By MarEx 2015-10-11 15:29:39
Oily water separators that are compliant with MEPC 107(49) regulations are sufficient technology for their purpose, conclude the authors of the final report from MAX1 Studies, a six-month study commissioned by the National Fish & Wildlife Foundation and managed by the maritime consultancy firm Martin & Ottaway.
The study examined two questions:
1. How effective are shipboard oily water separators (OWS)?
2. What can be done to further increase the effectiveness of shipboard oily waste management?
Historically, improvements to these systems have been hampered by a lack of open communication and technical cooperation. Therefore, this effort particularly focused on cooperative evaluation and analysis, especially through identifying and engaging stakeholders to consolidate possible divergent points of view.
The study found that the majority of complaints with OWS technology involve problems generally associated with OWS designed to comply with MEPC 60(33). As ships constructed after 2005 must be fitted with units that comply with MEPC 107(49), MEPC 60(33) units are no longer manufactured.
Therefore, the authors conclude that improving OWS technology should not be a regulatory priority, since MEPC 60(33) units will eventually be overtaken by improved MEPC 107(49) units without any additional intervention.
With regard to making continual improvements to MEPC 107(49) equipment, the authors suggest that the best method to address remaining issues is not to amend regulations to make a particular technology required, but rather to incentivize manufacturers to continue to improve OWS technology.
To assist manufacturers with making OWS improvements, shipowners and crews must also work to improve the customer feedback loop, which continues to show insufficient reporting of issues back to the manufacturer.
Remaining issues include the time-intensive nature of OWS cleaning/maintenance and false negatives/positives with oil content meter (OCM) equipment. Specifically, technical advances in OCM oil detection accuracy would find a ready market in the industry. False OCM alarms can become a serious operational issue, since possible false alarms make OWS systems difficult to troubleshoot, which results in ineffective crew efforts at resolving the alarm.
Crews should be trained to recognize this reality and to stop using an OWS that does not respond properly, issue a service report, and request that it be resolved at the next port, states the report. The study indicates that port state control officials would welcome this type of report and operational feedback.
A number of reported issues with MEPC 107(49) units can also be improved through adequate crew training and ensuring that an appropriate OWS system is selected for its intended operational environment. For a shipowner, these types of systems considerations will likely provide the greatest improvements to MEPC 107(49) OWS operations, states the report.
“We emphasize that there is no indication that further regulatory efforts at improving OWS technology are required. In fact, any regulatory change would most likely be counterproductive, since it would be destabilizing, requiring many years for implementation and creating confusion and possibly new myths,” state the report authors.
The report offers the following pathways to increase the effectiveness of shipboard oily waste management, which were reached through review of existing literature, extensive consultation with stakeholders, and technical and systems analysis:
• Increasing and improving crew training (in OWS operations and MARPOL regulations)
• Addressing availability and cost issues with port reception facilities
• Moving towards drier bilges
• Increasing and improving crew dialogue with shore management (making crews feel comfortable as part of the solution)
• Exploring options for electronic record keeping
• Cultivating a “culture” of compliance/trust/communication/transparency
For the most part, these suggestions are best applied through reliable, data-driven, transparent implementation by shipowners in consultation with relevant stakeholders such as regulatory bodies, shore personnel and ships crews, within the existing regulatory structure.
The study found that some shipowners are already solving these problems effectively, reducing stress on the system for all stakeholders. “Today’s regulations are resulting in increasingly drier bilges and improved OWS capability, reducing discharge of oil to water by total volume. With improved compliance this trend of reduced total discharge will only accelerate.”
The report is available here.