Ships Environmental Management

By the end of this module you will be able to: On completion the learner can explain how an international pollution-prevention instrument becomes a specific task on their own watch, identify which instrument governs a given waste stream, and state the personal and corporate consequences of failing to comply. This module is grounded in: • MARPOL 73/78 Annexes I to VI, and the concept of Special Areas and Emission Control Areas • SOLAS 1974 Chapter IX and the ISM Code, in particular elements 5, 7, 8, 10 and 12 • Resolution A.982(24) — Revised guidelines for the identification and designation of Particularly Sensitive Sea Areas • Flag State law, and coastal or port State law where it exceeds MARPOL

MARPOL is not a single rulebook. It is six technical Annexes, each with its own definitions, discharge criteria, equipment requirements, certificate and record book. A seafarer who cannot say which Annex governs the substance in front of them cannot know which rule applies to it, and will default to habit. What you must be able to do: • Name each of the six Annexes and the waste stream it governs • Given a substance — bilge water, galley waste, refrigerant, cooking oil, sewage, exhaust gas — state the governing Annex without hesitation • State which certificate corresponds to which Annex: IOPP to Annex I, ISPP to Annex IV, IAPP and EIAPP to Annex VI • State which record book corresponds to which Annex: Oil Record Book to Annex I, Garbage Record Book to Annex V, Ozone-Depleting Substances Record Book and fuel changeover records to Annex VI How this is proven in practice: • Correctly sorts a set of twelve waste-stream cards into Annexes in under two minutes • Locates the correct certificate in the ship's certificate file when named a waste stream Common failure modes seen on board — learn from these: • Treating cooking oil as food waste. It is not — it is a prohibited discharge under Annex V • Assuming grey water is covered by Annex IV. It is not covered by MARPOL at all, which is precisely why it catches ships out in the United States and Turkey • Assuming that because the ship has an incinerator, anything can go in it

MARPOL binds States, not seafarers. It reaches the seafarer through four translations: the flag State enacts it, the port State enforces it on arrival, the company writes it into the safety management system, and the officer performs it. Each translation can add requirements but never subtract them. What you must be able to do: • Explain why a company procedure may be stricter than MARPOL and must still be followed • Explain why a port State requirement may be stricter than both, and takes effect the moment the ship enters those waters • Identify where in the ship's documented system to find the procedure for a given operation • Recognise that a charterer's instruction is contractual, not statutory, and can never authorise a breach of MARPOL How this is proven in practice: • Traces one requirement — for example the retention period for a bunker delivery note — from the Annex, through the flag circular, to the shipboard procedure and the physical file • Correctly states who to consult when a charterer's instruction and a statutory requirement conflict Common failure modes seen on board — learn from these: • 'The company procedure says so' offered as the only justification, with no understanding of the underlying rule — this collapses under questioning by an inspector • Believing a charterer's approval provides legal cover for a discharge • Assuming the flag State position applies in a foreign port

These three designations are frequently confused. A Special Area is a MARPOL discharge regime. An Emission Control Area is a MARPOL Annex VI air-emission regime. A Particularly Sensitive Sea Area is a designation carrying associated protective measures such as routeing or reporting. Each changes what the ship may do, and each has a boundary that must appear on the passage plan. What you must be able to do: • List the MARPOL Annex I Special Areas and state the discharge effect within them • Identify the Emission Control Areas in force and the fuel sulphur limit within them • Explain that inside an Annex I Special Area, discharge from machinery spaces is prohibited for ships of 400 GT and above • Identify boundaries on the passage plan and confirm the ship's readiness before entry, not on arrival How this is proven in practice: • Marks Special Area and Emission Control Area boundaries on a sample passage plan and states the actions required before each boundary • States the Southern South African waters Special Area status and its practical effect on a coastal voyage Common failure modes seen on board — learn from these: • Discovering the boundary on the chart at the moment of crossing, with no changeover completed and no tank capacity planned • Confusing a Particularly Sensitive Sea Area with a Special Area and assuming a discharge is permitted • Treating the coastline as the baseline where a declared baseline applies

Environmental prosecutions are unusual in that they routinely reach individuals. In several jurisdictions the offence that produces the prison sentence is not the discharge but the false record and the obstruction that follows it. Learners must understand that signing a record they know to be untrue is a separate and more serious act than the discharge itself. What you must be able to do: • Explain that an officer may be personally prosecuted, fined, imprisoned and have their certificate of competency endorsed or withdrawn • Explain that a false entry in a statutory record book presented to an inspector is commonly charged as a distinct offence • Explain the commercial consequences: detention, off-hire, loss of charter, loss of Voluntary Environmental Compliance Program standing, insurance implications • Explain that pressure from any source is not a defence, and describe the routes available for raising concern How this is proven in practice: • Explains, in their own words, why 'I was told to' offers no protection • Correctly identifies at least three routes for raising a concern, including at least one outside the shipboard line of command Common failure modes seen on board — learn from these: • Believing seniority transfers liability upward — it does not remove liability from the person who signed • Believing that a discharge in international waters is beyond reach — the record book travels with the ship into the next port • Silence, on the assumption that someone senior has already dealt with it

In an inspection, the inability to find a document is treated as the absence of the document. Every learner must be able to physically produce the ship's environmental documents within a few minutes. What you must be able to do: • Locate the IOPP Certificate and its Supplement, the ISPP, IAPP and EIAPP Certificates, and check their validity dates • Locate the shipboard oil pollution emergency plan, garbage management plan, ballast water management plan, biofouling management plan and energy efficiency plan • Locate the manuals for the oily water separator, incinerator, sewage plant and refrigeration plant, and the NOx Technical File • Explain what the IOPP Supplement lists and why the physical plant must match it How this is proven in practice: • Produces any six named documents within five minutes • Compares the tank list in the IOPP Supplement against the ship's actual tank arrangement and identifies any discrepancy Common failure modes seen on board — learn from these: • A bilge primary tank fitted on board but absent from the IOPP Supplement — a common and consequential finding • Expired type-approval certificates for pollution-prevention equipment • Manuals stored in a locked office to which the duty engineer has no key

By the end of this module you will be able to: On completion the learner can carry out a structured external and internal environmental condition inspection of the hull, machinery space and deck, identify evidence of leakage or discharge, and record findings so they lead to corrective action rather than sitting in a notebook. This module is grounded in: • MARPOL Annex I regulations 12, 15 and 34 • Resolution MEPC.378(80) — 2023 Guidelines for the control and management of ships' biofouling • AFS Convention 2001, including the cybutryne restriction and the IAFS Certificate • Coating Technical File requirements under the Performance Standard for Protective Coatings

Streaking below an overboard opening is the single most visible external evidence of an unlawful or accidental discharge. Inspectors look at the hull before they board. So should the ship's own staff. What you must be able to do: • Identify every overboard opening on the ship's side by name and function, working from the shell expansion and piping diagrams • Distinguish oil staining from rust streaking, marine growth and normal coating wear • Inspect the eductor and cargo hold bilge eductor discharge openings specifically, which are commonly overlooked • Photograph, locate and report a stain with enough precision that another person can find it How this is proven in practice: • Produces a marked-up profile drawing identifying all overboard openings • Correctly classifies staining in a set of ten photographs Common failure modes seen on board — learn from these: • Painting over the stain before establishing its cause — this destroys evidence and, if discovered, is treated as concealment • Reporting 'some staining on the ship's side' with no location, no photograph and no date • Inspecting only the accommodation side because it is the side alongside

A clean bilge is not cosmetic. It is the primary evidence that leaks are being found and fixed rather than accumulated and discharged. Persistent oil in a bilge well means a leak that has not been traced. What you must be able to do: • Inspect all bilge wells, tank tops and the areas beneath machinery for oil accumulation • Trace an accumulation back to its source rather than simply pumping it away • Identify and report leaking glands, flanges, drains and gauge connections • Assess the condition of lagging for oil contamination, which is both a pollution and a fire risk How this is proven in practice: • Completes a bilge inspection record identifying condition, any accumulation and the traced source • Raises a defect report against a specific item of equipment rather than a general observation Common failure modes seen on board — learn from these: • Cleaning the bilge before an inspection without recording that it was done or why • Oil-soaked lagging left in place because replacing it is a shipyard job • Recording 'bilges clean' as a standing entry that is copied week after week

An overflow through an air vent is a pollution incident in waiting and often the first physical sign of a bunkering or transfer discipline problem. What you must be able to do: • Inspect vent heads and flame arrester screens for oil traces and for blockage • Confirm self-closing sounding cocks operate and are not gagged open • Confirm sounding pipes are accessible in the loaded condition • Confirm save-alls and drip trays are empty, drained to the correct destination and not plugged How this is proven in practice: • Demonstrates operation of a self-closing sounding cock and explains why gagging it is prohibited • Identifies the correct drainage destination for each save-all on the ship Common failure modes seen on board — learn from these: • Sounding cocks wired or wedged open for convenience during bunkering • Save-all drains led to the bilge rather than to a sludge or drain tank • Flame arrester screens blocked, which risks tank over- or under-pressure as well as overflow

