent
international and regional organisation and industry programmes, to promote co-operation for scientific
and technical research on the effects of anti-fouling systems as well as monitoring these effects.
Background
Anti-fouling paints are used to coat the bottoms of ships to prevent sea life such as algae and
molluscs attaching themselves to the hull, thereby slowing down the ship and increasing fuel
consumption.
The new Convention defines anti-fouling systems as a coating, paint, surface treatment, surface or
device that is used on a ship to control or prevent attachment of unwanted organisms.
In the early days of sailing ships, lime and later arsenic were used to coat ships' hulls, until the modern
chemicals industry developed effective anti-fouling paints using metallic compounds.
These compounds slowly leach into the sea water, killing barnacles and other marine life that have
attached to the ship. But the studies have shown that these compounds persist in the water, killing
sea life, harming the environment and possibly entering the food chain. One of the most effective anti-

fouling paints, developed in the 1960s, contains the organotin tributylin (TBT), which has been proven
to cause deformations in oysters and sex changes in whelks.
The Guidelines cover the following broad areas:
10.1 When are surveys required?

Before an International Anti-fouling System Certificate can be issued issued for the first time, an initial
survey should be carried out on the ship, whether or not it is a newbuild. A major conversion affecting
the anti-fouling system of a ship may be considered as a newbuild.
The initial survey of the anti-fouling system on ships already in operation may best be carried out
during a dry-dock survey. However, a survey should be carried out whenever an anti-fouling system is
changed or replaced.
Repairs generally do not require a survey, but those which affect approximately 25% or more of the
anti-fouling system, should be considered as a change or replacement of the anti-fouling system. A
non-compliant anti-fouling system controlled under the Anti-Fouling Convention, which undergoes
repair must be replaced with a compliant anti-fouling system.
Request for survey
The owner/manager should formally request a survey, detailing the ships basic details. This should be
supplemented by a declaration and supporting information from the anti-fouling system manufacturer,
confirming that the anti-fouling system applied, or intended to be applied, complies with the
requirements of the Convention (with an identification of the version of the Convention referred to).
Such a declaration should provide the following information contained in the Record of Anti-Fouling
System, as can be found in the Convention:
Type of anti-fouling system
Name of anti-fouling system manufacturer
Name and colour of anti-fouling system
Active ingredient(s) and their Chemical Abstract Service Registry Number (CAS number(s))
Information required by the surveyor regarding compliance should be found in a declaration from the
anti-fouling system manufacturer, which may be provided on the anti-fouling system container and/or
on supportive documentation (such as Material Safety Data Sheets (MSDSs)). A link between the
supportive documentation and the relevant container should exist.
Conduct of surveys for new buildings
The survey verifies that the anti-fouling system specified by the documentation complies with the
Convention and is identical to the system specified in the request for survey.
The verification includes one or more of the following tasks, as deemed necessary to achieve this:
A check to ensure the product identification on anti-fouling system containers used during
the application process is identical to the system specified in the request for survey
Sampling of the anti-fouling system
Testing of the anti-fouling system
Other checks conducted on site
The verification tasks will be conducted at any time, either before, during, or after the anti-fouling
system has been applied to the ship, as deemed necessary to verify compliance. No checks or tests
must affect the integrity, structure or operation of the anti-fouling system.

