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Oily waste management onboard of vessels
September 2006 update

Our colleague, captain LE CALVEZ, gave a lecture to air spotters cadets on training course with CEDRE, in order to explain them the origin of the oily effluents onboard ships, the means and rules of processing and storage of these products.
This lecture was also given during the seminar on maritime pollution fighting by ships (AGIS), organized in Brest by the Gendarmerie Maritime for European lawyers, police officers, customs officers, and gendarmes.

       One of the main sources of operational pollution of maritime environment by ships is propulsion machinery and all ships are concerned, as all of them use fuel oil for propulsion. In the past this was hidden by the operational pollution from tankers especially large tankers using cargo tanks alternatively for cargo and for ballast, in order to sail in safety conditions for hull stresses and keeping propeller correctly immersed.

       These procedures are discontinued as most of the vessels concerned have been sent to scrap since the beginning of years 2000 or even converted into floating storage for offshore oilfields.


         The fuel used in vessels propulsion engines is a product from end of distillation of crude oil, directly unusable. This fuel requires purification by centrifugation, in order to eliminate water and abrasive particles of heavy metals (vanadium, nickel) sediments and others. This operation has to be carried out by the vessel and generates approximately 1% of residues which have to be either unloaded periodically, or incinerated progressively, but in no case dumped overboard. The logical alternative to make the poor sailor's life easier would be to carry out this operation industrially ashore, at refining exit, but unfortunately, this residue generated has a commercial value in some countries of south-Saharan Africa and in China. It concerns very little our developed countries, which prefer to delegate to the vessels the management of these undesirable goods.

Some figures to give an idea of the vessels consumption :

Type of ship Power engine Speed Daily consumption
Generated waste
 Cargo liner 20.000 T 7.500 HP 12 kts 20 tons/day 0,25 m3/day
 Gas 35.000 m3 10.000 HP 17 kts 35 tons/day 0,4 m3/day
 Tanker 300.000 T 30.000 HP 15 kts 95 tons/day 1 m3/day
 Large container ship 50.000 HP 25 kts 180 tons/day 2m3/day

       Here is the B&W engine, 7 cylinders in line, of a 300.000 tons oil tanker , on the construction and test bench in a Japan shipyard, with the following characteristics :
  • Nominal power: 30.000 HP at 82 rpm.
  • Dimensions: breadth 9.50 m, length 14 m, height 17 m, weight 996 T
  • Lubrication oil load : 30m3.
The operation average consumption is 90 to 100 tons per day at 76 rpm that is to say about at 25.000 Hp and includes the generator sets consumption.

       This type of economic engine replaced the turbines installations of our old oil tankers from the Seventies, less demanding on quality of fuel simply burned to provide vapor, but consuming 120t per day in same conditions.


      To be used, fuel delivered on board must be in conformity with the engine builder's specifications, of type 380 centistoke and grade RMG35 as specified in the report hereafter.
      Sampling operations are conducted throughout bunkering and one average sample is sent to laboratory +for analysis in order to know injection parameters.

Here is a concrete example of analysis report :

To be noted: 0,2% of water, density 0,963, metals, sulfur,… and the temperature of injection to the engine 131° C.

  Fuel Sample   Nom du navire 
  VLC Log No.   F040850119 
  Date   08/02/04 
  Bunk. Port and Date   SINGAPORE - 07/25/04 
  Place and Date Sent   SINGA - 07/29/04 
  Date Received at VLC   08/02/04 
  Sample Type per Customer   IFO 380 
  Grade   RMG35 
  Tamper Proof   0216963 : Sealed 
  Customer furnished data:   Density 963,5 kg/m3 
  Quantity 3000 M. Tons 
  Density @ 15 deg C   963,2 kg/m3    (991,0 Max) 
  API Grade   15,32  ( 11,20 Min) 
  Viscosity @ 50 deg C   298,50 cSt   (380,00 Max) 
  Viscosity @ 100 deg C    30,9 cSt  ( 35,0 Max) 
  Upper Pour Point   19 deg C  ( 30 Max) 
  Carbon Residue   8.89 % wt.  (18,00 Max) 
  Ash   0,013 % wt.  ( 0,150 Max) 
  Water   0,20 % vol. ( 1,00 Max) 
  Sulfur   3,57 % wt.  ( 5,00 Max) 
  Sediment   0,01 % wt.  ( 0,10 Max) 
  vanadium   27 wt. ppm  ( 300 Max) 
  Al + Si   3 ppm  ( 80 Max) 
  Flash Point   > 65 deg C  ( 60 Min) 
  Si 2 ppm 
  Al < 1 ppm 
  Na 15 ppm 
  Ca 11 ppm 
  Fe 2 ppm 
  Pb < 1 ppm 
  Ni 6 ppm 
  P < 1 ppm 
  Zn < 1 ppm 
  CCAI 827 
  Calorific value  40,43 MJ/kg 
  Minimum Transfer
39 deg C 
  Injection Temperature
  (For 13 cSt Viscosity)
131 deg C 
  Engine Friendliness N°
  (EFN: 1-100)
The fuel sample tested conforms to grade RMG35.
Temperature for injection viscosity 10 is 143° C.
Temperature for injection viscosity 15 is 125° C.