Biofouling is both an invasive species pathway and a fuel-consumption issue, and it now sits inside a formal IMO guidance framework. Anti-fouling systems are separately regulated by the AFS Convention. What you must be able to do: • Explain the purpose of the biofouling management plan and record book and what entries they require • Explain the purpose of the Coating Technical File and that in-service maintenance and partial recoating are recorded in it • Explain that the anti-fouling system is certified under the AFS Convention and that certain substances are prohibited • Relate fouling condition to fuel consumption and therefore to carbon intensity performance How this is proven in practice: • Makes a correct entry in a specimen biofouling record book following an in-water inspection • Locates the Coating Technical File and the IAFS Certificate on board Common failure modes seen on board — learn from these: • A biofouling management plan present but never used, with an empty record book • In-water cleaning carried out in a port that prohibits it, or without capture of the removed material • Coating Technical File not updated after a drydock recoating

By the end of this module you will be able to: On completion the learner can manage the bilge water stream from source to lawful disposal, keep it separate from the sludge and clean-drain streams, prevent contamination that defeats the oil content meter, and record every movement correctly. This module is grounded in: • MARPOL Annex I regulations 12, 14, 15, 17 and 34 • Resolution MEPC.107(49) — Revised guidelines and specifications for pollution prevention equipment for machinery space bilges • MEPC.1/Circ.642 as amended — Revised guidelines for systems for handling oily wastes in machinery spaces, incorporating guidance notes for an Integrated Bilge Water Treatment System • MEPC.1/Circ.640 — voluntary declaration of quantities retained in bilge water holding tanks

A learner who cannot trace the system on the actual pipework cannot judge whether a connection is legitimate. Diagram literacy and physical tracing are different skills and both are required. What you must be able to do: • Locate the bilge piping diagram and confirm it is the current class-approved version • Trace bilge wells, the bilge primary tank if fitted, the bilge holding tank, the transfer pump, the separator, the oil content meter, the three-way valve and the overboard line • Identify every cross-connection: cargo hold bilges to engine room bilges, engine room bilges to the fire line, emergency bilge suction on main sea water pumps, bow thruster bilge eductor • State the purpose of the vacuum-break loop and why it must not be blanked How this is proven in practice: • Walks the system with an assessor, naming each component and its function • Marks up a blank piping diagram and identifies all sealed valves Common failure modes seen on board — learn from these: • Relying on an out-of-date diagram that does not reflect a later modification • Being unable to say where the emergency bilge suction discharges to • Not knowing which valves on the system are required to be sealed

The oil content meter measures optically. Solids such as soot and mud, and emulsifying chemicals, produce readings that do not correspond to oil content — either false alarms that tempt the crew to work around the equipment, or false low readings that mask genuine oil. The integrity of the whole system depends on what is allowed into it. What you must be able to do: • Identify the chemicals in use in the machinery space that are harmful to the environment or that interfere with separation, using the safety data sheets and the separator manual • Explain how emulsifiers defeat gravity separation and why degreasers must never be used in bilge wells • Identify activities that introduce solids — soot blowing residues, boiler and economiser washing, tank cleaning, grit blasting — and state the controls for each • Explain the function of a bilge primary tank in settling solids before treatment How this is proven in practice: • Produces a list of machinery space chemicals classified as acceptable or prohibited near the bilge system, referenced to safety data sheets • Explains the control applied to one specific activity, for example economiser washing Common failure modes seen on board — learn from these: • Using a general-purpose degreaser to clean a bilge well, then wondering why the separator will not run • Landing boiler wash water into the bilge holding tank with no separate arrangement • Treating repeated false alarms as an equipment fault rather than a contamination symptom

Retention capacity is what makes lawful behaviour possible. A ship that has run out of tank capacity has removed its own ability to comply, and every subsequent decision is made under pressure. What you must be able to do: • Sound and record the bilge holding tank on the required routine and reconcile against the Oil Record Book • Inspect and clean the tank on the maintenance routine and record the inspection and cleaning dates • Plan capacity against the passage: know how long the ship can hold before disposal becomes necessary • Explain the recording position for the primary bilge tank, including cleaning dates and any evaporation How this is proven in practice: • Produces a capacity plan for a stated passage showing generation rate, available capacity and the disposal decision point • Shows tank inspection and cleaning records consistent with the maintenance system Common failure modes seen on board — learn from these: • Discovering the tank is full while inside a Special Area • No record of the last internal inspection or cleaning • Soundings recorded in a private notebook rather than the controlled record

Clean drain tanks — collecting air cooler condensate, economiser and air-conditioning drains — are a lawful separate route to sea. They are also a well-known bypass opportunity, so they attract scrutiny. The ship must be able to prove the line is traced, listed and monitored. What you must be able to do: • Physically trace the clean drain lines and confirm they are not connected to the bilge system or the separator • Confirm the clean drain tanks are listed in the IOPP Supplement • State the verification method used before discharge, and where it is recorded • State the action if a clean drain tank becomes contaminated: it ceases to be clean, is routed to the bilge holding tank, and the event is recorded How this is proven in practice: • Traces the line and cross-references it to the IOPP Supplement entry • Describes the alternative disposal route via the separator if contamination occurs Common failure modes seen on board — learn from these: • A clean drain tank in use but not listed in the IOPP Supplement • No stated verification method — 'it's clean water' offered as the answer • A contaminated clean drain tank discharged anyway because there is no alternative route planned

This is the decision the whole module exists to support. It is a sequence of conditions, all of which must hold, and it ends in a record. What you must be able to do: • State every condition in MARPOL Annex I regulation 15 for discharge outside a Special Area • State the position inside a Special Area for ships of 400 GT and above • Apply the decision ladder in Figure 4 to a given set of circumstances and reach the correct answer • Make the correct Oil Record Book entry immediately after the operation How this is proven in practice: • Reaches the correct decision on eight of eight scenario cards, with no critical error • Writes a correct and complete Oil Record Book entry for a permitted discharge Common failure modes seen on board — learn from these: • Treating 'below 15 ppm' as the only condition and forgetting en route, Special Area and equipment status • Discharging at anchor or while drifting • Making the record at the end of the watch, or the end of the week, rather than immediately

By the end of this module you will be able to: On completion the learner can operate the 15 ppm separating equipment and oil content meter correctly, test and prove the automatic stopping arrangement, maintain the equipment to the required standard, and recognise the physical signatures of tampering. This module is grounded in: • MARPOL Annex I regulations 14, 15 and 34 • Resolution MEPC.107(49), including the requirement for the oil content meter to be calibrated at intervals not exceeding five years • MEPC.1/Circ.642 as amended • SOLAS Chapter II-1 bilge pumping arrangements

Most separator failures are operational, not mechanical: wrong start-up sequence, flooding not completed, feed rate too high, air not vented. An operator who follows the sequence gets clean water; one who improvises gets alarms and then feels pressure to work around them. What you must be able to do: • State the correct start-up sequence including flooding, venting and the establishment of flow • Operate within the rated throughput and explain why exceeding it defeats separation • Recognise the normal running signature — pressures, temperatures, sight glass appearance — and detect deviation • Shut down correctly, including flushing where the maker requires it • Explain why the equipment is operated in daylight during manned engine room hours How this is proven in practice: • Performs a complete start-up, run and shutdown under observation, following the posted instructions • Explains the consequence of each step being omitted Common failure modes seen on board — learn from these: • Starting on a partly flooded chamber, producing an immediate alarm • Running at a rate above the rated capacity to clear a tank before arrival • Operating at night with the engine room unmanned, which is exactly the pattern investigators look for

The automatic three-way valve is the last line of defence. A test that only confirms the alarm sounds is not a test of the stopping device. The learner must prove the valve actually moves and the flow actually diverts. What you must be able to do: • Carry out the zero and calibration check to the maker's procedure and record it • Test the oil detection probe and prove automatic and manual drainage of oil from the chamber • Prove the three-way valve operation, the bilge pump trip where fitted, and the vacuum-break loop function • Retrieve the operating log from the oil content meter and interpret it • Confirm the meter's date and time correspond to the ship's reference time so that logs can be reconciled How this is proven in practice: • Completes a full functional test under observation and records it correctly • Downloads and interprets a meter log, identifying periods of operation and any alarms Common failure modes seen on board — learn from these: • Testing the alarm but never proving the valve moves • A meter clock hours or days out, making log reconciliation impossible and creating suspicion where none is warranted • Calibration overdue — the five-yearly calibration is commonly aligned with IOPP renewal and commonly forgotten

Maintenance evidence is what proves the equipment is genuinely in service rather than nominally fitted. A separator that has never consumed a coalescer element has probably never done any work. What you must be able to do: • Carry out internal inspection of the first and second stage chambers when opportunity permits, and record the condition • Renew coalescer elements at the required interval and record the renewal • Maintain the essential spares holding, stored, labelled and inventoried separately • Relate spare parts consumption to running hours and recognise when the two do not agree How this is proven in practice: • Shows maintenance records, spares inventory and consumption history that are mutually consistent • Explains what a coalescer element looks like at renewal and why Common failure modes seen on board — learn from these: • No coalescer renewal recorded across several years of claimed operation • Essential spares mixed into general stores and untraceable • An unusual spares order — for example a sudden three-way valve replacement — with no corresponding defect record

