I have just had an email from an ex Cadet of mine, (see below) asking for details of padlocking Bilge valves.
As I am retired, I no longer have access to ship board copies of MARPOL and Solas and I was wondering if any of you who do have this access could provide up to date information on this topic? The company he sails with no longer provides a Hard Copy of these Books, instead it supplies the information on CD "Regs4ships" which is very difficult to search.
I thought the question raises a good point and was worth further discussion.
Currently having a discussion with the Chief and he thinks I’ve put a valid point across but I need the evidence to back it up.
The direct bilge overboard Valve is locked shut which means it can only be operated after unlocking. This is good to prevent accidental discharge. However, in the event of flooding where the engine compartment is to be drained of water quickly it is a potential threat to the ships stability should you take time to find the key and unlock the Valve.
I suggested to use a weak link system with a unique number inscribed where in the event of emergency can be broken but under normal circumstances. This will serve as a ‘barrier’ to those wanting to open the Valve when it shouldn’t be.
Is there a regulation that backs up my argument that the overboard Valve should not be physically locked. Having problems locating it on the ‘regs4ships’ disk
Thanks for your help,
My understanding is that US Coastguard Rules require all Bilge overboard valves to be identified as such and padlocked locked shut from entering US Territorial Waters until leaving US waters and locking and unlocking the valves should be recorded in the E Log Book.
However, in the case of the Emergency or Direct Bilge suctions, or Direct Bilge Injection valves these are
often connected to Engine Cooling systems and the Bilge water would discharge overboard through the engine cooling water system and the overboard valves for that could not be locked shut!! So it would make sense to secure them shut and if the US Coastguard require the normal overboard discharge valves from the OWS, Bilge & GS pumps etc to be locked, why not the Emergency suctions?
However, as far as I know, there is no requirement to lock these valves OUTSIDE US Territorial waters, I can't remember MARPOL saying anything about this at all.
Personally I think many shipping companies order all Bilge overboard valves to be kept padlocked shut in order to prevent accidental discharges and prevent deliberate discharges by Junior members of the ER crew. It puts all responsibility for overboard discharges firmly on the key holder, usually the Chief, or on larger ships the Second, and absolves the shore side management of any responsibility. However we all know that a padlocked valve can usually be opened by removing the hand wheel, with the padlock and chain still attached, and then opening the valve with a shifter on the square at the end of the spindle. However, this is a matter of Company policy, which may not be the best option for shipboard safety.
I am not sure if SOLAS requires all the Bilge Pumping equipment to be immediatly operable, if it does that would would make padlocking Bilge Valves a contravention of SOLAS.
In my own experience I have sailed with Companies that required all the Bilge valves to be listed and secured shut with numbered seals, every time a valve was open, the seal would break and the reason, time and date recorded in a "Bilge Valve Seal Log Book" after the the Legal Bilge pumping operation was completed the valve would be closed and a new numbered seal secured to the valve and the number time and date recorded in the Log Book. Every week the seals were checked for damage and any damaged ones replaced and this also was recorded in the Log.
If the ship is flooding and the water level in the engine room can not be controlled in any other way, the Captain and Chief Engineer can authorise the direct discharge of the ER Bilge Water overboard by any and all available means, this would not usually be agreed unless the Bilge level was threatening the stability of the ship or endangering Electrical Equipment and essential services, and the Oily Water separator was already unable to hold the Bilge level and initial efforts to stop the flooding had failed.
What does everyone else think? I am sure JK and JJ will have some thoughts on this.
Keep your feet dry everyone.
It is always better to ask a stupid question than to do a stupid thing.