Heat and store this fuel at 10°C above the measured pour point temperature.

Observation: Presence of water noted.
Ensure water removal through settling and purification.

Observation: This fuel has high sulfur.
High Sulfur can cause low temperature corrosion in combustion gas passages.
Avoid temperature below dew point.
Achieve this by maintaining higher temperatures and preventing moisture accumulation in scavenge spaces by keeping drains open. Avoid running engine at low speed for prolonged time.

Engine Friendliness Number (EFN) is a unique bench-mark of fuel quality evaluated by VISWA LAB from the point of view of engine wear and tear resulting from the use of this fuel. Based on EFN, which is calculated from the analysis results listed in this report, the quality of this fuel is good.

The conformance of this fuel to the contracted specifications may have no relationship to the evaluation of this fuel based on EFN.


Simplified schema of the principle of operation of a marine engine.

Internal combustion 2 strokes engine :

       The fuel injection is carried out at each passage of the piston at the upper part, and the gas renewal is done with air overfed at the passage at low position, with the exhaust valve opening at this moment. The smoke produced by the engine get away towards the exhaust gas economiser and the funnel through the turbo charger turbine, which compressor stage supplies with air the combustion chamber after passage through the air cooler. The fuel is settled in the bunker tanks, is centrifuged, and stored in a buffer tank, before being heated for injection into the engine at approximately 130°C.


       Between 0.8 and 1.5% of residues are generated by centrifugation of fuel, that is to say about 1 ton per day (for our example).

       lubricating between lining and piston is done by a continuous lost injection of about 800 liters of cylinder oil per day. The cylinder oil drainage, cumulated with ashes and soot in the lower chambers of the pistons, (vaults), the filtering and centrifugation of movement oil generate about hundred litres of oily residues per day.

       All these residues, after transit through small intermediate capacities, are stored in a sludge tank 85m3 capacity (for our example). This volume is calculated before construction according to the type of voyage that is to say 2,5 months.

       This low part of piston (named vaults and scavenging manifold) requires a monthly cleaning during an interruption period. This operation generates from 200 to 300 litres of solid oily waste.


       For the elimination of this liquid sludge from the sludge tank several possibilities exist. It shall be noted that there should be no piping for direct dumping to the sea.

  • The discharge in port of call, but more, it is necessary to find facilities or a barge able to receive this sludge, for a financial contribution of course.
  • The onboard incineration.
  • The transfer to the cargo slop tank (residues tank) is an option applicable only to tankers, but however with commercial constraints, and thus not always possible.
Incineration of the engine oily sludge.

       A slow operation, which requires in our example the care of an engineer every day :
  • to burn 1m3 in 12 hours at a rate of 80 liters per hour, from 7 a.m. to 7 p.m.
  • for daily transfer to the incinerator tank of 1m3 at the end of the day.
  • for the warming up during the night, in order to facilitate the combustion of the product and the decantation of water towards the bilge waters storage tank in the morning.
       The incineration is time consuming even when the device works properly, it matches with difficulty the residue production, especially when the bunkers quality is poor or difficult to treat. The solution is sometimes a compromise between incinerating as much as possible, and discharging this sludge in some ports able to take delivery by barge, as in Rotterdam, Gibraltar, Singapore, in China or in Fujairah (Arab Emirates) with the flow rate of the small transfer pump (7 to 10 m3 per hour) after reheating at 80° C, or alongside as in the ports of North Sea, with the example of Mongstad in Norway, where the discharge of sludge is free. But the problem is to pump out the residues at 150 meters from the engine room exit, in the middle of the ship, by the cargo piping, before beginning the commercial operations.

