Wondering if how vessels PICs are handling the Oil Record Book recordings in the US government printed 2016 ORBs? It appears that some of the examples they put in the instruction section conflict with MARPOL for machinery spaces. The show collecting waste oil from a machine and adding to a dirty oil tank as a C 12 operation rather than a C 11. MARPOL guidance shows these operation as C 11. I heard the ABS ACP surveyors have told Chiefs and Captains on vessels they’ve been inspecting not to use the examples in the ORB because they are full of errors. Can’t believe I’ve been using the wrong coding for 30 yrs. I don’t find anything on USCG website alerting or admitting to the errors in the ORB. Just wondering if other Chiefs out there have the same take on this and how they’re dealing with it.
That is some odd guidance, as C11 should be collection and C12 should be disposal.
While my experience is one-quarter USCG ORB and three-quarter Marshall Islands ORB, all inspectors I’ve dealt with from primarily Port State USCG and Flag MI, as well as class ABS and DNV, all seem to be focused on consistency. So long as you provide your officers with a template and hold them to it, such that all similar entries are made using the same coding each time, they tend to be content that you are in compliance.
If they provide differing guidance and a preference for recording a particular evolution with a particular code, and you are likely to be subject to their jurisdiction regularly, then it is in your interest to make note and consider making their preference your template.
For this exact reason the Marshall Islands provided the following guidance which I found useful in reconciling any difference between our consistent entries and the inspectors interpretation:
Choosing Entry Codes
- The Administrator recognizes that various vessel configurations and the vagueness of code and item definitions may lead to different ideas as to which code is to be used for a particular circumstance. A good faith entry made following these instructions and including a code letter, item number (clearly identifying the material), an accurate account of operations carried out, and which has all relevant required information provided, will satisfy the intent of the Convention’s Oil Record Book entry requirements.
It is recognized that the choice of code used is possibly subject to different interpretation by third parties, but that should not be considered a contravention or be grounds for adverse or punitive enforcement actions by port or coastal State Authorities.
My company had guidance provided for each entry with examples of each, both Deck and Engine. As long as you followed their write up, they would defend any issues that arose.
As stated above, consistency made things a little easier with the vetters - they were more in depth than the USCG ever was.
Same here, follow the provided company guidance and there’s no issue. ABS and USCG typically happy to see that there is something written in the ORBs. SIRE Inspector will spend an hour combing through I and II looking for nonsense.
SIRE inspectors need to justify their existence ($$) and since most of the actual major things are usually just fine, they need to go through nonsense like this to do so. Not saying it’s right or wrong but the fact that ORB entry standards are a constant headache with many different interpretations speaks for itself.
If the USCG or some other regulatory authority is going through your ORB for an actual investigation, whether your entries are under X category or Y category, are the least of your problems.
Worrying about the ORB entries is one of the things you do before you realize how things work.
It’s better to spend your time making sure it isn’t an exhibit in court.
I agree that actual problems have higher priority than keeping the paperwork in order.
That said, the issue is that keeping operations smooth and out of trouble requires the time and attention of the senior officers
.Time and attention is what’s scarce, issues with things like the ORB and PSC can turn into a real time suck.
Better to get PSC and others off the ship ASAP so the real work can get done.
As others have stated consistency and accuracy are more important than endless wrangling over entry codes.
I use two methods. If a proper turnover is performed I write a key using the previous officers coding and place it in the ORB at the date of my first entry.
If a proper turnover isn’t possible I make up my own key and place it in ORB with my contact information.
Eliminates timesuck completely. There’s nothing that goes in the ORB that shouldn’t be accurately logged anyways.
This bullshit went on for days.
First we got hit by PSC for using the C11.4 entry because it was not included in the instructions, so we stopped using it. Then we got hit in another port by PSC for not using the C11.4 entry.
After all that the company hit us up for getting hit on the ORB twice in a row. Clearly proof to them we were not taking it seriously enough.
A round the world trip takes the vessel through several different PSC regimes and each one is independent wrt frequency of inspections. So it’s possible to have several PSC visits on a single trip.
Why bother? You can’t be held responsible for whatever your relief did. It’s in his handwriting and signature. I always looked back to see what had happened but if something was wrong it wasn’t my place to fix it.
Consistency.
The idea is not to get out of trouble but to present a consistent oil record book to an inspector. I don’t care about getting in trouble. Inconsistency leads to time wasting more often than slightly incorrect coding.
ETA: The key is not to ‘fix’ something the previous officer did but to remind me of how the coding has been done.
Years ago during a CG inspection, I did get a comment on the ORB, I told him that I did it the way it was shown in the ORB, his response was” Did you follow the example or the instructions “
So the key doesn’t stay in the ORB when authorities look at it? Or does it? I can see if you wanted to make it up for yourself but I don’t know why an outside party would want to see that.
If it has my contact info it stays in there in case a subsequent officer has a question. It’s just a loose sheet of paper, not something written in the ORB so I don’t see why an authority would want to look at it but they’re welcome to.
I was going through a vetting a few years back. The inspector came into my office to go through NS5 and he saw the ORB sitting on the desk. He got this smug look on his face and said “I just came from a seminar where I was teaching a large group of USGC inspectors the ORB”. With an I just pumped the neighbors cat look on my face, I said very interesting… he then said “do you think I will find any errors in your ORB?”. At this point, I resigned to the fact that this was the direction the vetting was going to go so I just said "I’m sure you will, I’d welcome any input and started thinking when I was going home…
There are inspectors and surveyors that revel at the thought if finding any little thing wrong. . .
I prefer using the Intertanko book. I thought it did a good job of explaining the various entries and giving examples. Never had an issue with the USCG and we were on the enhanced inspection program because of the OWS.
It certainly isn’t cheap though: