Trouble is a relative term and so much depends on our old friends time, place and circumstance. But yes it’s possible to experience discomfort if not actual trouble based on entries alone. My only one instance of this came with a very nice PSC inspector who noted the names of the tanks I was using in the ORB did not match the names class had typed in the tables at 3.1 and 3.2 of the IOPP. Seems we were using the traditional / common names of the tanks in use on the ship but this did not match what the surveyor had recorded when setting up the IOPP cert.
She did not make a big issue (non conformity) of it but the combination of disappointment and compassion in her demeanor served to educate me to take the time and give a closer read of the sample entries and the regulations. One practical solution is to record the specific names of the tanks from the IOPP tables to the inside front cover of your ORB (some commercial versions of the book even give space for this) for reference so all are using the proper names. Don’t try to invent a better or more logical way to record things in the ORB than what they have specified. They (PSC)don’t care, petition IMO if you like wizzing up a rope.
As to the note taking scheme I say whatever works is fine in your talley-book. You seem to have the basics covered in your table and should be able to construct a proper ORB entry from that. For a sludge tank to sludge tank transfer (table 3.1) you record what “remains” in the tank it came from and “the total in” the tank transferred to as well as the amount so you’d want to account for that in your system. It seems the sounding and comment field should work for that though with a before AND after sounding of at least one of the tanks.
I think that this must be a common observation that the surveyors make. It was something that we’d been spoken to about at some point in the history of the book, and a lot of care was taken around this point. Its another reason why the singular, clean-handed, responsible adult makes the entry. The ORB needs to be translated into bureaucratese from the common tongue.
More often than not (IMO) it is entries in the ORB that will hang you. A good acquaintance of mine had the Coast Guard come down to the ship on a call from a disgruntled 3rd. In the end no oil was ever pumped over the side and in fact the guys on the ship were doing the best they could with a crappy set up but it was incorrect ORB entries that ended up getting the company fined and an agreement to implement an Environmental Compliance Plan to get the DOJ off their backs.
Once the Coast Guard starts an investigation and it goes to the DOJ the lawyers view it as a matter of winning or losing, not what is right or wrong. Not making entries per MARPOL can cause a lot of problems even with no ill intent. Remember Martha Steward did not go to jail for insider trading, it was what she said to the investigators. Al Capone went to prison for tax evasion, not all the real stuff he did. If the Coast Guard is called to a ship on allegations of illegal pumping, existence of a magic pipe, or the like and nothing is found…don’t be surprised if the ORB is gone over very carefully.
The first was from PSC in Japan because C11.4 entries were being made but the instructions from the CG in the ORB did not call for them. So we stopped using the C11.4 entry
The second was a few weeks later from the so-called German Water Police because the C11.4 entries were not being made, paid two 35 euro fines, one for me and one for the chief.
The third hit was from the company complaining that we’d gotten nailed on the ORB twice in a row and they told us to get our shit together.
So I know about problems with the ORB. But my view is it’s far better to take a take a hit on the ORB with no problems elsewhere then have problems with oil in the wrong place. I’d rather eat a shit sandwich then go to jail.
Of course it’s best if all the i’s are dotted and t’s crossed but if the E/R gets too paranoid about the ORB it’s possible they can take their eye off the ball.
The bottom line, make entries you can explain and defend. Based on the guidance, regulation language, etc. Be consistent as well. Slips in the syntax and grammar may result in discomfort and a “learning opportunity” but not making entries or falsely making them well, we know what that means. Especially if the PSC involved views their enforcement activities as a profit center. I have not witnessed that in person but some places they just have to find something to play stump the professor. I’d rather have them find something like a loose deck plate or signage issue than an error in the ORB but we operate hanky-panky free so I don’t fret about it too much.
If your ship operates with one person updating the ORB you can still be a big help by providing the detail required to make the entry whether your CE requires filling in a log sheet or passing him/her a chit.
In our case with the office you’re either in compliance or you’re not, but with story. And we were out of compliance and our story didn’t fit in the subject line of an email.
So the office took action and the P/E told the C/E that only the 1 A/E could make ORB entries. Normally the 3 A/E does it since he burns the waste oil and makes most of the transfers.
When I came back to work the C/E told me he thought the 1 A/E’s time was being wasted so I told him to switch back to having the 3rd make ORB entries and just don’t say anything. Which we did.