       Some oil tankers companies currently have all-in contracts for sludge removal in Fujairah, a small bunkering port located at the entrance of the Arab Gulf, provided that the operation is carried out quickly. This requires the transfer of the sludge the previous day at 8 m3 per hour, after reheating, towards cargo capacities, then the use of the reciprocating stripping pump at 200 m3 per hour to pump towards the barge during a little half an hour. The cost of the operation is the mobilization time of the reception barge, because for everybody, time is money.

Solid oily waste

       Two solutions to process the oily solid waste production from the vaults and the engine scavenging manifold: The periodic discharge in 200 litres drums, which is a good drill for administrative correspondence and paperwork, or the incineration, a more economic operation but rather difficult, dangerous, and not very clean.

Management of oily water from engine room bildge :

Note: the domestic waste water is not considered, being matter of a statutory specific processing.

       Since the end of era of wooden vessels, despite the mechanical seals of the pumps and other propeller shafts watertight systems of our beautiful steel ships, we always pump engine bilge water, stored in a capacity located, like the sludge tank in the double bottom of the engine room compartment, which contains, in theory, contrary to its neighbor, a lot of water with a little oil on the surface.

       On board a vessel in good condition, this daily water production comes mainly from condensation of atmosphere humidity from the air-conditioning plants, and especially from the air cooler of the main engine and of diesel generator sets, where the atmospheric air is compressed in the turbo-chargers, then cooled down by the passage in the air cooler. According to the hygrometry of the geographical zone, this production is about 20 to 30m3 per day in our example. Note: Being able to contain some compressors lubricant, the condensations dumping of air-conditioning in the bildge tank is mandatory.

       If this production of limpid fresh condensation water does not create any difficulty for pumping to sea through the statutory oily water separator at 15 cm3 per m3 (15 ppm) , the following occasional maintenance operations will complicate this task.

  • The monthly periodic washing of the aerial part of the air coolers carried out during the port stops of the main engine, dumps there 1 to 2 m3 of water which contains a chemical specific to this type of cleaning, and gives to this water an appearance of whitish emulsion.
  • The monthly periodic washing of the exhaust gas economiser smoke element, carried out during these same stops, may at each operation pour there 2 to 3m3 of dark water despite the passage through the decantation soots tank.
  • The wash water from the workshop wash-hand basin and the washing of the engine floors pour there a dirty water not necessarily oily.
  • The various maintenance and cleansing operations of the condensers and sea water exchangers carried out when stopped in ports give some quantity of seldom limpid harbor water and almost always unacceptable for the 15ppm separator sampler.
  • During harbour stay the damages to mechanical seals of the pumps caused by muddy water of some rivers can bring in a non-oily and muddy water unacceptable by the sampler.

Engine bilge waters separator 15ppm.

photo P. Le Calvez
       Various models of equipment, whose principle of operation is the following :
       A 5m3/h bilge pump pumps water from the bilge tank to the stilling tank. Inside this tank the oil is separated from the water and an hydrocarbon detector connected to an electric valve drains the oil to the sludge tank, the water below the oil flows through filters where solid particles are retained and through the 15ppm sampler detector, which actuates a 3 way valve, to the sea. From experience, this system has limited capacities, reduced to light oils or gas oil, with fuel oil you get quickly into trouble by oil plugging of various elements.

       On recently tested devices : The principle of operation of the approved detection device, on a vessel launched from a shipyard in 2001, is based only on opacity and a photoelectric cell, and not on an hydrocarbon detector by light diffraction or other technical principles (chromatography...). This system which does not accept dirty and whitish non-oily washing water, and the water pumped in ports, brings the user to defy the interdict by misleading the detection system with a clear fresh water injection. Equipment unable to differentiate hydrocarbon from dirty water…! The periodic cleansing of the bilge separator filters in the engine room brings the collected dirt back to the sludge tank and is recycled again…!

       Hereafter, the standard management cycle of engine oily residues in application of MARPOL regulation :
  • Daily production of 1m3 of oily sludge and 40 m3 of bilge water.
  • Daily transfer at day's end of 1m3 towards the incinerator & reheating tank.
  • Decantation in the morning of water towards bilge water tank
  • Incineration of the sludge during 12 to 14 hours per day
  • § Pumping of bildges through the 15ppm separator during 8 hours in authorized zone.
       Regarding the problems encountered due to the lack of reliability of this separator, everyone has his method of bilge water management!

       It is thus better to avoid oil introduction into the bildge separator, and therefore into the storage tank, which everyone will keep clean. It will never be fully drained in order to maintain the possible oily layer on the liquid surface.

