Be Proactive!

• Identify problems with your oil contaminated liquid waste management system before port state control officials identify them for you

• The U.S. Coast Guard published a policy letter providing detailed guidance for investigators.  It is clear that enforcement actions will continue.

• Enforcement actions frequently involve criminal prosecution resulting in jail time and multi-million dollar fines for the company's management personnel, as well as the ship's crew. 

• In many cases company personnel and ship's crew want to do the right thing, but fall prey to poor oversight, sloppy record-keeping, or just get scared and do not tell the entire truth when confronted by the authorities.  In other cases...crew members and company personnel are intentionally violating the law.

We will:

•  Observe the operation of the OWS  (Oily Water Separator) 

• Assess crew intentions as it relates to the handling of oily waste

• Assess crew competency to operate the system

• Review your Oil Record Book and associated transfer records

• Assess company policy

• Prepare a detailed written report with embedded photographs of our findings

• Provide recommendations on establishing a comprehensive compliance program for your company and ships

• MARPOL I : Prevention of Pollution By Oil (Storage, Treatment, and Disposal of Oily Water and Sludge)

• MARPOL IV : Prevention of Pollution By Sewage (Storage, Treatment, and Disposal of Greywater and Blackwater)

•  MARPOL V : Prevention of Pollution By Garbage 

•  MARPOL VI : Prevention of Air Pollution 

• International Convention for the Control and Management of Ships' Ballast Water and Sediments

• EPA National Pollutant Discharge Elimination System (Vessel General Permit)