Errors in Oil Record Book Part I Entries

OIL RECORD BOOK PART I

Refer to MEPC 1-Circ 736 always.

Ship Inspectors (FSC / PSC / Vetting) frequently mention in their Reports improper maintenance of the Oil Record Book (ORB) to Masters and Chief Engineers and about the importance of correctly maintaining the ORB during their visits on board entered vessels.

Sludge can be easily calculated
As a rough guide, approximately 1% (one percent) of fuel shipped, ends up as sludge. This would include all HFO (Heavy Fuel Oil), MDO (Marine Diesel Oil) and LO (Lubricating Oil).

The inspecting authorities SIMPLY wish to be able to see clearly that the total oil shipped plus the oil already on board, less the main engine consumption for that voyage equals the total oil remaining on board (ROB) plus the sludge ROB.

( ROB + bunkered fuel ) - M.E. cons. = ROB + sludge

It is simple arithmetic to add up the amount that should be on board compared with the amount 'said to be' disposed. If the figures are not as required and the Inspecting Authority have to hunt for the figures and try to figure out the totals - this gets them suspicious.
In this case you are guilty until you can prove your innocence.

Also sometimes Class may not properly annotate the IOPP certificate and Supplement 'B' to include the incinerator and/ or the capacity of the OWS. Thus the ship may be incinerating the oil but according to the IOPP certificate there is no incinerator on board and although you may protest your innocence the Inspecting
Authority assumes you have pumped it overboard.

And there is a fine to help concentrate the mind and get the paperwork right next time. !!

ORB entries
Correct entries must be made as per the MEPC 1-Circ 736

Sludge retention
Entries under C 11.1 sludge retention and the entries required at the end of a voyage (or weekly if the vessel is on short sea trade) are frequently overlooked and do not include the total ROB sludge. Simply on arrival at any port, if the vessel has been on a passage for more than seven (7) days, then a detailed entry of ALL sludge ROB on a tank by tank basis is required. Vessels on short sea trade or coasting vessel make a weekly entry.

C11.4 entry, in effect from 01st January 2011:

Please refer to the notes in the example #2 in MEPC 1-Circ 736 (available on the net) as here below:

Note: Operator initiated manual collection where oil residue (sludge) is transferred (transfer with a pump) into the oil residue (sludge) tank(s). Examples of such operations could be:

1. Collection of oil residue (sludge) from fuel oil separator drain tanks.

2. Collection of oil residue (sludge) by draining engine sump tanks.

3. Adding fuel oil to an oil residue (sludge) tank (all content of a sludge tank is considered sludge).

4. Collection of sludge from bilge water holding tanks – in this case a disposal entry for bilge water is also needed.

So long as CE or his representative has not initiated a manual draining, it need not be written. 

Code C 11.4 is required to be used for recording of oil residue (sludge) collected by manual operation in oil residue (sludge) tank. Sludge should be collected and stored only in tanks listed under item 3.1 in the Supplement to the IOPPC.

Code C 11.4 is not required for recording Weekly inventory of sludge.

However, in case of automatic draining of sludge from seperator / purifiers, it is prudent to make such an entry in a MARPOL record book seperately or put an entry for C11.4 stating - Automatic draining from seperator, as a good faith entry, whenever there is an increase.

This is for two reasons:-
1. It is required by MARPOL and the Oil Record book - Section C11
2. If any pollution was to occur during the vessels stay in that particular port you have written proof of what the ship had on board in terms of sludge - tank by tank. A quick sounding of these tanks by the Authorities will prove that you are not the culprit. If the entries are not made then again you are guilty until you can prove your innocence. This will mean getting the P&I correspondent involved, Surveyors to attend, litigation / verifications and of course in the end totally unnecessary costs incurred by the Shipowner.

Incineration of oily rags should be noted in garbage record book and not in oil record book. 

C12.3 is only for incineration of Sludge.

Disposal of Water
Entries under D 15.2 disposal overboard of water in sludge frequently do not contain the time of stopping or the TWO geographical positions required (i.e. at Start and Stopping of the Oily Water separator (OWS)) or an inaccurate estimate of the amount disposed of overboard - e.g. the OWS has been on line for about two hours, has a capacity of 2 cu. m and during this period 10 cu. m have been pumped overboard according to the Chief engineer's entry in the book. Simple arithmetic again !! 

Careful attention to entries and knowledge of the pumps and capacities will easily avoid this.

Bunkering
Entries under H 26 (All Fuels including DO and Lub Oils) frequently do not give the required information requested by the Oil Record Book. Read the instructions !!

Refer to Example 18 of MEPC.1 Circ 736. Specification of fuel and sulphur must be included properly.

Simple - study the front cover or the instructions that come with the ORB or alternatively read the MARPOL Regulations - a copy must should be carried on board. (STCW 1995)
Keep the receipts
Certificate records of sludge pumped to shore facilities or barges are sometimes not retained with the ORB, are lost or not available

- they should be filed within the ORB - stapled or at the back or a clearly noted record made in the book as to where they are maintained.

Keep it neat - keep it clean
Provided the ORB's are neat and properly record the information there is generally no problem, but if the records have NOT been entered as required, or it looks like a spider has crawled across the page the result could easily be a fine. Use plenty of space for the entries do not try to cram every entry into one line and always leave space between entries.

Look for the Entries (Code I) related to corrections of earlier entries / additional entries / voluntary informations in the circular MEPC 1-Circ 736.

Read before you sign !!
Masters must be aware that as they sign the bottom of each page they are attesting to the accuracy and correctness of the entries.
The rule is always read carefully before you sign ANYTHING !!

Secure the Book and relevant attached documents!!
Most of the Chief Engineers, Masters and Chief Officers do not realize the importance, but it is better to have the Oil / Cargo / Garbage record books, receipts etc in safe custody of the in-charge. You do not want to face a situation of lost book.

AVOID PUTTING YOURSELF IN PROBLEMS, AVOID FACING CRIMINALIZATION.