       According to the structure configuration of each vessel, an additional decantation system may be installed upstream of the bilge water tank. The interest is to have a good decantation capacity, little influenced by dynamic movements of the vessel, with great height and small sections in length and breadth (large and long vertical pipe), which is not the case of the bildge tanks located in the double bottom.

       The evaporation before incineration, is another solution whose cycle becomes the following after the installation of a second storage tank :

  • 1m3 oily Sludge production and 40 m3 bilge water per day.
  • Daily transfer at day beginning of 1 m3 from the evaporation tank towards the incinerator tank.
  • Continuous sludge incineration, 24h/24h
  • Filling up of the 3 m3 evaporation tank and heating.
  • Pumping of the bildges through the 15ppm separator during 8 hours
       With inertia, some ship-owners conscious of this problem, install, in line with oily water separator, a new more efficient equipment available on the market. Others ask their crews not to dump bilge waters in the “watched zones”…! Some coasters have instructions from their ship-owner not to use the bilge water separator, and to discharge these waters at port.

       Equipments of engine bildge separators brought into service in year 2005 have difficulties to produce waters with hydrocarbon content lower than 200ppm.

PPM : Part Per Million, figure without dimension, which uses numbers of same nature (weight or volume). 1 ppm = 1 g per ton or 1 cm3 per m3 and not grams per cubic meter or cm3 per ton.

Regulation and Recordings.

       In order to facilitate to the various international administrations the control of the proper uses in compliance with the international rules of pollution prevention of the maritime environment, we find on all vessels the main documents and recordings as follows :
  • The up to date document of MARPOL regulations (maritime pollution convention).
  • IOPP (International Oil Pollution Prevention) certificate of compliance with MARPOL rules for processing plants of the engine sludge, and water bildges for all vessels. Are reported there the volumes of the tanks and the characteristics of the incinerator.
  • An additional part to the certificate (IOPP) of compliance with the MARPOL rules for the washing and treatment plants of the cargo compartments and hydrocarbon discharge for the vessels carrying oil, hydrocarbons, and chemicals.
  • The Oil Record Book N°1 for engine room for all vessels, in which every day and in a coded way are recorded all the main operations of bunkers and ecological pumping, incineration and discharge to shore plants with written certificate from the receiver.
  • The Oil Record Book N°2 for the cargo capacities for vessels carrying oil and other pollutant products, in which are recorded in a coded way all these commercial operations of transfer, washing, water ballasting operations, and discharge relating to freight capacities.
  • An O.D.M.E. (Oil Discharge Monitor Equipment) device for analysing and recording the hydrocarbon dumpings from the cargo capacities for vessels carrying potentially pollutant products. These recording strips must be kept onboard for 5 years. Informations recorded: date, GMT time, geographical positions (on some models), speed, flow rates, and dumping rates must be in compliance with the records of the N°2 Oil Record Book.
  • A Ship Oil Pollution Emergency Plan (SOPEP) for fighting against accidental pollution, approved by the authorities. This plan has a worldwide application except in the USA, where it is replaced by the OPA90 (Oil Pollution Act of 1990).
In this plan we find, the inventory of statutory antipollution equipment, the worldwide phone call list of the companies and local authorities, the ship's plans, and a blank form of assistance and towing contract.
  • A register for garbage bins management on which are recorded daily the dumping to sea from galley and biodegradable waste, the incineration of solid oily waste (greasy rags), the periodic discharge of the plastics with the certificate issued by the receiver.
  • Various pollution insurances certificates, civil liability (CLC), P&I, and others…


  Propeller shaft sealing

       It happens periodically to all vessels some worries with this sealing system for propeller shaft, due to fouling with nets for example, the ship has a continuous leak of a small quantity of oil.

       To repair afloat this damage, requires the sealing replacement, bring out from the water the propeller shaft hub, and thus the unloading of the ship combined with a ballast movement to trim by the head.

Oil coolers

       Leaks caused by corrosion or constraint movement of the ship's structure on the sea water oil coolers may be the source of continuous or episodic lubricant leakages by this mechanism.

Contamination of the ballast water tanks by hydraulic leaks

         The operation of the seawater valves of ballast water tanks is usually hydraulic. On some ships without duct-keel, pipings and valves actuators are located directly in the ballast water tanks and may perspire, even leak episodically or continuously some oil, due to corrosion, loose connections, or constraints caused by the localized deformation of the ship's structure normal work.

       Some vessels may be equipped with immersed ballast pumps hydraulically driven (FRAMO standard) with same risks of potential leakages. Damages being able to cause an unforeseeable and uncontrolled dumpings to the sea, of transmission lubricant, during full ballast water draining, even congregated to the sludge mud. Situation and event which may happen to all vessels (and even to good crews).