This outcome is deliberately taught to operators and not only to auditors. Ratings and junior engineers are usually the first to see a bypass being rigged, and they need to recognise it and know what to do. What you must be able to do: • Identify freshly removed, cleaned or painted pipework in way of the separator, pumps and overboard line, and know to ask why • Inspect the first section of piping upstream of the overboard valve for oil residue • Distinguish graphite deposit from oil residue by the simple beaker test — graphite sinks in clean water, oil floats and forms a sheen • Identify unauthorised flanges, hose connections and portable pump arrangements • Explain the reporting route, including routes outside the immediate line of command How this is proven in practice: • Correctly classifies residue samples in a bench test • Identifies three tampering indicators from a photograph set and states the action for each Common failure modes seen on board — learn from these: • Assuming black residue in the overboard pipe is always oil, producing a false allegation • Seeing a rigged hose and saying nothing • Recording a concern in a personal notebook rather than through a formal route

Equipment fails. The compliance outcome depends entirely on what happens next. A ship that reports promptly and obtains an exemption is in a different position from one that keeps quiet and improvises. What you must be able to do: • Record the failure in the Oil Record Book under the correct code, with the time, the reason and the time of restoration • Notify the Chief Engineer and Master, and through them the company, flag State and class • Explain the flag State exemption process and why it is applied for before the situation becomes critical • Plan retention and shore disposal for the period of unavailability How this is proven in practice: • Writes a correct record entry for an equipment failure and restoration • Produces a notification and contingency plan for a stated failure scenario Common failure modes seen on board — learn from these: • No record of the failure at all, leaving an unexplained gap in operations • Waiting until the tanks are nearly full before telling anyone • Attempting a repair that constitutes an unapproved modification

By the end of this module you will be able to: On completion the learner can manage oil residue from generation to lawful disposal, maintain the absolute separation between the sludge and bilge systems, plan capacity so that the ship never runs out of options, and evidence every disposal. This module is grounded in: • MARPOL Annex I regulations 12, 13 and 17, as amended by resolution MEPC.187(59) • MEPC.1/Circ.642 as amended • Port reception facility requirements under MARPOL Annex I regulation 38

Sludge arrives from many places: separator and purifier discharge, sump and tank drains, filter cleaning, cargo of drain trays. If any of these routes to the bilge instead of the sludge tank, the ship has created a compliance problem at the source. What you must be able to do: • List every sludge source on the ship and its destination tank • Confirm that all oily mixture drainage from tanks and cleaning activities is led to a sludge tank • Explain that once fuel oil is added to a sludge tank, the entire contents are treated as sludge • Identify the tanks listed in the IOPP Supplement and confirm the physical arrangement matches How this is proven in practice: • Produces a sludge source and destination map for the ship • Cross-references it against the IOPP Supplement Common failure modes seen on board — learn from these: • Purifier drains led to a bilge well 'because it is closer' • Adding fuel to a sludge tank to improve incinerator burning without appreciating the recording consequence • Tanks in use that do not appear in the Supplement

This is the hardest boundary in Annex I and the one that attracts criminal investigation when it is crossed. The regulation is explicit: sludge tanks have no discharge connections to the bilge system, the oily bilge water holding tank, the tank top or the separator. The only common point is disposal to a reception facility. What you must be able to do: • State the requirement in regulation 12 as amended and explain what it prohibits • Physically verify that no such connection exists, including blanks, spool pieces and change-over valves • Verify sludge transfer arrangements between sludge tanks, and confirm they do not create a path to the bilge • Identify and challenge any temporary arrangement, hose or portable pump that could create a path How this is proven in practice: • Completes a verification walk-round with the assessor, checking every potential connection point • Correctly identifies a deliberately introduced illegitimate connection in a mock-up Common failure modes seen on board — learn from these: • A change-over valve that permits incinerator settling tank drainage to the bilge holding tank, unblanked • A blank fitted but not secured, or with the bolts stored beside it • Assuming that because a valve is normally shut, the connection is acceptable — the regulation prohibits the connection, not merely its use

Sludge generation is predictable. Roughly, it is a percentage of fuel consumed, and it varies with fuel quality and purifier performance. A ship that tracks this can plan disposal. A ship that does not will eventually have a full tank and no port. What you must be able to do: • Calculate expected sludge generation from bunker consumption and compare it to actual generation • Recognise when actual generation departs from expectation and investigate why • Plan disposal against the voyage, allowing for notice periods, charterer approvals and port availability • State and apply the contingency plan when the tank approaches capacity, including early escalation to the company How this is proven in practice: • Produces a sludge budget for a stated voyage and identifies the disposal decision point • Explains what an unexpectedly low generation figure might indicate Common failure modes seen on board — learn from these: • Generation figures that are suspiciously low and unexplained — a recognised indicator that sludge is leaving the ship by an unlawful route • Requesting shore reception with insufficient notice, then facing a full tank • Treating evaporation as an unlimited capacity solution

Shore disposal is the primary route. The receipt is the ship's proof, and it must be capable of standing on its own years later. What you must be able to do: • Prepare for and carry out a sludge discharge to a barge or truck, including connection, sampling and quantity measurement • Obtain a receipt showing quantity, type, date, time and the receiver's identity • Retain the receipt for three years and file it so it can be produced against the corresponding record entry • Explain the standard discharge connection requirement and its dimensions How this is proven in practice: • Completes a disposal checklist and produces a compliant receipt • Matches a supplied set of receipts to record book entries and identifies the mismatch Common failure modes seen on board — learn from these: • A receipt showing only 'sludge' with no quantity • Quantity on the receipt inconsistent with the tank soundings before and after • Receipts filed loose and lost before the three years expire

Water is decanted or evaporated from sludge to make it burnable. Both are legitimate. Both change the tank contents and both must be recorded, because an unrecorded reduction in tank volume looks exactly like an unlawful discharge. What you must be able to do: • Explain the purpose of decanting and evaporation and the correct method for each • State where the water removed goes and record its destination • Make the correct record entry for evaporation and for decanting • Explain why an unexplained fall in sludge tank soundings is treated as an adverse finding How this is proven in practice: • Writes correct record entries for a decanting and an evaporation operation • Explains the volumetric consequence and how it will appear in the sounding book Common failure modes seen on board — learn from these: • Evaporation carried out routinely but never recorded, so the tank appears to empty itself • Decanted water led to the bilge with no entry • Relying on evaporation as the primary disposal strategy

By the end of this module you will be able to: On completion the learner can operate and maintain a shipboard incinerator safely and within its design limits, determine what may and may not be incinerated, manage ash lawfully, and record the operation in the correct record book. This module is grounded in: • MARPOL Annex VI regulation 16 — shipboard incineration • Resolution MEPC.244(66) — 2014 Standard specification for shipboard incinerators • MARPOL Annex I regulation 17 and Annex V recording requirements • SOLAS Chapter II-2 fire safety provisions

The incinerator is not a general waste disposal device. Annex VI regulation 16 prohibits the incineration of specified substances, and burning the wrong material produces emissions the unit was never designed to handle and residues that are then themselves a problem. What you must be able to do: • List the substances whose shipboard incineration is prohibited under Annex VI regulation 16 • State that cargo residues covered by Annexes I, II and III, and contaminated packing materials, must not be incinerated • State the position on polychlorinated biphenyls, on refuse containing more than traces of heavy metals, and on refined petroleum products containing halogen compounds • State the position on polyvinyl chlorides where the unit is not type-approved for them • State the position on exhaust gas cleaning system residues How this is proven in practice: • Correctly sorts a set of waste cards into may-incinerate and must-not-incinerate • Locates the incinerator type-approval certificate and states what it permits Common failure modes seen on board — learn from these: • Burning oily rags and plastics together because they are both 'waste' • Burning cargo-related residues to avoid a reception facility charge • Assuming that if it fits in the charging door it may be burnt

Incinerator ratings are established with a specified test material. Modern waste burns hotter and faster, so operators routinely exceed the design rate without realising it. Overfiring destroys refractory, distorts the casing and produces smoke that will be noticed from ashore. What you must be able to do: • State the design burning rate and the water decanting volume from the ship's documentation • Calculate the actual burning rate achieved and compare it to the design rate • Test flame failure, interlocks, safety cut-outs and forced draught fan operation and record the results • Operate on diesel oil as a minimum where sludge temperature does not permit waste oil firing • Explain the daylight and manned-hours operating rule and any port or regional restriction How this is proven in practice: • Produces a burning rate calculation from actual operating data • Completes a safety function test under observation Common failure modes seen on board — learn from these: • Charging to clear a backlog before arrival and exceeding the design rate • Operating with a flame failure device known to be unreliable • Operating in port where the port prohibits it

Refractory condition determines whether the unit reaches and holds combustion temperature. Cracked or spalled refractory means incomplete combustion, smoke, and eventually casing damage. What you must be able to do: • Carry out external examination for gas or smoke leakage and confirm casing insulation condition • Inspect the firebox for refractory cracking, spalling and signs of overheating, and record the condition with photographs • Inspect main burner, pilot burner and igniter for condition and operation • Inspect the waste oil tank: drains clear, heating coil, level gauge, thermometer, stirrer, and the last internal cleaning date • Confirm warning and instruction plates are legible and that the manufacturer, model, serial number and capacity are permanently marked How this is proven in practice: • Completes an inspection record with photographs and a clear condition statement • Correctly grades refractory condition against reference photographs Common failure modes seen on board — learn from these: • Recording 'refractory satisfactory' with no photograph, then reporting a crack at the next inspection with no history • Waste oil tank stirrer inoperative, so water is never properly distributed and burning is erratic • Illegible instruction plates, a common and easily fixed finding

