It appears from this case that the engineers onboard had no idea that the new Oil Content Meters have a memory which records the start and stop times of the OWS. That’s apparently how the CG detected the illegal discharges. Really? Isn’t it widely known among engineers that the new OCM’s have this feature? Numerous reputable operators have been caught up in this. Mariner’s, what is the root cause of this overall problem and how have you seen it solved?
[QUOTE=LMR;66427]It appears from this case that the engineers onboard had no idea that the new Oil Content Meters have a memory which records the start and stop times of the OWS. That’s apparently how the CG detected the illegal discharges. Really? Isn’t it widely known among engineers that the new OCM’s have this feature? Numerous reputable operators have been caught up in this. Mariner’s, what is the root cause of this overall problem and how have you seen it solved?
I don’t know the root cause and I haven’t seen it solved. Staying safe at sea requires learning a routine by habit and sticking to it. However the rate of change of regulations has become very high. The cheapest way to try to get the ship’s routine changed is to send threatening emails to the ship with all the appropriate regulations sent as attachments. The effectiveness of this approach is likely very low.
On my last voyage with a U.S. ship with a U.S. crew and a load of U.S. military equipment I got an email from the COTP telling me that my ship was a threat to the security of the port and that if I failed to comply with the appropriate cfrs the ship would be seized (with it’s furniture etc ) and I was liable for fines up to $10,000 and up to 10 years in jail. Plus the threat of a delay or fine if the eNOAD is not sent on time or has errors and the redundant I-418. I being threatened if I fail to follow the instructions with regards to the Right Whales the EPA regs, STCW rest periods so on and so forth. As far as the oil record book goes I just sign it and hope the engineers go to jail if there are errors and not me as I have enough on my plate as it is.
It seems the number of regulations and the severity the fines is going up exponentially. Basically when I enter the U.S. to some extent I feel I’m rolling the dice.
K.C.
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[QUOTE=Kennebec Captain;66492]I don’t know the root cause and I haven’t seen it solved. Staying safe at sea requires learning a routine by habit and sticking to it. However the rate of change of regulations has become very high. The cheapest way to try to get the ship’s routine changed is to send threatening emails to the ship with all the appropriate regulations sent as attachments. The effectiveness of this approach is likely very low.
On my last voyage with a U.S. ship with a U.S. crew and a load of U.S. military equipment I got an email from the COTP telling me that my ship was a threat to the security of the port and that if I failed to comply with the appropriate cfrs the ship would be seized (with it’s furniture etc ) and I was liable for fines up to $10,000 and up to 10 years in jail. Plus the threat of a delay or fine if the eNOAD is not sent on time or has errors and the redundant I-418. I being threatened if I fail to follow the instructions with regards to the Right Whales the EPA regs, STCW rest periods so on and so forth. As far as the oil record book goes I just sign it and hope the engineers go to jail if there are errors and not me as I have enough on my plate as it is.
It seems the number of regulations and the severity the fines is going up exponentially. Basically when I enter the U.S. to some extent I feel I’m rolling the dice.
K.C.[/QUOTE]
KC,
Your point is very well taken. Many echoed your concern at the recent CMA event in Conn. With the impending implementation of new Ballast Water requirements and the implementation of MARPOL Annex VI(emissions) - which are long, complex regulations, in and of themselves - the problem you cite will only get worse. The challenge, I think, with all regulations, is for the govt and shoreside managers to boil the complex down to simple, workable procedures and giving the mariner good equipment that works. Operating a vessel is complicated and dangerous enough - overly complex requirements, which no one understands, sets mariners up for failure on many fronts. My 2 cents.
To address your specific question I have no experience shore side. However I think what I would do is hire from my fleet a very recently retied C/E that was skilled and highly respected in the fleet. I would visit the ships with that chief and learn what the routine was and check to see if the written procedures had been updated and if they are being followed. Basically do an audit with someone who knows what goes on aboard ship. I’d spend time with the engineers, have coffee with them etc and see what they are up against. In actual practice this audit will occur at crew change during bunkers and piston pull etc and therefore be of limited effectiveness. Might have to ride the ship for a few days.
I don’t know what it’s like elsewhere. I know where I work the demands increase with no corresponding increase in resources.
K.C.
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This thread is from 12 years ago,
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