MARPOL Annex I Oil Pollution
The following requirement and clarification has been received from the DMA, in relation with the application of the new regulation 12.2.2 of MARPOL Annex I which entered into force on 1st January 2011:
The regulation, which is applicable to every ship of 400 GT and above, requires that oil residue (sludge) tanks shall have no discharge connections to the bilge system, oily bilge water holding tank(s), tank top or oily water separators.
For ships constructed on or after 31st December 1990, this matter was dealt with under the previous version of regulation 12 and Interpretation 17 (paragraph 17.1.3). However, this interpretation was not mandatory and its application depended on individual flag state requirements; consequently, some ships built between 1991 and 2010 do not comply with the interpretation. There is no applicable requirement/interpretation for ships built prior to 31st December 1990.
It is the understanding of the Danish Maritime Authority (DMA) that regulation 12.2.2 applies to both new and existing ships. We also understand that it was accepted during the development of the regulation that modifications would be required to the piping systems of ships not built in compliance with the new requirements. However, we have become aware that some recognised organisations either do not require modifications to be carried out at all or they may allow modifications to be deferred until the next scheduled IOPPC renewal survey.
On this background, please note that the DMA require the piping systems of non-compliant ships to be modified as necessary not later than the first IOPPC survey (annual, intermediate or renewal as applicable) conducted on or after 1st January this year.
Source: BUREAU VERITAS