Ash is not simply waste. Incinerator ash is a prohibited discharge under Annex V, and ash from plastics or from products containing heavy metals requires particular care. It must be segregated, stored and landed. What you must be able to do: • State that incinerator ash may not be discharged to sea • Segregate and store ash separately, in suitable closed containers • Record ash landings in the Garbage Record Book with quantity and receipt • Explain the additional care required for ash from products containing heavy metals How this is proven in practice: • Shows compliant ash storage arrangements • Makes a correct Garbage Record Book entry for an ash landing Common failure modes seen on board — learn from these: • Ash swept over the side in the belief that it is inert • Ash mixed with general garbage, defeating segregation • No receipt obtained for an ash landing

The split confuses people constantly. Sludge incineration is an Oil Record Book operation. Garbage incineration is a Garbage Record Book operation. Oily rags and cooking oil go in the Garbage Record Book. Getting this wrong produces an apparent gap in one book and an apparent surplus in the other. What you must be able to do: • Record sludge incineration in the Oil Record Book under the correct code • Record garbage, oily rag and cooking oil incineration in the Garbage Record Book • Record non-operation of the incinerator in the Oil Record Book where the ship's procedure requires it • Maintain the running hours record and reconcile it against both record books How this is proven in practice: • Correctly allocates ten incineration events between the two record books • Reconciles a running hours log against supplied record book entries and identifies the discrepancy Common failure modes seen on board — learn from these: • Sludge incineration recorded in the Garbage Record Book • Running hours that do not correspond to any recorded operation • Long periods of non-operation with no explanation, followed by an implausible burst of activity before arrival

By the end of this module you will be able to: On completion the learner can make timely, accurate and complete entries in the Oil Record Book Part I using the correct codes, correct an error properly, and — at verifier level — cross-check a record set against soundings, meter logs, receipts and capacities to detect inconsistency or falsification. This module is grounded in: • MARPOL Annex I regulation 17 and Appendix III • Resolution MEPC.187(59) — amendments introducing the current definitions and entry codes • MEPC.1/Circ.736/Rev.2 — Guidance for the recording of operations in the Oil Record Book Part I • MEPC.1/Circ.640 — voluntary declaration of quantities retained in bilge water holding tanks

The codes are not decorative. An operation recorded under the wrong code is, in evidential terms, an operation not recorded. Codes C to I cover the machinery space operations of all ships. What you must be able to do: • State what each of codes C, D, E, F, G, H and I covers • Select the correct code and item number for a given operation without reference to notes • Record quantities, times, positions and tank identities in the required form • Explain when an operation requires entries under more than one code — for example collecting sludge from a bilge water holding tank How this is proven in practice: • Codes fifteen operations correctly with no more than one error and no critical error • Explains the two-entry requirement for a sludge collection from a bilge tank Common failure modes seen on board — learn from these: • Using code I as a catch-all for anything difficult • Recording a bilge discharge under C rather than D or E • Recording quantities without stating the tank

Almost every defensive quality of the record book comes from the timing and the signatures. An entry written at the time by the person who did the work carries weight. One written up later, in a different hand, does not. What you must be able to do: • Make the entry without delay on completion of the operation • Sign as officer in charge of the operation • Ensure each completed page is signed by the Master • Ensure the Chief Engineer countersigns operations as required by the ship's procedure • Explain the three-year retention requirement and where the book is kept How this is proven in practice: • Writes a complete entry for an observed operation within the same watch • Identifies missing signatures in a supplied specimen page Common failure modes seen on board — learn from these: • A week of entries written up in one sitting in identical handwriting and ink • Master's page signature missing on several pages • The book kept in the Chief Engineer's cabin and unavailable to the duty engineer

Errors happen. How they are corrected is what an inspector reads. A single struck line, corrected, initialled and dated is normal and unremarkable. An erasure, an overwrite or correction fluid is treated as evidence of concealment. What you must be able to do: • Strike through the erroneous entry with a single line so it remains legible • Write the correction, then initial and date it with rank • Never erase, overwrite, use correction fluid or remove a page • Apply the same discipline to the tank sounding record How this is proven in practice: • Correctly executes three corrections on a specimen page under observation • Identifies improper corrections in a supplied specimen Common failure modes seen on board — learn from these: • Overwriting a digit so that the original is unreadable • Correction fluid — which in practice is read as an admission • A page torn out, however innocent the reason

The record book does not exist in isolation. It must agree with tank soundings, oil content meter logs, disposal receipts, running hours and rated capacities. Inspectors reconcile these. So must the ship, before the inspector arrives. What you must be able to do: • Reconcile record entries against the tank sounding record and identify differences • Reconcile against the oil content meter operating log, allowing for clock differences • Reconcile recorded processing and incineration rates against rated capacities and identify impossibilities • Reconcile disposal quantities against receipts • Correct or explain any discrepancy in writing at the time it is found How this is proven in practice: • Reconciles a supplied three-month record set and identifies all planted discrepancies • Writes an explanation for a genuine discrepancy in a form that would satisfy an inspector Common failure modes seen on board — learn from these: • Soundings kept in an uncontrolled notebook that does not match the official record • Recorded processing volumes that exceed the separator's rated capacity for the hours claimed • Discrepancies noticed but left unexplained

Verifiers must be able to look at a record set and see the shape of a problem. This is taught explicitly so that Masters and Chief Engineers find issues on their own ships before someone else does. What you must be able to do: • Recognise repetitive or identical entries for operations that in reality vary • Recognise round-number quantities appearing consistently where measurement would produce variation • Recognise entries that are chronologically impossible given the ship's movements or the equipment's capacity • Recognise handwriting, ink and pressure discontinuities indicating retrospective completion • Take the correct action on discovering an anomaly, including preserving the record and escalating outside the ship where required How this is proven in practice: • Identifies at least five of six planted falsification indicators in a specimen set • Writes a correct escalation note that preserves evidence and does not accuse Common failure modes seen on board — learn from these: • Confronting the individual before securing the record • Correcting the record retrospectively to 'tidy it up', which converts a finding into an offence • Deciding it is a company matter and not reporting it

By the end of this module you will be able to: On completion the learner can operate and maintain a sewage treatment plant, apply the discharge criteria correctly including the untreated discharge rate calculation, and identify where regional rules are stricter than MARPOL. This module is grounded in: • MARPOL Annex IV regulations 9, 11 and 12 • Resolution MEPC.227(64) as amended by MEPC.284(70) — effluent standards and performance tests for sewage treatment plants • Resolution MEPC.157(55) — standards for the rate of discharge of untreated sewage • Regional and national requirements exceeding Annex IV

Three routes exist: an approved treatment plant, comminuted and disinfected sewage beyond 3 nautical miles, or untreated sewage beyond 12 nautical miles at a controlled rate. Each carries conditions and the ship must know which route it is using. What you must be able to do: • State the distance, speed and rate conditions for each of the three routes • State that the ship must be en route at not less than 4 knots for the distance-based routes • Explain that treated effluent from an approved plant may be discharged at any distance subject to the plant meeting its standard • Explain that discharge from a holding tank must still respect the rate limit How this is proven in practice: • Reaches the correct decision on six scenario cards with no critical error • States the conditions from memory Common failure modes seen on board — learn from these: • Emptying a holding tank at maximum pump rate once past 12 miles • Discharging while drifting or at anchor • Assuming a plant that is fitted is necessarily working and approved

This is a formula every officer on a ship without a treatment plant is expected to be able to produce on demand. It is asked at inspections precisely because it separates those who understand the requirement from those who have memorised a distance. What you must be able to do: • State the formula from resolution MEPC.157(55): DR = 0.00926 × V × D × B • Identify each term and its unit: discharge rate in cubic metres per hour, speed in knots, draught in metres, moulded breadth in metres • Calculate the permitted rate for the ship's own particulars at a stated speed and draught • Compare the calculated rate to the actual pump capacity and state the operational consequence How this is proven in practice: • Calculates the rate correctly for three sets of particulars • States whether the ship's discharge pump could exceed the permitted rate and what control is applied Common failure modes seen on board — learn from these: • Using beam instead of moulded breadth, or displacement instead of draught • Calculating the rate but never comparing it to the pump's actual output • Not knowing the formula exists

A biological plant is a living system. It fails slowly and invisibly when it is neglected, and by the time the effluent is visibly wrong the biology has been dead for weeks. What you must be able to do: • Confirm air supply, air pressure, reducing valve and gauge condition, and aeration device operation • Carry out chemical dosing to the maker's regime and explain the purpose of each product • Carry out the residual chlorine test to the maker's procedure and record the result • Check discharge pump condition, leakage, vibration and automatic cut-in and cut-out • Explain what must never be put into the system: solvents, chemicals, oil, excessive paper, sanitary items How this is proven in practice: • Performs a residual chlorine test and records it • Explains the purpose of each dosing chemical in the ship's regime Common failure modes seen on board — learn from these: • Aeration blower belt slipping for months, killing the biology • Cleaning chemicals dumped into a toilet, sterilising the plant • Residual chlorine testing chemicals expired or absent

