I need a (sea) lawyer to interpret Marpol V

A vessel is working a rig in a special area. The nature of the vessel’s job requires the vessel to stay in the vicinity of the rig for several months.

Regulation 5 (pertaining to fixed and floating platforms). Para 2 states “Food wastes may be discharged into the sea from fixed or floating platforms located more than 12nm from the nearest land and from all other ships when alongside or within 500m of such platforms, but only when the wastes have been passed thru a comminuter or grinder.”

Regulation 6 (pertaining to discharge of garbage within special areas). Para 1.1 states “Discharge of the following garbage into the sea within special areas shall only be permitted while the ship is enroute and as follows: Discharge into the sea of food wastes as far as practicable from the nearest land, but not less than 12 nautical miles from the nearest land or the nearest ice shelf. …”

Question 1: Does this vessel fall under rule 5 or rule 6?

Question 2: If regulation 5 applies does it mean that the vessel can only dump when it is within 500m of the platform?

My understanding is a ship within 500m of a platform must follow waste management protocols of the platform.

A standby vessel beyond 500m is considered a stationary platform if it is not underway. The term ‘en route’ refers to vessels underway which will spread any overboard discharge over a broad area so less stringent restrictions apply. In the case of food waste, the rules are the same. it must be passed through a grinder capable of producing particle size less than 25mm and then discharged. Other waste streams have varying procedures and that is where the distinction between stationary platforms and ships come in to play.

See link for a quick visual of the distinctions:

Not an attorney so take the above as an opinion.

I vote for Reg 6 …

both can apply
rig in or out of 12mile zone?

Rig is outside 12nm and in a “Special Area” as defined by Marpol. My interpretation is that even in a special area, if you are inside 500m you can dump food wastes without being “enroute” as long as it is ground. If outside the 500m but “standing by” the rules technically state the vessel must be “enroute”. So, to dump 2 buckets of slop (which takes about a minute) you should be enroute. I guess the rule makers have to draw that line somewhere.

These may be completely stupid comments so get ready…

What are you going to be doing with your trash for these months of standby?

I would assume that there will be other vessels bringing supplies and groceries back and forth to you and the rig if you will be piling a standby op for that amount of time. I would see if I could transfer this garbage and good waste to the transiting vessel to send back to port if I wasn’t equipped with the proper grinder.

I don’t know though… Just throwing around ideas.

Some vessels have incinerators for their trash. For the most part though standby vessels send their trash in with crew boats that frequent the site.

[QUOTE=Azimuth;121485]Rig is outside 12nm and in a “Special Area” as defined by Marpol. My interpretation is that even in a special area, if you are inside 500m you can dump food wastes without being “enroute” as long as it is ground. If outside the 500m but “standing by” the rules technically state the vessel must be “enroute”. So, to dump 2 buckets of slop (which takes about a minute) you should be enroute. I guess the rule makers have to draw that line somewhere.[/QUOTE]

incinerate

[QUOTE=blaineatk;121490]These may be completely stupid comments so get ready…

What are you going to be doing with your trash for these months of standby?

I would assume that there will be other vessels bringing supplies and groceries back and forth to you and the rig if you will be piling a standby op for that amount of time. I would see if I could transfer this garbage and good waste to the transiting vessel to send back to port if I wasn’t equipped with the proper grinder.

I don’t know though… Just throwing around ideas.[/QUOTE]

incinerate