Shipping Industry Guidance On Environmental Compliance PDF
Shipping Industry Guidance On Environmental Compliance PDF
Shipping Industry Guidance On Environmental Compliance PDF
Environmental
Compliance
A framework for ensuring compliance with
MARPOL
Also supported by
BIMCO
Society of International
Gas Tanker and
Terminal Operators
Environmental
Compliance
A framework for ensuring compliance with
MARPOL
The following guidance has been prepared by the International Chamber
of Shipping (ICS) and the International Shipping Federation (ISF)
as a template for the review of company compliance programmes
adopted in accordance with existing regulatory requirements, such as
the International Maritime Organization (IMO) International Safety
Management (ISM) Code. This framework is also supported by BIMCO,
Intercargo, Intertanko, OCIMF and SIGTTO. The following is relevant
to preventing all forms of pollution but can be read in conjunction with
the Shipping Industry Guidance on the Use of Oily Water Separators (see
www.marisec.org/ows).
The shipping industry is committed to a process of continuous
improvement of the design and operation of ships to ensure that they
have no harmful impact on the environment.
Introduction
The International Convention for the Prevention of Pollution from Ships
(MARPOL) has been in place for many years and applies worldwide.
Despite this, however, MARPOL requirements have not always been
followed uniformly and instances of deliberate discharges in violation
of MARPOL are still being detected by government authorities. While
the lack of adequate waste reception facilities and the inefciency of
equipment may be of relevance, they can never justify agrant breaches of
international regulations.
Prosecuting authorities, particularly in the United States, have identied
the absence within some companies of a systematic approach to identifying
and managing compliance with environmental requirements as a common
failure, directly leading to shipboard non-compliance. Leadership
commitment and a clearly delineated path of accountability to the top of
the company have often been found lacking.
Notwithstanding current compliance mechanisms in use by maritime
companies, it is advisable for companies to review their practices
and take additional steps to ensure compliance with environmental
protection obligations. Fortunately, detailed information about prudent
environmental management is readily available. The International
Organization for Standardization (ISO) has developed the ISO 14000
series of environmental management system standards to satisfy global
environmental needs.
In seeking to change the working practice of those companies found
to be in violation of environmental rules, authorities have frequently
required adherence to compliance programmes overseen by the courts.
Guidance
Management responsibility
Technical equipment
Environmental equipment should
be considered as critical and should
therefore be assessed for proper
functioning and efciency in
normal at-sea operating conditions.
Any failure should be reported to
the environmental compliance
manager, along with details of the
corrective actions taken and the
timetable to effect repairs.
If any equipment does not operate
effectively, the company should
replace the equipment or augment
the existing system.
The adequacy of the storage
capacity for waste on board the
ship should be assessed against its
operations. If necessary, additional
capacity should be added to allow
for storage and subsequent proper
shore disposal.
The company should have a
maintenance and replacement
programme for environmental
compliance equipment that
specically requires periodic
sampling and testing of waste
discharges.
Control devices
Companies should take steps to
prevent deliberate non-compliance.
This may involve installing
monitoring equipment, using seals
on overboard discharge lines, tting
unique tags on anges, or tting
interlocks to prevent falsication of
monitoring records.
Documentation
A sound system of documentary
management, including records
required for statutory purposes and
records kept in accordance with
company policy, should be capable
of demonstrating a full, complete
and accurate record of all matters
pertaining to environmental
compliance on board each ship and
by shore staff.
The documentary management
system should support crosschecking of data, and be capable
of detecting any falsication of
records.
Managers and executives should
periodically conduct internal
reviews of the document
management system in addition to
the formal audit process.
Companies should be encouraged to
use electronic transfer and storage
of documents to take advantage of
the smooth ow of communication
and accountability that these
methods support.
Internal reporting
The basic requirement is for a
system of written or electronic
records, documentation and
standard reporting procedures
using the ships organisational
structure.
In addition to the ISM noncompliance reporting system,
the company should have an
anonymous reporting mechanism
that encourages any employee to
report a suspected violation to
the environmental compliance
External reporting
Non-compliance with MARPOL
regulations should be reported to
the vessels ag administration.
In the event of the discovery of
evidence of intentional discharges
of waste, the ag administration
must be notied immediately and a
request for an investigation should
be initiated.
Notice to port state authorities
should also be required for
discharges within port state
jurisdictional waters.
Audits
The aim of an audit is to verify
environmental compliance
throughout the company.
It is strongly recommended that
senior management establish
an environmental auditing
policy requiring universal and
unannounced audits to be
conducted at least annually.
www.marisec.org/
environmental-compliance
Also supported by
BIMCO
Society of International
Gas Tanker and
Terminal Operators