Certification and arrangement details are where inspections concentrate, because they can be verified from a chair. What you must be able to do: • Locate the type approval certificate and the ISPP Certificate and check validity • Confirm the permanent plate affixed to the plant, which some administrations specifically look for • Confirm holding tank capacity is adequate for the ship's port stays and calculate the holding time available • Confirm whether hospital and dispensary drainage is connected to the sewage system and explain why it matters • Confirm the overboard valve is sealed and logged How this is proven in practice: • Produces certificates and states expiry dates • Calculates available holding time from tank capacity and complement Common failure modes seen on board — learn from these: • ISPP Certificate expired and unnoticed • Holding capacity adequate for a short call but not for the ship's actual port stays • Hospital drainage arrangement unknown to the duty engineer

Annex IV is a floor. Several important trading areas impose no-discharge regimes, and the definition of nearest land changes where declared baselines apply. What you must be able to do: • Identify no-discharge zones and stricter regimes on the intended voyage • Explain the Great Barrier Reef and Bohai Bay baseline position • Explain the position in United States waters and in Turkish waters • Build the requirement into the passage plan and check capacity against it How this is proven in practice: • Annotates a passage plan with sewage discharge restrictions and identifies the capacity implication • States where to obtain current regional requirements Common failure modes seen on board — learn from these: • Discovering a no-discharge zone on arrival with a full holding tank • Measuring from the visible coast where a baseline applies • Relying on out-of-date guidance

By the end of this module you will be able to: On completion the learner can explain why grey water is a compliance risk despite not being regulated by MARPOL, manage the holding and discharge arrangements, and identify the jurisdictions where it is controlled. This module is grounded in: • Grey water is not regulated as a discharge under MARPOL • United States Vessel General Permit and the emerging Vessel Incidental Discharge Act regime • Turkish, Egyptian and other national requirements • Class environmental notations, where the ship carries one

Because MARPOL does not regulate it, crews assume it is unregulated everywhere. It is not. The United States, Turkey and several other jurisdictions control it, and class environmental notations impose requirements independently. The absence of a MARPOL rule is exactly what makes it dangerous. What you must be able to do: • State that grey water is not a MARPOL-regulated discharge • Identify grey water sources: galley, laundry, showers, wash basins, deck drains where they lead to the grey water system • Identify the jurisdictions and regimes that do control it on the ship's trading pattern • Explain the effect of a class environmental notation on grey water handling and recording How this is proven in practice: • Lists the ship's grey water sources and the tanks serving them • Identifies the controlling requirement for two named ports on the trading pattern Common failure modes seen on board — learn from these: • 'It's just washing water' as the operative belief • Discharging in a United States port in the belief that MARPOL silence means permission • Not knowing whether the ship carries an environmental notation

Grey water is generated continuously and in volume. Where machinery spaces are not under the accommodation there may be more than one tank. Capacity planning is the whole game. What you must be able to do: • Identify all grey water holding tanks and their capacities • Calculate holding time from generation rate and complement • Check discharge pump condition, leakage and vibration • Confirm the overboard valve is sealed and the seal number logged How this is proven in practice: • Calculates available holding time and compares it to the longest planned port stay • Confirms the seal against the log Common failure modes seen on board — learn from these: • Only one tank identified where the ship has two • Holding time calculated on paper but never checked against an actual port stay • Overboard valve unsealed because 'grey water isn't regulated'

Where grey water is regulated, the requirements often concern what is in it — phosphates in detergents, oil and grease from the galley, food solids. Source control is cheaper and more reliable than treatment. What you must be able to do: • Explain the phosphate-free soap expectation where it applies, and the availability of product information • Explain galley grease trap maintenance and why it matters to grey water quality • Explain that cooking oil must never enter the grey water system • Brief catering and accommodation staff on source control How this is proven in practice: • Reviews the ship's cleaning product inventory against the requirement • Inspects and reports on grease trap condition Common failure modes seen on board — learn from these: • Grease trap never cleaned, so galley waste passes straight through • Cleaning products purchased on price with no attention to specification • Catering staff never briefed

By the end of this module you will be able to: On completion the learner can classify, segregate, store, dispose of and record every category of shipboard garbage in accordance with Annex V, and apply the stricter requirements applying in special areas and sensitive sea areas. This module is grounded in: • MARPOL Annex V regulations 3, 4, 5, 6, 7, 9 and 10 • Resolution MEPC.295(71) — 2017 Guidelines for the implementation of MARPOL Annex V • Resolution A.982(24) — Particularly Sensitive Sea Areas • Garbage Management Plan and Garbage Record Book requirements

Segregation happens at the bin, by whoever is holding the waste. If it is wrong there, nothing downstream can fix it. This is why the awareness tier exists. What you must be able to do: • Name the Annex V garbage categories and give examples of each • Segregate correctly at the point of generation using the ship's colour coding and marking • Identify materials that are commonly misclassified: cooking oil, e-waste, oily rags, medical waste, aerosols, batteries • Explain why mixed garbage must be treated according to its most restrictive component How this is proven in practice: • Sorts twenty items correctly into the ship's bin arrangement • Explains the treatment of a mixed bag containing plastic and food waste Common failure modes seen on board — learn from these: • Cooking oil put with food waste • Plastic-lined paper cups treated as paper • Bins unmarked or marked in a language part of the crew does not read

The matrix in Figure 8 is the core knowledge. It is also the part learners most often half-remember, which is worse than not remembering at all. What you must be able to do: • State the discharge position for each category outside special areas, inside special areas, and in the Antarctic and Arctic • State the food waste comminution requirement and the 25 millimetre screen • Explain the meaning of en route in this context • Identify the special areas and sensitive sea areas on the ship's trading pattern and their specific restrictions How this is proven in practice: • Completes a blank version of the Figure 8 matrix with no critical error • Applies the matrix correctly to eight scenario cards Common failure modes seen on board — learn from these: • Discharging comminuted food waste at 5 nautical miles inside a special area • Treating the Great Barrier Reef as ordinary coastal water • Discharging while manoeuvring or at anchor and calling it en route

Storage is where inspections concentrate because it is visible from the deck. Poor storage also produces the pressure that leads to unlawful discharge. What you must be able to do: • Maintain the garbage station: marked, colour-coded, metal drums with metal lids, secured • Confirm garbage locker ventilation operates where fitted • Assess whether locker capacity is adequate for the trading pattern and matches the capacity stated in the Garbage Management Plan • Maintain segregation in remote locations, including the engine room workshop • Manage the specific requirements for narcotics, medical waste and expired medicines, including disposal receipts How this is proven in practice: • Completes a garbage station inspection against a checklist • Compares actual locker capacity to the capacity stated in the plan Common failure modes seen on board — learn from these: • Plastic drums with no lids in an open deck garbage station • Locker capacity in the plan that bears no relation to the actual locker • No receipts for controlled disposals

The two books overlap at incineration, and the overlap is where errors cluster. Oily rags and cooking oil are Annex V. Sludge is Annex I. Both may go through the same incinerator on the same day. What you must be able to do: • Make correct Garbage Record Book entries for discharge, incineration and landing, with category, quantity and position • Obtain and retain disposal receipts • Reconcile incineration entries between the Garbage Record Book and the Oil Record Book • Explain the retention requirement and who signs How this is proven in practice: • Makes six correct entries covering discharge, incineration and landing • Identifies the misallocated entries in a supplied paired record set Common failure modes seen on board — learn from these: • Incineration of oily rags recorded in the Oil Record Book • Quantities estimated with no method and no consistency • Landing entries without receipts

The plan is a required document that must reflect the actual ship. Placards must be posted where the decision is made, not on an office noticeboard. What you must be able to do: • Confirm the plan reflects the ship's actual arrangements, capacities and procedures • Confirm placards are correctly posted, legible and in the working languages of the crew • Maintain the garbage training record and confirm it is current • Explain the designation of the person responsible for carrying out the plan How this is proven in practice: • Audits the plan against the ship and lists discrepancies • Confirms placard placement and legibility throughout the ship Common failure modes seen on board — learn from these: • A plan describing a bin arrangement the ship no longer uses • Placards only in English on a multinational crew • Training record last updated two crew changes ago

By the end of this module you will be able to: On completion the learner can identify the refrigerants on board and manage them under the ODS regime, state the NOx Tier applicable to each engine and prove it, maintain the NOx Technical File and the Record Book of Engine Parameters, and operate correctly within a NOx Tier III area. This module is grounded in: • MARPOL Annex VI regulation 12 — ozone-depleting substances, and the ODS Record Book • MARPOL Annex VI regulation 13 — nitrogen oxides, Tiers I, II and III • NOx Technical Code 2008, including the Record Book of Engine Parameters and survey methods • Resolution MEPC.291(71) and the annual spot-check provisions for selective catalytic reduction • Resolution MEPC.392(82) — Canadian Arctic and Norwegian Sea Emission Control Areas