My thinking was the chief wanted to stay out of trouble, certainly as much as I do, so I should trust him to do things the way he thought was better overall and not just sweat the ORB only. Plus it was never a mistake by the 3rd to begin with.
For us, First does the homework and the OWS, all of us looked after the incinerator and transfers from time to time, and the cadet, oiler, and wiper do the soundings and ullages. I think it took First a lot of time every day to do the ORB, but he always did it during his “off” hours.
I wonder if a computer accounting system would make this all simpler. You could input your sounding tables for each ship once, and choose which country’s format you want for the ORB. It could be provided with time and location from the nav system upstairs. I see a GUI with a touchscreen: point at your tank, choose your action, enter the number: Voila, it updates its volume tallies, and First can log in at his leisure and make his entries based on that. I think a person could do it with Microsoft Access.
Well, this is my point. Having the ORB correct is important. Having the 1st take care of it seems like an obvious step to reduce the chance of problems. But having the 1st do it almost inevitably means he not going to be doing something else. But when something else goes wrong it will be impossible to make a direct link to the time and hassle of keeping the ORB.
PSC loves looking at the ORB, in my case they went right to the C11.4 entry because it was a new requirement and it’s an easy catch, they don’t have to leave the comfort of the ship’s office.
I’m not saying the 1st shouldn’t do it, I’m just saying I left it up to the chief, not as a knee-jerk reaction to some random PSC inspector who has little to no interest or responsibility for the safety of the ship.
I would have loved to have had whomever did the operation make the appropriate ORB entries. Unfortunately in my world of 90 day rotary assistant engineers I (as C/E) usually took care of the entries (based on engine room log entries) as they aren’t that frequent. When this changes I may need to revisit this approach.
Having one person do the ORB while he’s in his day-room has another drawback, too. Knowledge sharing is limited. If more of us are involved with making entries and getting feedback on it, then we are learning. If one guy is always having to squeeze in the time for it somewhere, we don’t get to see how it is done. Distributing the task might also build a culture of rules compliance and reporting in the ER, as people who know coach people who don’t. If everyone is sort of aware of where the levels are day-to-day, it might also make it easier to find and fix problems sooner.
I agree in principle but unfortunately when it comes to regulatory entries that can get you, the ship, and company in hot water the stakes are higher. If you enjoy having steady (~ permanent) crew there is no reason for this not to be the case. The same goes for PM and inventory records. On the other hand if you work under a rotary system where you get a mixed bag of abilities, the high turnover just plain wears you down.
Wears you down and people don’t feel ownership for the quality and continuity of the reporting. There is one local company here that seems to have this problem: its only day work, there are a lot of different people who have their fingers in the ORB: rumor is that the entries have got nothing much to do with reality. On the other hand, because they are in port every night and get pump-out service and they don’t put anything over the side or run incinerators. As a learner, I would be unlucky to end up in that sort of workplace, I think.
My company dictates that the Chief Engineer is the only person who may fill out the ORB for Machinery Space, and the C/M is the only person who may fill out the ORB for Cargo/Ballast. These duties cannot be delegated. I don’t know about the engine side of things, but I definitely wouldn’t want more than one person in my ORB. It takes me long enough to figure it all out by myself, never mind anybody else trying to fill it out too.
So in your case if the company left it to you to make the decision the outcome would be the same, you would take care of it. What if the company decided that the C/M was insufficiently mindful of his responsibilities and required the captain keep the records of cargo/ballast?
In that case, to the crew at least it, would be obvious that the company was making things worse. In the case of the Eng dept it could be better or worse. I don’t know, but my bet is the company doesn’t either.
That would become interesting. Some Captains, no problem. Others? I see that becoming an issue.
I think it’s more they hold one person accountable. Makes sense that the Mate is responsible for the Cargo, and, at least to me, that the Chief is responsible for the Engine Room. Every day at lunch the Chief gets the logbook with the day’s numbers, and fills it out after he eats.
The problem with one person signing the ORB is that if a mistake or fraudulent entry was made, unbeknown to the single person making the entry or signing for the entry, you can be liable, I don’t sign or make entries that I personally didn’t either witness or do my self. In the ORB on page 3, it also states that the officer or officers in charge of the operation make the entry and sign it.