Surveys of existing ships intending to apply a new anti-fouling system
If the International Anti-fouling System Certificate confirms that the existing anti-fouling system is not
controlled under the Convention, then the survey provisions for newbuilds described above apply to
existing ships. Where the certificate does not document anti-fouling systems that have been declared
uncontrolled, then a survey will verify whether or not they comply with the convention's requirements.
This verification may be based on sampling and/or testing, and/or reliable documentation, as deemed
necessary, according to experience gained and existing circumstances. Documentation could be
MSDSs, or similar, a declaration of compliance from the anti-fouling system manufacturer, invoices
from the shipyard and/or the anti-fouling system manufacturer.
The removal of existing anti-fouling systems should also be verified, in addition to the provisions for
the survey of new buildings.
The application of a sealer coat is also subject to verification. The survey confirms that the name, type
and colour of the sealer coat matches those specified in the request for survey, and that it covers the
existing anti-fouling system. The provisions described for the survey of newbuilds also apply.
If the existing anti-fouling system is controlled under the Convention, it should be removed or covered
by a sealer coat not later than 1 January 2008. Prior to this date, the existing anti-fouling system may
be over-coated with an uncontrolled anti-fouling system, without removing or sealing the existing
system. This option should be stated on the International Anti-Fouling System Certificate by ticking off
the appropriate box.
Surveys of existing ships requesting only an International Anti-fouling System Certificate
If the existing anti-fouling system is controlled under the Convention (i.e. containing
prohibited/regulated compounds), an International Anti-fouling System Certificate may be issued on
request, stating that the anti-fouling system will be removed, or covered with a sealer coat when
directed by the Convention.
Where the anti-fouling system is not controlled under the Convention, verification will be carried out to
confirm that the system complies the Convention requirements as described in the previous section.
The International Anti-fouling System Certificate may be issued if documentation, such as an MSDS or
an invoice from the anti-fouling system manufacturer, does not raise any doubt that the system is
compliant with the Convention.
Surveys of ships prior to entry into force of the Convention
If authorised by the Administration, Lloyd's Register may conduct surveys of ships and issue a
Statement of Compliance before the Convention enters into force. On this basis ships may be issued,
upon entry into force of the Convention, an International Anti-fouling System Certificate subject to any
additional requirements from the Administration.

MARPOL ANNEX VI APPLICATION TO EXISTING SHIPS (KEELS OF WHICH LAID BEFORE 19 MAY 2005)
Surveys
Application
Ships 400 grt and

every fixed and
floating drilling rig
and other platform
Application
Date
General
Requirements
Initial, annual,
intermediate and
periodical surveys.
Survey of engines
conducted in
accordance with
NOx Technical
Code.
Note: Although
initial surveys
would be held
concurrent with
the issue of
certification, it is
nonetheless
necessary for the
requirements of
MARPOL Annex
VI to be complied
with on 19 May
2005.
Certification
Ozone
Depleting
Substances
Nitrogen
Oxides (NOx)
Sulphur Oxides
(SOx)
Ships 400 grt on

international
voyages, and
platforms and
drilling rigs on
international
voyages
All ships and fixed

and floating drilling
rigs regardless of
size
All ships regardless

of size
First scheduled
drydocking after 19
May 2005, but no
later than 19 May
2008
19 May 2005
Each diesel engine

of 130 kW
installed on a ship
whose keel laid
on/after 1 Jan 2000.
Any diesel engine of
130 kW which
undergoes major
conversion, on/after
1 Jan 2000
19 May 2005
International Air
Pollution Prevention
(IAPP) Certificate.
5 year period of
validity, but subject
to HSSC where
applicable
Deliberate emissions
of ODS (including
whilst maintaining,
servicing, repairing
or disposing)
prohibited.
UK Flag ships are

required to be
surveyed and issued
with IAPP
certificates as soon
as possible
New installations
prohibited, except
those containing
HCFCs permitted
until 1 Jan 2020.
New installations
includes new
portable fire
extinguishing units
and insulation, but
excludes repair or
recharge of
previously installed
units
NOx emissions to be
within limits, and
engine to comply
with NOx Technical
Code.
Does not apply to
emergency diesel
engines, lifeboat
engines or any
device solely for
emergency use.
This regulation only
applies to diesel
engines at present,
and not steam
turbine or gas
turbine systems
Shipboard
Incineration
Fuel Oil Quality
All tankers
regardless of size,
when trading to a
port or terminal
which regulates
VOC emissions