The question is not whether the ship has a refrigeration plant. It is whether every charge on board, including the ones nobody thinks about, has been identified. Water coolers, control room air conditioning units, deck reefer containers and portable units all contain a charge. What you must be able to do: • Produce a complete inventory of every refrigerant charge on board, including small and portable units • Identify which refrigerants are ozone-depleting substances and which are not • Confirm any ODS on board is listed in the appendix to the IAPP Certificate • Explain that deliberate emission of ODS is prohibited and that leakage must be minimised How this is proven in practice: • Produces the ship's complete refrigerant inventory with the type and approximate charge of each unit • Correctly classifies a list of refrigerant designations as ODS or non-ODS Common failure modes seen on board — learn from these: • An inventory that covers the provision plant and air conditioning but omits deck containers and water coolers • An ODS charge on board that is not listed on the IAPP Certificate appendix • Assuming that because the main plant uses a modern refrigerant, no ODS exists anywhere on the ship

Refrigerant loss is normally slow and invisible. A regime that detects loss early protects both the environment and the plant. Records must show that the regime is actually running, not merely written down. What you must be able to do: • Carry out and record routine leak testing and detector checks • Record refrigerant top-up quantities and relate them to the charge of the unit • Maintain the refrigeration log required by the ship's class notation, where one is carried • Recognise that a rising top-up rate is a leak that has not been found How this is proven in practice: • Completes a leak test record and interprets a twelve-month top-up history • Identifies from a supplied history the unit that is losing charge Common failure modes seen on board — learn from these: • Top-ups recorded as a running total with no unit identified • Leak detector unserviceable for months with no defect raised • Log entries made monthly in identical figures, which cannot be real

When ODS or equipment containing it leaves the ship, it must go to a reception facility and it must be recorded. Ships that have made such a discharge keep an ODS Record Book permanently on board. What you must be able to do: • State the requirement for an ODS Record Book where ODS has been discharged to a land-based reception facility • Record removal, recharging and landing with quantities and receiver details • Obtain and retain the reception receipt • Explain that the record is maintained permanently on board How this is proven in practice: • Makes a correct ODS Record Book entry for a landing operation • Produces a compliant receipt specification Common failure modes seen on board — learn from these: • Equipment landed at a repair yard with no record and no receipt • No ODS Record Book on a ship that has made such a landing • Recovered refrigerant vented because recovery equipment was unavailable

Tier is determined by the engine's construction date and the ship's operating area. Every engineer should be able to answer, without hesitation, what Tier each engine is and how that is proved. What you must be able to do: • State the Tier of the main engine and each auxiliary engine and the basis for it • Locate the EIAPP Certificate and Statement of Compliance for each engine • Locate the approved NOx Technical File and explain what it contains • Explain the survey method used for each engine as set out in its Technical File How this is proven in practice: • Produces the EIAPP Certificate and Technical File for a named engine and states its Tier • Explains the applicable survey method in outline Common failure modes seen on board — learn from these: • Not knowing the Tier of the auxiliary engines, only the main engine • A photocopy of the Technical File on board where the original approved copy is required • The Technical File not updated after component renewal

A NOx-critical component is identified by its IMO number. Fitting an uncertified part, or fitting a certified part without recording it, breaks the chain of compliance even though the engine may run perfectly. What you must be able to do: • Identify NOx-critical components — commonly fuel valve spindles and guides, nozzles, and pump plunger and barrel assemblies • Verify on receipt that the component's IMO identification matches the Technical File listing • Record every substitution in the Record Book of Engine Parameters, with specification, date and supplier • Photograph the IMO number of the component fitted and attach it to the maintenance record as permanent evidence • For electronically controlled engines, verify the engine control system survey record, including hardware identification numbers and software checksums How this is proven in practice: • Makes a correct Record Book of Engine Parameters entry for a component renewal • Verifies a supplied component certificate against a Technical File extract Common failure modes seen on board — learn from these: • A component fitted with no record, discovered at IAPP renewal • No Record Book of Engine Parameters started at all — a common finding on ships where nobody has been told it is expected • Photographs of IMO numbers duplicated between work orders, which destroys their evidential value

Tier III applies to specified engines in specified areas. Where the ship relies on exhaust gas recirculation or selective catalytic reduction, entry and exit must be recorded and the system must be proved to be working. What you must be able to do: • Identify the NOx Tier III areas on the intended voyage • Record area entry and exit correctly in the required log • Maintain the exhaust gas recirculation record book where fitted • Carry out and record the annual spot check for a selective catalytic reduction system and verify the reduction rate against the Technical File • State the recent additions to the Emission Control Area map and their applicability dates How this is proven in practice: • Annotates a passage plan with Tier III boundaries and states the records required at each • Interprets a supplied spot-check result against a Technical File value Common failure modes seen on board — learn from these: • Entry and exit times recorded in the deck log but not in the required record • Reduction rate never verified, so the system's continuing effectiveness is unproven • Assuming the Emission Control Area map is static — the Canadian Arctic and Norwegian Sea entered into force on 1 March 2026, with the fuel requirement following on 1 March 2027

By the end of this module you will be able to: On completion the learner can plan and execute a compliant fuel changeover, conduct a bunkering operation with correct sampling and documentation, manage fuel segregation and compatibility, and produce the complete evidence set on demand. This module is grounded in: • MARPOL Annex VI regulations 14 and 18, including the 0.50 per cent global limit and the 0.10 per cent Emission Control Area limit • The carriage ban on non-compliant fuel oil where no approved equivalent arrangement is fitted • Bunker Delivery Note and MARPOL sample requirements, including retention periods • Resolution MEPC.392(82) and the current Emission Control Area designations

Two numbers, several boundaries, and a map that changes. The 0.50 per cent global limit and the 0.10 per cent Emission Control Area limit are stable; the list of areas is not. What you must be able to do: • State the global limit and the Emission Control Area limit • Name the Emission Control Areas currently in force and any applicability dates still running • Explain the carriage ban and its exception for ships with an approved exhaust gas cleaning system • Identify additional regional limits, such as those applying at berth in certain jurisdictions • State where current information is obtained and how often it is checked How this is proven in practice: • Lists the Emission Control Areas on the ship's trading pattern with the applicable limit and date • Explains the carriage ban in their own words Common failure modes seen on board — learn from these: • Working from a map printed several years ago • Believing the carriage ban does not apply because the fuel is 'only in a storage tank' • Overlooking a regional at-berth requirement stricter than MARPOL

Changeover is where the compliance requirement and the engineering risk meet. Done too late, the ship is non-compliant. Done too fast, the fuel pumps seize and the ship blacks out. Both outcomes are avoidable by calculation. What you must be able to do: • Calculate changeover time from system volume, flow rate and the ship's flushing characteristics • Work backwards from the boundary to determine the start time • Control viscosity and temperature ramp rates to avoid thermal shock • Confirm completion before the boundary and record tank, quantity, position, date and time • State the responsibilities, back-up arrangements and record-keeping in the written changeover procedure How this is proven in practice: • Produces a changeover plan for a stated boundary crossing, with times • Completes a changeover record correctly Common failure modes seen on board — learn from these: • Starting the changeover on sighting the boundary • Ramping temperature fast to save time, and losing a fuel pump • A changeover record showing completion but no start time, so the duration cannot be assessed

Bunkering produces the evidence the ship will be judged on for the next year. The sample and the delivery note are the entire defence if a fuel dispute or a compliance question arises. What you must be able to do: • Follow the bunkering procedure including pre-transfer checks, communications and the safety plan • Take samples correctly using the statutory sampling kit, at the correct point, throughout the delivery • Seal, label and sign samples jointly with the supplier, and distribute the sample set correctly • Retain the MARPOL sample on board for not less than twelve months, or until the fuel is consumed, under the ship's control • Retain the Bunker Delivery Note for three years • Issue a Letter of Protest at the time, signed by the supplier where possible, when the delivery note is incomplete or the fuel is off specification, and notify the company and the stemming party immediately How this is proven in practice: • Completes a bunkering document set including a sample label and a Letter of Protest • States the retention period for each document without prompting Common failure modes seen on board — learn from these: • Samples drawn at the start of the delivery only, which does not represent the parcel • A Letter of Protest written days later, when its evidential weight has largely gone • MARPOL samples stored in an unsecured locker where their integrity cannot be assured

Mixing incompatible residual fuels precipitates asphaltenes. The result is not a slow degradation but a rapid blocking of filters and purifiers, often within hours, and frequently at the worst possible moment. What you must be able to do: • Explain asphaltene precipitation and why incompatible fuels cannot simply be blended • State the safeguards where very low sulphur, high sulphur and distillate fuels share a manifold line • Explain the consequence of mixing distillate with residual fuel • Plan tank allocation so that segregation is maintained through the voyage How this is proven in practice: • Produces a tank allocation plan for a stated bunkering that maintains segregation • Explains the line flushing and blanking arrangements used on the ship Common failure modes seen on board — learn from these: • Topping up a part-full tank with a different parcel to save a tank • No line flushing between grades on a single manifold line • Assuming that because both parcels meet the sulphur limit they are compatible

