ITOPF paper
As of 1st January 2013, amendments to MARPOL Annex V mean that shippers have new responsibilities regarding cargo classification and how it affects the ability of the crew to discharge hold wash water into the marine environment. From this date shippers will need to consider whether or not the cargo residues present in the water are harmful to the marine environment (HME).
ITOPF paper on Bulk Cargo Hold Wash Water Discharge and Cargo Declarations under MARPOL Annex V sets out the requirements as well as the concept and process of classification of cargoes as HME.
The discharge of wash water and any non-recoverable cargo residues contained therein is primarily controlled through MARPOL Annex V, where it is classed as garbage and therefore subject to the controls specified within Regulations 4.1.3 and 6.1.2. of the recent amendments to MARPOL. In essence the discharge of cargo residues contained in wash water is governed by the following criteria:
- No discharge of cargo residues should occur less than 12 nautical miles from the nearest land, or the nearest ice shelf.
- No discharge of cargo residues should occur within the six MARPOL defined “Special Areas” (the Mediterranean, the ”Gulfs” area, the wider Caribbean including the Gulf of Mexico, the baltic Sea, the North Sea and the Antarctic). The discharge of cargo residues contained in wash water is only permitted if both the destination and departure ports are within the Special Area and the ship will not transit outside the special area between these ports, and only provided that no adequate reception facilities (RF) exist. In such instances discharge of non recoverable, non HME cargo residues in hold wash water should take place as far out to sea is practicable and, in any event, no less than 12 nautical miles from the nearest land or the nearest ice shelf.
- No discharge of any cargo residues specified as HME. Hold wash water should be discharged to a suitable reception facility. Note that due to a reported lack of adequate reception facilities at present, MEPC Circular 810 allows the discharge of HME cargo residues contained in hold wash water until 31st December 015 outside Special Areas providing that i) based on the information from the relevant port authorities, the master determines that there are no adequate RFs at the receiving terminal or at the next port of call, ii) the ship is en route and as far as practicable(but at leasdt 12 nautical miles) from the nearest land, iii) before washing solid bulk cargoes are removed (and bagged for discharge ashore) as far as practicable (and the holds swept), iv) filters are used in the bilge wells to collect any remaining solid particles and v) that the discharge is recorded in the garbage record book with the flag state notified utilising the revised consolidated format for reporting alleged inadequancies of port reception facilities stated in MEP.1/Circ.469/Rev.2. It is still a requirement for receiving terminals to provide adequate port reception facilities for this waste stream, this circular only provides flexibility for ship owners and operator in the case when receiving terminals have failed to meet their obligations under the Annex
For more information, please click at ITOPF paper
It is not allowed to pump wash water with cargo residues that are not harmful to the marine environment outboard in special areas as, for example, the North Sea. So after discharging clay, salt, stones or timber, you must order trucks to pump out the wash water. If you clean well a hold of, for example, a cargo ship of about 2500 mt deadweight, you will have about 20 m3 wash water. A couple of trucks will be needed , to pump out this wash water and to transport it, using fuel that contaminates the environment. The wash water with, for example, clay residues, where they will leave it? I suppose they let it go into the sewage systeem that will bring it to a sewage plant, where this water with clay rediues will be “cleaned” ???? This is protecting the environment, or only making difficult the life of seamen and shipsowners??? Who invented this rule???