Oil record book technicalities

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hugerich
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Oil record book technicalities

Postby hugerich » Fri May 01, 2015 8:26 am

Here's a question for those of you that have had the pleasure of maintaining an oil record book.

We have two tanks that are recorded as sludge tanks and are therefore recorded in the oil record book when any transfers are made, such as to an incinerator or from another tank registered as holding sludge to one of these sludge tanks. However, my question is about something in the guidance that is in my opinion not overly clear.

One of the tanks has all of the engine room drains leading to it, so we are talking settling/service tank water drains and various oil drains round the engine room. Now, since the oil record book states that I only need to log waste oil collections that are PUMPED (they have this word in bold in the guidance) to the tank rather than drained to it, would I need to include these in the book? My rationing also is that I don't need to include every bowl discharge from the purifiers to the sludge tank, so why should I have to do it with oil drains? The paragraph I am referring to is this one:

Operator initiated manual collection where oil residue (sludge) is transferred (transfer with a pump) into the oil residue (sludge) tank(s).

The page I am referring to is this one http://www.imo.org/blast/blastDataHelpe ... me=736.pdf

The reason I ask is because I inherited this book from the previous engineer, and before the weekly declaration of tank quantities on the same day he would always put x amount collected from fuel oil drains to make up for the increase between last weeks numbers and this weeks, since the tank had increased without any transfers to it. Which also doesn't make a lot of sense because if you were to take that statement at face value it means you have managed to drain say 2 tonnes of oil in a single day rather than over the whole week.

So, any thoughts? Any input is as always appreciated.

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JollyJack
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Re: Oil record book technicalities

Postby JollyJack » Fri May 01, 2015 7:02 pm

Falsifying documents is a very serious offence. A short explanation that the drain tank is gravity fed would suffice. Sometimes, wide boys enter burning 2 cubic metres of sludge per watch in the incinerator, the capacity of which is 85 litres an hour! If I, as a Port State Control inspector were to see that I would lay charges.

I take it you refer to Annex 2, page 2, example 2. The drain tank should be listed in the weekly entry for retention. (Page 1, example 1) At least, that's how I see it, how the stuff actually gets there isn't really relevant
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hugerich
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Re: Oil record book technicalities

Postby hugerich » Sat May 02, 2015 7:33 am

That is the way I interpreted it. The way I see it, any decrease in sludge should be a concern for someone auditing the document, however an increase shouldn't be a big deal as long as it is accounted for when it leaves the tank. This of course doesn't apply if the increase is due to a transfer by pump from somewhere such as a genny sump or another IOPP nominated tank. Also a recent addition is that all waste oil from the galley has to be logged if poured down the sounding pipe, as small as the quantity is as it is also noted in the ships garbage record book so these must match up.

As I mentioned, I do log all IOPP nominated tank quantities every week so I'm pretty sure I'm covered if someone does start asking questions. Plus I have the backup of the document itself that states only pumped transfers need to be logged unless from another nominated tank, the only reason I really wanted to double check with you guys is because we are on our way to the US and I have heard they try their best to catch you out on the smallest errors. Never been to the US before and I am dreading the sight of the coastguard, even though I am absolutely confident we do everything by the book here! But still, best to be safe than sorry.

Thank you for your help.

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JollyJack
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Re: Oil record book technicalities

Postby JollyJack » Sat May 02, 2015 8:01 am

Most of these USCG guys are young kids with check lists and a chip on their shoulder. Just look him right in the eye and convince him that you know that he knows what you're talking about, then you can tell him anything. The older guys have been around the block, just look him in the eye and tell him the truth. Nothing to worry about if due diligence is taken.

When a Carnival Cruise ship fitted a "magic pipe" to bypass the OWS and pumped bilge oil overboard, they were fined $3 million because it wasn't in the ORB, the charge was falsifying documents.
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Big Pete
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Re: Oil record book technicalities

Postby Big Pete » Sat May 02, 2015 11:21 pm

Years ago when was on the Irvine Canada,(Products Tanker) I remember a US coastguard Inspection by a young Coastguard with a clipboard, he was asking one of the Deck Officers what every piece of equipment on the Bridge was, and was quite happy when he was told that the second Radar was a Fish Finder, just ticked the Box on his inspection sheet.
When he checked on Deck he got very worried by the Inert Gas system. we didn't use it because the keel was laid before the requirement to use it came in. Despite the spectacle blanks in the deck lines, between the tanks and the ER he was concerned that oil vapour would leak past the gasket between the tank and the spade blank to atmosphere then leak back in between the other side of the spade blank and the gasket to the Engine Room, he nearly drove me insane as I tried to explain on how many levels that was impossible.
I agree with the previous comments on the oil Record Book, try your best to follow the Regs and be honest.
Although I was once fined by the German Coast Guard, they went through the previous 3 years entries in the Oil Record book and added up all the quantities added to the Bilge Tank and all the quantities reported discharged and compared it with the remains on board figure and it didn't exactly add up, despite the fact that we had always entered approx. 0.3 cubic metres ER Bilges transferred, or whatever. Purely a cash raising exercise. Three of them sat down with calculators for a couple of hours going through the book...

BP
It is always better to ask a stupid question than to do a stupid thing.


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