Flow meters, soundings and reported figures must agree. Where they do not, the ship must know why before someone else asks. What you must be able to do: • Confirm flow meter arrangements for main engine, auxiliaries and boiler, and confirm they are working and calibrated • Confirm flow meters are correctable for changes in fuel data • Apply temperature and density corrections to sounding-based quantities • Reconcile soundings, flow meter readings, the Oil Record Book and figures reported to charterers • Explain why no unofficial or rough sounding notebook may be kept How this is proven in practice: • Completes a reconciliation of a supplied data set and identifies the discrepancy • Applies a temperature and density correction correctly Common failure modes seen on board — learn from these: • Uncorrected soundings recorded as final figures • A private notebook of 'real' figures alongside the official record — this converts a discrepancy into evidence of deliberate misstatement • Boiler consumption unmetered and estimated by habit

A scrubber is an equivalent arrangement, and it carries its own monitoring, recording and discharge obligations. Where it is not working, the ship is not compliant, however good the fuel logistics. What you must be able to do: • State that the system is approved as an equivalent to compliant fuel and must meet its approved monitoring manual • Confirm sensor calibration for pH, polycyclic aromatic hydrocarbons, turbidity and continuous emissions monitoring, as required by the approved manual • Confirm emissions and discharge data are retained for not less than eighteen months, including through any device change • Maintain the record book covering malfunction, maintenance, daily records during sensor failure, alkali consumption for closed-loop operation, and wash water and sludge shore discharge with receipts • Confirm the discharge water analysis is current and valid • Confirm the system is operating in the correct mode for the area How this is proven in practice: • Audits a supplied scrubber record set and identifies gaps • States the data retention period and the position when a monitoring device is replaced Common failure modes seen on board — learn from these: • Data retained on a device that was replaced, with the historical record lost • Operating outside the approved mode inside an Emission Control Area • Wash water residue landed with no receipt

By the end of this module you will be able to: On completion the learner can operate the environmental seal regime end to end, maintain the environmental documentation set, verify certification validity, and produce a complete and consistent evidence package on demand. This module is grounded in: • MARPOL Annexes I, IV, V and VI certification requirements • ISM Code elements 10 and 11 — maintenance and documentation • Company environmental seal control procedure • Voluntary Environmental Compliance Program style requirements, where the ship operates under one

The seal list is ship-specific and must be complete. A valve that could put a regulated substance into the sea and is not on the list is a gap that will be found. What you must be able to do: • Identify from the ship's arrangements every overboard valve and connection requiring a seal: separator overboard, sludge discharge port and starboard, sewage overboard, grey water overboard, bunker manifold valves, bilge cross-connections, emergency bilge suction, bow thruster bilge eductor, tank connection and fuel preparation room bilge overboards • Identify additional sealing points required by charterers or by a voluntary compliance programme • Confirm the pollution response locker is sealed and its inventory list displayed, signed and dated • Explain the purpose of a warning notice at a sealed valve How this is proven in practice: • Produces a complete seal register for the ship, cross-referenced to the piping diagrams • Identifies a valve omitted from a supplied incomplete register Common failure modes seen on board — learn from these: • Bow thruster compartment eductor overboard omitted because it is outside the machinery space • Charterer-required seals treated as optional • Response locker sealed but the inventory list unsigned

The seal is only evidence if the log is contemporaneous and the seals are controlled stock. Loose seals in a drawer make the entire regime worthless. What you must be able to do: • Control seal stock so that seals are issued only by the Master or Chief Engineer • Record seal number, location, date fitted and the fitting officer's signature • Carry out physical verification by sighting each seal and comparing the number to the log, initialling the check • Explain why reading the log without sighting the seal is not verification How this is proven in practice: • Carries out a verification round and correctly identifies the seal whose number does not match the log • Explains the stock control arrangement in force on the ship Common failure modes seen on board — learn from these: • Seals stored where any crew member can take one • Verification recorded as complete in less time than the round physically takes • Seal numbers recorded in blocks in advance

Seals are meant to be broken — for lawful operations. What matters is that the authority, the reason and the timing are recorded before the seal is cut, and that a new seal follows immediately. What you must be able to do: • Obtain and record the Master's or Chief Engineer's authority before breaking a seal • Record the reason, time and authority in the seal log • Fit and log a new numbered seal immediately after the operation • Where the operation was a discharge, record the new seal number in the Oil Record Book as well • State what to do if a seal is found broken with no record How this is proven in practice: • Executes a complete break, operate, re-seal and record sequence under observation • States the escalation route for an unexplained broken seal Common failure modes seen on board — learn from these: • Seal broken first, authority sought afterwards • New seal fitted days later • An unexplained broken seal quietly replaced, which is far worse than reporting it

The document set is the ship's account of itself. It must be complete, current, filed so it can be produced, and consistent with the physical ship. What you must be able to do: • Verify validity and endorsement status of the IOPP and its Supplement, ISPP, IAPP, EIAPP and any additional certificates • Confirm the physical arrangements match the IOPP Supplement, including tank listings • Maintain the required manuals and plans in an accessible location known to the Master and Chief Engineer • Maintain the environmental file structure: pipe leakage and breakage records, pollution prevention equipment training records, incinerator running hours, refrigeration log, sewage and grey water records, stern tube monitoring records • Confirm the hazardous materials inventory documentation is in order and understand the current ship recycling regime • Confirm posted operating instructions and regulatory placards are present, legible and correctly located How this is proven in practice: • Completes a documentation audit against a structured list and produces a finding list • Identifies a supplement and physical arrangement mismatch Common failure modes seen on board — learn from these: • A tank in use that does not appear in the IOPP Supplement • Placards posted in the ship's office rather than at the point of decision • Manuals present but nobody able to find them within the time an inspector will wait

The portable pump and the flexible hose are the physical means by which almost every bypass is created. Controlling them is therefore a direct control on the offence. What you must be able to do: • Maintain an inventory of flexible hoses at or above the specified size and of portable pumps • Tag each item and store them in a controlled location with the inventory displayed • Verify the inventory physically at the required interval • Challenge any hose or pump found rigged and establish its purpose How this is proven in practice: • Verifies a supplied inventory against a physical store and identifies the item that is missing and the one that is not listed • States the action on finding a hose rigged between a sludge tank drain and a deck scupper Common failure modes seen on board — learn from these: • An inventory that has not been verified physically for months • Hoses stored loose around the machinery space • A rigged hose observed and rationalised rather than challenged

By the end of this module you will be able to: On completion the learner can operate the ballast water management system in compliance with the D-2 standard, maintain the ballast water record, manage biofouling under the current guidelines, and meet national requirements on invasive species. This module is grounded in: • Ballast Water Management Convention 2004, regulations D-1 and D-2, and the Ballast Water Record Book • Ballast Water Management Plan and the type-approved treatment system's operational manual • Resolution MEPC.378(80) — 2023 biofouling guidelines • AFS Convention 2001 • National requirements, including regional inspection regimes for invasive pests

Treatment systems fail quietly and often. The record must show what was actually done, including bypasses and failures, because a clean record with a broken system is worse than an honest one. What you must be able to do: • Operate the system in accordance with its type-approval and operational manual • Record every ballasting, deballasting, treatment, internal transfer and exchange in the Ballast Water Record Book • Record system failure, bypass and any contingency measure, with times and reasons • Explain the D-1 exchange and D-2 performance standards and which applies to the ship • Complete the mandatory onboard familiarisation and training for the fitted system and record it How this is proven in practice: • Makes correct record entries for a ballasting operation and a system failure • Demonstrates or describes the system start-up and treatment sequence Common failure modes seen on board — learn from these: • Bypass used but not recorded, leaving an untreated discharge unexplained • Training on the specific fitted system never carried out, only generic ballast training • Record entries made from the ballast plan rather than from what actually happened

Ballast rules are heavily national. Ports impose reporting, sampling, timing and exchange requirements that go beyond the Convention, and several require advance notification. What you must be able to do: • Identify national and port requirements on the intended voyage, including reporting formats and notice periods • Plan uptake and discharge to avoid prohibited areas, shallow water and sediment disturbance • Explain sediment management and the requirements for tank sediment removal and disposal • Prepare for a port State sampling inspection How this is proven in practice: • Produces a ballast plan for a voyage that includes a port with additional requirements • Lists the notifications required and their deadlines Common failure modes seen on board — learn from these: • Discovering a reporting requirement on arrival • Ballast uptake in shallow or turbid water immediately before a discharge port • Sediment disposal arrangements never considered

Biofouling management moved from good practice to a structured guideline framework with resolution MEPC.378(80), and several jurisdictions now inspect against it. It is also a direct fuel consumption and carbon intensity issue. What you must be able to do: • Explain the purpose and content of the biofouling management plan and record book • Record inspections, in-water cleaning, drydock cleaning and coating renewal • Explain the concept of niche areas and why they dominate the risk: sea chests, thruster tunnels, rudder stock, propeller boss, internal seawater cooling systems • Explain the requirements applying to in-water cleaning, including capture of removed material and jurisdictions where it is prohibited • Relate fouling to fuel consumption and carbon intensity performance How this is proven in practice: • Makes a correct biofouling record book entry following an inspection • Identifies the niche areas on a supplied ship arrangement Common failure modes seen on board — learn from these: • Plan and record book present but never used • In-water cleaning carried out where it is prohibited, or without capture • Fouling treated as a hull maintenance matter unconnected to compliance or fuel

