Read this in the news this morning. Note they were found guilty of falsification of the vessel’s Oil Record Book.
Yes, getting caught with a illegal discharge and a falsified ORB is likely to land someone in legal problems.
My question was how many problems have people had with problems with the ORB only, for example clerical errors, with no underlying issues?
In the linked news the point was explicitly made that it was not simply a records issues:
“While the charges in this case rest on the failure of the ship’s crew to properly document the discharge of oily bilge waste, the heart of this case is the illegal discharge itself
In my view the lesson learned here is not; if you discharge oil illegally make sure you log it properly in the ORB.
How come the chief only got a $5500 fine for misleading the USGC, faking up the ORB, and (looks like) habitual polluting? Seems like he got off easy. I guess he got his name published, too… that’s fairly serious.
If one discharges oil under any circumstances it should be noted in the ORB. I have made entries where the OWS malfunctioned and I suspected a discharge occurred. An entry was made stating such noting when and where. Some years ago an acquaintance of mine was dealing with a leaking stern seal losing several gallons a day. He made entries in the ORB. When the Coast Guard became aware of the leak they specifically asked if it was noted in the ORB. When they were shown, it was all good.
If I have 3.2 Cubic meters in the waste oil tank, then someone changes the oil in an air compressor and dumps it down to the waste oil tank it requires an 11.4 entry. So an entry along the lines of: “.015 M^3 from #1 Start air compressor sump to waste oil tank, 3.215 M^3 ret.”
So you end up pumping “exactly” 215 liters of waste oil to the incinerator. Wow, now my waste oil tank has exactly 3 M^3 left.
The front has a passage that say’s: Soundings may change based on trim, list, temperature, this book should be considered accordingly. Yet here I am, pumping slops with precision down to the liter
Does your company require you to go to 3 decimal places on entries? If so, that’s crazy. I’d just base it on sounding. Whatever the inital and final soundings converted to in volume then that’s what you log. When we log galley oil disposal (20L or 0.020 m3), usually the ROB after the transfer is the same as the previous entry because adding that little amount doesn’t make a measurable difference in the sounding.
Some would say then why even bother making the entry? Because if an auditor or vetter looks at your records and sees the SAC had an oil change on this date, he can ask what did you do with the oil? With no entry, your choices of answers are 1.- We didn’t make a required ORB entry or 2.-we didn’t actually do this required PM and made a false entry in the maintenance program… Neither is a good answer.
Just a C/E I worked with. Every entry needed to add up even if it didn’t correctly reflect the tank level. Looking correct and exact in the ORB was the most important part. He counted the Sunday sludge entries as a reset, deeming those the start numbers for the week.
As stuff got pumped, steamed, or burned our tanks got slightly further and further off from what we said we had. What a tangled web etc…
Wouldn’t it be acceptable to do both?
Ist entry: I put the oil change (3L) in the sludge tank
2nd entry: Then I sounded the sludge tank and according to the table it has 3 cubes, just like it did before I added the oil.
I guess people want things done in different ways, but is it reasonable to do it this way?
Yes, sure is for the example you gave. Your system will depend your history with PSC. Bottom line can you reasonably, logically defend it?
Some guidance here
Since there is an, often misconstrued, assumption that ORB measurements are bookkeeping records (as in the dollars have to add up), rather than engineering measurements, very significant disputes can arise when the numbers do not appear to “add up”.
As such, a methodology needs to be established with regard to shipboard tank measurement and recording that passes appropriate and reasonable engineering standards, which then can be applied to ORB volumes.This document establishes such a standard.
Recording conditions truthfully in the ORB can never get anybody in trouble therefore do not interpret and adjust records to make the ORB look “nice”
Basically it says the standard is record to the nearest tenth. So 3.0 + 0.02 = 3.0
The information is +/- 0.4 at best but is recorded to the nearest 0.1 so that results in an inherent inconsistency:
Worst case volume transfer accuracies are expected to be in the range of +/-0.4 cubic meters (+/-0.2 cubic meters level measurement plus +/-0.2 cubic meter conversion accuracy) in optimal conditions (no seaway, etc.). At the same time it is known that measurement accuracies of 0.01 cubic meters are not achievable even on the smallest tanks.
The above indicates that measurement recording to 0.1 cubic meters accuracy is barely achievable, and that on tank volume records, depending on the tank and conditions, the last digit (representing a tenth of a cubic meter, 100 liters) is inherently questionable.
It does seem like it would be helpful to have written guidance aboard that people could follow.
Exactly. And always round off high especially if you have a tank you can boil. Much easier to explain why you have to much sludge in your tank than too little.
That’s right I think. Has to be quick and easy to defend successfully .
As an example our ship has about 700 heat/smoke detector heads in the car decks. They fail from time to time and this shows up on the display as a “fault”. When the car decks are full it’s not possible to reach them for service. So sometimes there are a few that are showing fault.
PSC sees this right away and starts asking questions, it takes a while to explain. The chief and I got tired of this and we created a procedure. As part of that procedure we said that up to 1% of the detectors in fault was considered acceptable. We used 1% because we knew we could meet that requirement without too much problem.
So now when PSC asks why two or three are in fault we show them a procedure that says up to 7 in fault is within specs. They just say OK and move on, they never ask were the 1% number comes from, it’s in writing and they just accept it.
If you take an estimated figure, multiply it with a factor and feed it into a computer, the result become gospel. (Nobody questions the Gospel, do they??)
With the fire detection system there was some ambiguity with regards to what was acceptable and what is not. Putting acceptable parameters (1%) in writing removed the ambiguity, it was plausible, and could be defended. Better than an ad hoc defense.
Likewise the instructions for the ORB are subject to interpretation by the crew, there is some ambiguity. For example there is a miss-match between the precision of entries compared to the possible errors in measurements of the actual tank contents. Well written instructions from a authoritative source that decreases the ambiguity might increase the odds of the ORB withstanding close scrutiny.
I wonder what’d happen if I said “the capt. signed it” … and looked glassy eyed ?
The inspector(s) would have to question the ruling authority first right? then later you may be involved it it was a major issue… by then you’d be off the ship maybe?