Statutory Alert: Revised MARPOL requirements for oil residue (sludge) piping arrangements Applicability: All shipowners and managers
The IMO has adopted amendments to Regulation 12 of MARPOL Annex I (see Resolution MEPC.266(68)), which will enter into force on 1 January, 2017.
The amendments mean that oil residue (sludge) tanks must have no discharge connections to the bilge system, oily bilge water holding tank(s), tank top or oily water separators.
The only exceptions to this are as follows:
Tanks may be fitted with drains (with manually operated self-closing valves and arrangements for subsequent visual monitoring of the settled water) that lead to an oily bilge water holding tank or bilge well or they may be fitted with an alternative arrangement, provided that this arrangement does not connect directly to the bilge piping system.
The sludge tank discharge piping and bilge-water piping may be connected to a common discharge connection provided it does not allow for the transfer of sludge to the bilge system.
These requirements apply to all new and existing vessels 400 gt and above (previously, they did not apply to vessels delivered before 1 January 2014*). All ships 400 gt and above, constructed before 1 January 2017 must be arranged to comply with the requirements no later than the first renewal survey carried out on or after 1 January 2017.
It is anticipated that the biggest impact will be on existing vessels with keels laid before 31 December 1990, which may have connections between the bilge and sludge systems. Connections between designated sludge pumps and the oily water separator are not uncommon and will need to be removed.
Some examples of compliant and non-compliant arrangements are shown here
* See IMO Unified Interpretation 17 to MARPOL Annex I, Regulation 12.2.2 and also MEPC.1/Circ.753/Rev.1. Ship delivered before 1 January, 2014, means a ship:
1. for which the building contract is placed before 1 January, 2011; or
2. in the absence of a building contract, the keel of which is laid or which is at a similar stage of construction before 1 January, 2012; or
3. the delivery of which is before 1 January, 2014.