The anti-fouling system is separately certified, and certain jurisdictions run seasonal inspection regimes for invasive insect pests that can result in a ship being turned away. What you must be able to do: • Locate the anti-fouling system certificate and declaration and explain what they cover • Explain that certain anti-fouling substances are prohibited and what that means at recoating • Describe the inspection and certification regime for invasive insect pests in the relevant regions, including the ports and seasons where it applies • Carry out and record a self-inspection for egg masses in the required locations How this is proven in practice: • Produces the anti-fouling certification for the ship • Carries out a structured self-inspection following the published guidance and records it Common failure modes seen on board — learn from these: • Anti-fouling certification not updated after recoating • Self-inspection carried out only on accessible deck areas, missing the high and shadowed locations where egg masses are actually laid • Using an obsolete name for the pest regime and therefore searching the wrong guidance

By the end of this module you will be able to: On completion the learner can manage the environmental requirements specific to dual-fuel vessels, explain and support the ship's energy efficiency and carbon intensity obligations, and maintain the hazardous materials inventory in accordance with the current ship recycling regime. This module is grounded in: • IGF Code and dual-fuel vessel operational requirements • MARPOL Annex VI Chapter 4 — energy efficiency, including the Energy Efficiency Existing Ship Index, the Ship Energy Efficiency Management Plan and operational carbon intensity • Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, in force since 26 June 2025 • Inventory of Hazardous Materials requirements • Exhaust gas cleaning system approved onboard monitoring manual requirements

Gas-fuelled ships add a set of environmental controls that do not exist on conventional ships, and methane release is both a safety and a greenhouse gas issue. What you must be able to do: • Confirm tank connection space and fuel preparation room bilge overboard valves are closed, sealed and placarded • Confirm manual gas tank venting valves are closed and sealed and the seal numbers logged • Confirm gas manifold vent and purging valves are closed and blanked • Verify the gas detection system is fully functional on vent masts and double-wall piping, with no disabled or simulated sensors • Maintain the gas bunkering log and confirm the quality certificate is received and filed How this is proven in practice: • Completes a dual-fuel specific verification round and records the result • Identifies a simulated sensor in a supplied system status screen Common failure modes seen on board — learn from these: • A sensor placed in simulation during commissioning and never restored • Vent valve seals fitted but numbers not logged • Gas bunkering records incomplete because the format differs from oil bunkering

Energy efficiency instruments sit in MARPOL Annex VI Chapter 4 and are usually managed ashore, but the data and the operational decisions come from the ship. Crew who understand the mechanism produce better data and better decisions. What you must be able to do: • Explain the purpose of the Ship Energy Efficiency Management Plan and what entries it requires • Explain the Energy Efficiency Existing Ship Index and, where an engine power limitation is fitted, the operational implications and the documentation carried • Explain operational carbon intensity reporting and the ship's part in producing accurate data • Explain how hull and propeller condition, trim, speed and auxiliary load affect the outcome • Explain the fuel data reporting obligations the ship contributes to How this is proven in practice: • Explains, in their own words, how a decision taken on the bridge or in the engine room affects the ship's reported carbon intensity • Locates the energy efficiency plan and the engine power limitation documentation where fitted Common failure modes seen on board — learn from these: • Treating energy efficiency as an office matter with no shipboard action • Engine power limitation arrangements in place but the watchkeepers unaware of the operating restriction • Fuel data submitted without verification, producing a carbon intensity result nobody on board can explain

The Hong Kong Convention entered into force on 26 June 2025. The inventory is now a live document that must be maintained through the ship's service life, not a survey artefact produced once. What you must be able to do: • Explain the structure of the inventory and what Part I covers • Explain the certification pathway and the transitional arrangement running to 26 June 2030 • Maintain Part I when new material is installed, using material declarations and suppliers' declarations of conformity • Explain the restriction on new installation of listed hazardous materials • Confirm whether the ship is asbestos-free and where that is documented How this is proven in practice: • Records an inventory update following a supplied equipment installation, with the correct supporting declarations • Locates the ship's inventory certification and states its status Common failure modes seen on board — learn from these: • Inventory produced at survey and never updated, so it no longer describes the ship • Equipment accepted on board with no material declaration • Asbestos status assumed rather than documented

Where a scrubber is fitted, the verifier must be able to audit the whole evidence chain rather than accept that the system is running. What you must be able to do: • Audit sensor calibration against the approved onboard monitoring manual • Verify eighteen months of emissions and discharge data are available, including across any device change • Audit the record book for malfunction, maintenance, sensor-failure daily records, alkali consumption and residue landing receipts • Verify the discharge water analysis is current and appropriate to the trading pattern • Verify the system is operated in the correct mode for each area entered How this is proven in practice: • Audits a supplied record set and produces a finding list • Identifies the gap created by an undocumented device replacement Common failure modes seen on board — learn from these: • Accepting a running system as evidence of compliance • Data gap at a device change treated as unavoidable • Mode verification never carried out

By the end of this module you will be able to: On completion the learner can plan and conduct a structured shipboard environmental self-inspection, write findings that lead to closure, verify records against physical evidence, and sustain a reporting culture in which concerns are raised early. This module is grounded in: • ISM Code elements 9, 10 and 12 — reports of non-conformity, maintenance, and internal audit • MARPOL record-keeping and verification requirements across all Annexes • Company environmental self-inspection procedure and the six-monthly interval • Voluntary compliance programme gap analysis requirements, where applicable

The self-inspection is the ship's own check, normally at six-monthly intervals and normally the Master's responsibility with the Chief Engineer. Its value depends entirely on whether it is done properly or performed as a paper exercise the day before it is due. What you must be able to do: • Plan the inspection against a structured scope covering every system in this programme • Delegate specific checks appropriately while retaining responsibility for the review and completion • Allocate realistic time — a genuine inspection cannot be completed in an afternoon • Enter findings into the maintenance and defect system so they generate work and are tracked • Explain how the self-inspection relates to, and does not replace, inspection by shore staff How this is proven in practice: • Produces an inspection plan with scope, delegation and timing • Explains the relationship between the self-inspection and the external inspection cycle Common failure modes seen on board — learn from these: • The inspection recorded as complete with every answer 'Yes' and no findings — statistically implausible and immediately obvious • Findings recorded in the checklist but never raised as work • The whole inspection delegated and then signed without review

A finding that says 'housekeeping to be improved' produces nothing. A finding that names the item, the location, the condition, the requirement and the required action produces a work order and eventually a closed defect. What you must be able to do: • Write findings in a consistent structure: what was found, where, against what requirement, and what is required • Distinguish a non-conformity from an observation and from an opportunity for improvement • Assign responsibility and a realistic target date • Verify closure by evidence rather than by assertion How this is proven in practice: • Rewrites five weak findings into a form that could be actioned • Correctly classifies a set of findings as non-conformity or observation Common failure modes seen on board — learn from these: • Findings written so vaguely that closure cannot be judged • Everything classified as an observation to keep the non-conformity count at zero • Closure recorded on the basis of an email saying it has been done

This is the discipline that distinguishes an inspection from a walk-round. Every record claim should be testable against something physical, and the verifier's job is to test a sample of them. What you must be able to do: • Select a sample of record entries and trace each to physical evidence — a sounding, a seal, a receipt, a meter log, a spare part consumed • Reconcile across systems: record book against sounding book, incineration record against running hours, disposal entry against receipt, seal log against physical seal • Compare recorded rates against rated capacities and identify impossibilities • Investigate changes in operational pattern, cleaning, maintenance or spares ordering and establish the reason How this is proven in practice: • Completes a verification sample on a supplied record set and produces evidence-based findings • Identifies a pattern change and formulates the questions to ask about it Common failure modes seen on board — learn from these: • Verifying that records exist rather than that they are true • Sampling only the most recent month • Noticing a pattern change and accepting the first explanation offered

Port State Control, vetting and voluntary programme inspections are won or lost in preparation. The ship that has already found its own problems is in a completely different position from the one discovering them alongside the inspector. What you must be able to do: • Prepare the environmental evidence package in advance so any document can be produced in minutes • Brief the crew on what will be asked and on answering honestly and within their own knowledge • Accompany the inspector, record what is examined and what is said, and avoid speculation • Respond to findings with a corrective action that addresses cause rather than symptom • Explain what to do if an inspector asks a question the crew member cannot answer How this is proven in practice: • Produces a pre-inspection preparation plan • Role-plays an inspection interview without speculating or over-answering Common failure modes seen on board — learn from these: • Crew coached to give particular answers, which is transparent and profoundly damaging • Documents produced slowly and incompletely, which changes the inspector's assumptions about everything else • Corrective actions that address the individual finding but not the reason it arose

Every documented environmental prosecution has a period during which somebody on board knew. The single most effective control any ship has is a crew that raises concerns early and a command that does not punish them for it. What you must be able to do: • State the routes available for raising a concern, including at least one outside the shipboard line of command • Explain the protections that apply and their practical limits • Describe how to raise a concern in a way that preserves evidence and does not accuse • As a senior officer, respond to a concern in a way that makes the next one more likely rather than less • Explain the standing orders' role in setting the expectation How this is proven in practice: • Writes a concern report that is factual, specific and non-accusatory • Responds to a supplied concern in a role-play, assessed on whether the reporter would come back a second time Common failure modes seen on board — learn from these: • Reporting routes posted but not believed • A first report handled defensively, which reliably ensures there is no second one • Senior officers treating a report as a personal attack