Disclaimer: these comments are based on one guys experience which was only on gravimetric and coalescing type OWS’s and older ships or carelessly designed ship - so perhaps these centrifugal separators if they are working so well will negate some of what follows…
Shedding light on the “problems” is not really an issue as you yourself have experienced.
See you are getting close to the answer right there.
Don’t get me wrong I wish you well shining a light on the problems.
The biggest problem is getting shipowners and the technical employees they hire ashore to realize this is not an OWS problem it is a system problem. That is to say achieving the goals of MARPOL is a “process” and so involves a system not a single piece of equipment.
This guy here came close to getting it right.
He’s going in the right direction system-wise but I found his section on “Human Factors” pretty much insulting to shipboard engineers. However, I did of course agree with this section:
It could be concluded that human factors issues are related to ship’s crews alone, but it is important to emphasize that this is not the case in OWS system operation and design. As an example, it is noted that Naval Architectural and Marine Engineering design curriculums completely ignore the existence of systems that serve the public. As such, a graduate Naval Architect or Marine Engineers will not have any education on the design of such systems. This has resulted in generally very poorly designed OWS systems aboard ships. Consequently, training on OWS and associated systems should extend from the designers through the shipyards through the engine room crews.
The majority of my working life was at sea and I’m sure my attitudes changed over time but I never saw it as an imposition to follow the law and not put oil in the ocean. Which is why I bristled at the authors twisted argument to prove engineers are taking the route of least resistance or need “extra” motivation.
Now this is an older paper, I finished up my at sea experiences on a very old ship and I don’t track ME/NArch training programs BUT I suspect looking at this as a process may not have gained wide spread acceptance just yet among owners and designers.
If regulatory bodies define an illegal discharge and snake oil salesman tells an owner this piece of equipment does that they don’t seem to want to make investment in tanks, heaters, filters, additional process steps etc. Just buy the one item, have it suck directly from the bilge and argue with the crew later about how it works and then blame them for when it does not perform or meet the goals.
I think there is a pot full of problems with IMO but in this specific case I’m going to give them the benefit of the doubt and believe they came to the limits according to some scientific thought process and probably some compromise between factions wanting higher and lower limits. What is the right limit is a separate discussion so I’m against adjusting the limits because its hard to meet with an out of the box OWS. Also because even on an ancient ship we were able to reliably operate a plant that could meet the limits. Took years of adding a tank here, pump there, filter here, drain segregation etc. but it can be done.
Legitimate questions can be asked as to what’s worth it and how enforcement could be used to level the playing field between those doing it right and those that only demonstrate they have the equipment aboard and an ORB that “proves” they’re golden. Subjected to PSC’s all around the world and its mostly a tick the box type inspection no real understanding of the process either. Understandable a PSC could take days if they got into details. But the questions or rather lack of questions really tell me they have bought the OWS is the only thing that matters hook, line and sinker. So is there motivation to do it the right way or not?
But hey back to IMO, how about when they made a new rule that OCM’s had to read emulsions as well as oil particles? The operational problems you bemoan were valid then as well. People standing on their heads to get these plants to work and then come out with that. Can’t make it over the existing bar so raise it higher? How about recognizing what is going on and assisting flag states with solutions then.
Of course tweaking design of OWS’s and OCM’s should continue - build a better mousetrap and they will beat a path to your door. But if that is the length and breadth of ones view I don’t think much is going to change for shipboard engineers.