of size

of size
19 May 2005
Subject to a 12
month waiver, so
becomes effective
19 May 2006.
19 May 2005
19 May 2005
19 May 2005
Sulphur content of
any fuel used
onboard not to
exceed 4.5% m/m.
Vapour collection
system to be
provided, complying
with MSC/Circ.585.
Shipboard
incineration only
allowed in a
shipboard
incinerator.
In SOx Emission
Control Areas
sulphur content of
fuel used onboard
not to exceed 1.5%
m/m unless exhaust
gas cleaning system
or equivalent used.
Tankers with a
VECS System
approved by LR will
also comply with
MSC/Circ.585.
Fuel oil for

combustion
delivered to and
used onboard to
comply with this
regulation.
If operating on both
high and low
sulphur fuel, the
practical
arrangements of fuel
storage and transfer
need to be
considered.
Volatile
Organic
Compounds
Only applies to gas

carriers when
loading and
containment system
allows safe retention
of non-methane
VOCs on board, or
their safe return
ashore.
Shipboard
incinerator installed
on/after 1 Jan 2000
to be approved in
accordance with
MEPC.76(40).
Oil and sewage
sludge incineration
may take place in
main or auxiliary
power plant or
boilers.
Prohibited
incineration of
certain materials
Bunker delivery
note to be kept
onboard for 3 years,
and fuel oil sample
for 1 year, after fuel
delivered

Marpol 2007

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Lloyds Register ASIA

MARPOL 73/78 Annexes I, IV, V and VI

Lloyds Register ASIA is an exempt charity

Lloyds Register EMEA

MARPOL 73/78 Annexes I, IV and VI

AN INTRODUCTION TO MARPOL 73/78

MARPOL 73/78 is an international convention comprising a set of regulations aimed at preventing

1.1 The MARPOL Annexes

This Annex, which entered into force on 2 October

Annex II: Regulations for the Prevention of

This Annex entered into force on 6 April 1987, and

Annex III: Regulations for the Prevention of

This came into in force on 1 July 1992, and is

Lloyds Register ASIA

MARPOL 73/78 Annexes I, IV, V and VI

This Annex entered into force on 27 September 2003.

Annex V: Regulations for the Prevention of

This Annex came into force on 30 December 1988 and

Annex VI: Regulations for the Prevention of

This Annex was adopted by the IMO on 26 September

MARPOL Annex I - The Prevention of Pollution By Oil

2.1 Background: From OILPOL 54 to the Prestige disaster

Lloyds Register ASIA

MARPOL 73/78 Annexes I, IV, V and VI

Lloyds Register ASIA

MARPOL 73/78 Annexes I, IV, V and VI

1973 International Convention for the Prevention of Pollution from

Lloyds Register ASIA

MARPOL 73/78 Annexes I, IV, V and VI

3.1 Exxon Valdez disaster

Lloyds Register ASIA

MARPOL 73/78 Annexes I, IV, V and VI

Survey and certification

Requirement for machinery spaces for all ships

Requirement for the cargo area of oil tankers

Lloyds Register ASIA

MARPOL 73/78 Annexes I, IV, V and VI

Prevention of oil pollution arising from an oil pollution incident

Special requirement for fixed or floating platforms

The extent of compliance is determined by applying the following factors:

Type of vessel - tanker or ship other than a tanker

Size of vessel - gross tonnage, deadweight and length

The various regulations have differing application dates.

Which vessels do these regulations apply to?

Lloyds Register ASIA

MARPOL 73/78 Annexes I, IV, V and VI

For cargo area discharges from an oil tanker:

3.3 Regulations applying to all ships

Lloyds Register ASIA

MARPOL 73/78 Annexes I, IV, V and VI

Oil Filtering Equipment - used to describe 15ppm equipment.

Monitoring Equipment - more commonly referred to as a bilge monitor or 15ppm alarm.

Lloyds Register ASIA

MARPOL 73/78 Annexes I, IV, V and VI

Lloyds Register ASIA

MARPOL 73/78 Annexes I, IV, V and VI

Lloyds Register ASIA

MARPOL 73/78 Annexes I, IV, V and VI

Regulation 36 - Oil Record Book

whenever bunkers or lube oil is loaded and discharged; or

Lloyds Register ASIA

MARPOL 73/78 Annexes I, IV, V and VI

A fully laden tanker arrives at a discharge port