Soot tank draining.

       Due to the main engine economizer periodical washing, the contents of the soot storage tank will be drained in open sea after the port of call, using a sea water ejector device on the fire collector. This operation may generate a black trail, transitory, with an oily appearance in the ship's wake. This normal operation is applicable to all the trading ships. It is not considered as pollutant because not mentioned in the Marpol protocols.

Contamination of the harbor water by the washing tower of the inert gas generator.

       Unusual, but, identical to the soot effects, the oil tankers processing the smoke of the boilers by washing with sea water before injection into cargo capacities, may encounter this misadventure in the event of temporary bad combustion with an important smoke production, resulting in a black and transitory contamination of the harbor water very similar to a pollution effect of heavy petroleum product.

Operational management of the Ballast.

P. Le Calvez photograph

       The pumping of ballast water in some river ports (the Loire, the Gironde, the Mersey, the Yang-tseu-kiang…) overloads the ship with mud, sometimes black , which it is necessary to quickly remove before decantation, this as soon as in open sea. This operation may leave a coloured trail in the ship's wake. Example: The ballast water mud charge of a 300.000 t VLCC in Donges harbor is about 200 tons.

AFCAN photograph
AFCAN photograph

       These sludges and muds pumped in from harbours may contain and congregate together various oily waste of unspecified origins (dumpings from other ships, 15ppm outflows from refineries, harbour facilities, underground pipes leakages, or organic triturations in decomposition inside muds…). From experience of manoeuvres in some ports, the propeller movements pushes up oily irisations with the mud to the surface of the water.

Regulation management of Ballast Water (B. W. M.) :

       In order to avoid the contamination of the ecosystems in some ports as in the USA, by live species carried from other ports of the planet, it is imperative to renew the ballast water in open sea before calling in these ports.

Various cargo dumpings during the cargo holds cleaning :

       Some ore vessels, due to commercial reasons of products changes, have to clean their decks and cargo spaces after unloading. Coal, iron ore, bauxite, animal feed flours generate beautiful coloured trails.

       The discovery last year, with a media coverage, of carbonaceous blackish releases on the beaches of the south western part of France, considered at the beginning as pollution by hydrocarbon, made me think about a voyage on a gas transport vessel, from Gijon in Spain towards the North Sea, during which we had to wash the decks and superstructures after a rather long call in this port with inopportune loading, by the wind, of a remarkable quantity of coal dust from the next quay. This operation generated a beautiful blackish trail on calm sea.


       For commercial reasons of products changes, of cleaning operations before repairs, of water ballasting operations for bad weather condition, the vessels carrying crude oils, hydrocarbons, and chemical products, when proceeding, may have to dump their decantation water or ballast water (from cargo capacities) in open seas authorized zones at more than 50 miles from the shore, with an oily flow rate not exceeding 30 liters per nautical miles. The total dumped quantity for each voyage must not exceed the 1/30.000 of the volume previously loaded, that is to say 10 tons for a former 300.000 t oil tanker. It should be noted that the sampling equipment for the dumpings is a chromatography hydrocarbon detector independently of the water opacity.

       These recordings and written traces can be found again in the N°2 Oil Record Book and on the dumpings detector paper strips.

double-hull oil tankers from years 2000.

P. Le Calvez photograph
         Having experience of crude oil transport for the last 35 years, the VLCC with double-hull is, today, very ecological operationally compared to old structures with simple hull and ballasting operations in the cargo capacities, Clean Ballast Tanks (C.B.T. ) and segregated ballast tanks (S.B.T. ). The sea water transfers in cargo capacities of double-hull vessels are unusual and exceptional, the contamination possibilities of ballast tanks by pipings damages impossible because there is no passage of ballast pipings in the cargo and conversely.

       Moreover, the various crude oils are liquid ores more or less viscous according to the origin, and loaded at temperatures between 30 and 45°C. They are transported throughout the planet during 2 to 5 weeks, and sometimes discharged in winter zones. The products, cooled down by the heat exchange of the hull in contact with the ocean, become thicker, adhere to bulkheads and structures, settles on the handrails, and sometimes are difficult to pump at low temperature. This phenomenon always applies to single hull existing vessels.

