West P&I Club: Key measures to avoid pollution in Turkey

The Club has highlighted some key recommendations for vessels transiting Turkish waters when engaging in any operations where there is a risk of pollution. While the list of recommendations is not exhaustive, it is imperative to comply with all relevant anti-pollution procedures within Safety Management Systems and ensure crews are fully familiar with these procedures. 

• Vessels to conduct environmental briefings for all crew prior to arriving in Turkish waters to ensure they understand the heightened risks when operating in the region.
• De-ballasting operations should be avoided. If the vessel is fitted with an approved BWTS, this system shall be used with all appropriate details noted into the vessel’s ballast log during such operation. All the sensors and associated components should be checked for faults to verify the system is fully operationally compliant before discharging ballast.
• If ECGS is being utilised by the vessel, ideally operate it in closed loop mode (though this is a design limitation on some systems) to prevent overboard discharge from the scrubber tower of potentially sooty water.
• Ensure that the anchor wash system valves are closed and not used in port for the duration (i.e. to clean sediment off the anchors or test the system)
• Lubricants used in the rudder stock/stern tube are ideally environmentally acceptable lubricants (ELA)
• Avoid so far as possible performing internal transfer of bunker fuel, bilge, slops etc. to reduce the potential risk of tank overflow, which could lead to an overboard spill. Strict adherence to operation checklists is advised with heightened oversight during operations.
• When engaged in bunkering operations, follow operational procedures and ensure scuppers are plugged and the manifold is monitored by crew at all times. Ensure the bunker manifolds station are recorded on video where possible, ensuring compliance with intrinsically safe operations where applicable, to aid against any accidental spillage dispute. Crew should be vigilant in checking for leaks on deck and monitoring the operation for any potential concerns.
• Ensure that Garbage Record Book and the Oil Record Book carried on board are fully up to date with recent entries checked for missing information.
• All overboard discharge valves should be closed and secured/sealed and recorded in the appropriate logbook. Periodical checks of valve proper function are advisable. The overboard discharge valves must be maintained as per vessel’s PMS
• All deck scuppers should be plugged and any gaps in the fish plate surrounding the deck should be closed. The scupper plugs need to be checked prior to arrival in Turkish waters r to ensure proper functioning.
• Hydrostatic test of deck pipes/hoses or other equipment should not be performed.
• Washing of decks and superstructure should be avoided to reduce the risk of washing any chemicals/dirty water overboard into the sea.
• Treated water from the sewage system and grey water should be transferred to a holding tank and should not be discharged until the vessel is outside Turkish waters.
• Bins on deck should be checked to ensure they are not overfilled to protect against the risk of garbage finding its way overboard by accident.
• Cargo residues, cargo space cleaning residues, all garbage and other substances should not be disposed of in Turkish waters.
• The vessel’s hull should not be scraped, chipped, or painted while alongside or at anchor with it being better to conduct this work once away from Turkish Waters.
• If the vessel is in the shipyard, the work of the shipyards’ workers must be strictly checked and any negligence of shipyard workers and/or if any defective equipment is used, the shipyard management must be informed in writing.
• Where it is ascertained that a pollution event has occurred, the Master should contact the Port State Control, their management, the Club and local correspondent immediately. Masters should take their own photos/videos of the scene and preserve all relevant evidence. 

In summary – no discharges from the vessel should go overboard while operating in Turkish waters. To remind, there are new pollution rates in effect since January 1st 2024, pursuant to the Turkish Environmental Code.