P. Le Calvez photograph
         The handrails and structures of the double hull vessels are mainly localized in the ballast water tanks sections.The plane surface areas of the cargo capacities, bulkheads and floors, do not offer any more hiding places to the viscous elements, and a washing of the bottoms with light crude incomparably minimizes the residues remaining onboard at the end of the discharge. Moreover the empty double-hull limits the heat exchange with the sea during the voyage,vessel loaded. For example: Loaded at 42°C in Saudi Arabia, the product is delivered at more than 30°C in Saint-John, Canada, in February after 35 days at sea by the Cape of Good Hope, for 10 to 15°C on a voyage with a single hull.

       The disadvantage of these vessels is, at sea, the very difficult paintings maintenance of ballast water tanks, because of the access, of containment, of moisture, of heat, of mud accumulation, and the paintings drying time, especially if they were not perfectly succesful during construction. These paintings of ballast water tanks are applied at the shipyard at 98% in open air before assembling the various elements. After the assembly, only are remaining the weldings to be covered, this in good conditions. To note: The stop periodicity for the careenage of these types of vessels is only about ten days every 5 years.
This type of ship is thus not inevitably the ideal remedy for accidental big pollutions.

Air surveillance and repression of the ships dumpings :

Comments from a sailor in conclusion of this presentation.

       I perceive this initiative of our political leaders well covered by the medias like an univocal contribution to the other international maritime authorities, in order to give a sense of responsibility to the various intervening parties in sea transportation on improving cleanliness of the oceans.

       However, at the era of evidence by DNA in criminology, where at few meters the sight of a simple red stain (of painting) does not conclude inevitably to a murder, I deeply think with many reserves that the visual observation at few hundred meters, without other reliable technical means, of a coloured trail in a ship's wake, does not mean necessarily the effective evidence of a pollution offense, with risks of disproportionate sentences and fine, revised at increase after every maritime catastrophe.

       The delocalization of legal follow-up of these pollution cases with a mediatic din towards countries of great maritime vocation seems beneficial to me. It will allow in the medium term, I hope, to get back to a reasonable and more objective processing of these cases. The systematic sampling of the punishable dumpings, in order to know the nature and thus the source of the pollutant, seems essential to me to leave this present context of inculpation by presumption of culpability, and give possibility to reconsider the accidental dumpings (mistake or lack of luck) and to discriminate the illusions of pollution. Not rely on the judgment of God after sentence by all…! Being overflown by one of your planes, during the liquid gas carrier deck washing to remove the coal dust as per my previously quoted anecdote, I think retrospectively that I probably should have been diverted to Brest, and sould have been accused of pollution for hydrocarbon dumpings (with lack of cadaver), and this, due to the necessary analysis time to establish the true nature of this carbonaceous residues collected directly on sand during this “false” beach pollution of the Basque coast last year.

       I finish this presentation with some news of one and not the least of these maritime world intervening parties which is the I.M.O.

       The International Maritime Organization re-examined during year 2003 the certification requirements of the engine bilge water separation and dumpings equipments, for the ships which construction started after january 1st 2005. By establishing a new test procedure of separation in workshop laboratory, and modifying the dumpings analysis device, which becomes similar to the cargo dumpings chromatographic detection device of the oil tankers, with recording paper strip to be kept 18 months for potential check by authorities, and with impossibility of misleading or blocking the rinsing sequences of the measuring cell.

       However, during the IMO 2006 spring session, the German and Indian delegations appeal for revision of this new resolution MEPC.107 (49) of July 18th, 2003, Germany proposing additions to the homologation tests procedures to approach the reality on board. And more realistic India, informing that today's systems for process of used oils from engines are inappropriate, and asking for improvements in efficiency, flow rate, and quality, arguing that equipment designers and those who lay down the rules do not seem to understand the real conditions of movements, of heat, of moisture, of various emulsified residues generated on board of vessels, which explain why, even the new installed material in accordance with the year 2003 rules is still unsuitable for onboard requested use. Difference between quietude of a laboratory and the open sea… Also indexed to this proposal: the insufficient vessels incineration capacity always calculated too short, the bunkered fuel quality, the time spent by the crews to operate and maintain these equipments in good condition, the inadequacy of reception facilities at a reasonable price, and request to the MARPOL 73/78 signatories countries to take concrete measures to provide in their ports reception facilities easily accessible at a reasonable price, rather than to engage procedures against the sailors.

       Do we have to be surprised that in a democratic country, passionate for justice, we do not seek better for the guilty? In comparison with the life expectancy of the ships currently operating, equipped with their origin separator, we cannot hope for an improvement of the engine bilge water dumpings quality only beyond the year 2036 in the legislation present state.

Captain Patrick LE CALVEZ

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