False oil record book entries

I can site a number of incidents where either the chief engineer or master is sentenced for a prison term ranging from a few months to few years.

I can also name many incidents where a company is handed over a fine ranging in millions of dollars.

I am talking about the incidents related to false oil record book entries.

Cases of false oil record book entries

What’s more !!! In 2016, Princess Cruise Lines paid USD$40 million as a plea agreement in respect of a number of US MARPOL violations. This is the largest ever criminal penalty involving deliberate vessel pollution.

Largest criminal penalty for mapol violations

That is huge amount of money.

In United state, involved of National whistleblower center has seen increase in number of reported Marpol violations.

National Whistleblower center

Port states these days consider the false oil record book entry as the “signed confession” by the person making the entry.

I am just trying to show here the seriousness of this matter. Usually the serious matters warrant serious measures. Not in this case.

In these cases, measures required are so simple.

To avoid these situation, we just need to ensure that we do not make any false entry and we do not violate Marpol.

But for Masters the situation is not that simple. Sometimes they may find themselves into these situations for no direct fault on their part.

This is simply because they are not involved directly with the engine room operations. And also because for Masters it may not be easy to verify the correctness of oil record entries.

But there are few things masters must do to avoid themselves from situations of false record book entries.

Master’s action would fall in two different categories.

  • Actions to prevent false oil record book entries
  • Actions on discovering false oil record book entries

Let us discuss both of these actions.

Actions to prevent situations of false oil record entries

We all have heard this phrase. “Prevention is better than cure”. 

As I would discuss later in this post, the actions required on discovering false oil record book entries are not so easy.

The best bet to handle false oil record book entries is to prevent these. Masters have an important role in preventing false oil record book entries.

The whole idea of prevention of these situation lies on masters being aware of what is required and then being situationally aware of what is going around on board their ship.

Let us see how this is done.

1. Verify the Seal record

Each company may have different methods to control the Marpol violations on their ships.

Control measures for Marpol Violations

Source: Gard P&I

But effectively sealing the carefully identified Marpol point is the most basic method that most of the companies use.

Most companies would require the ship staff to maintain a Marpol seal record which has the record of all the seals put on Marpol lines. These may include

  • Seals on OWS equipment
  • Seals on flanges of lines of the IOPP tanks
  • Seals on overboard valves
  • Seals on emergency overboard and suction line and valves
  • Seals on sludge overboard line, valves and flanges

Marpol seal record

This is the most basic version of Marpol seal record. Few companies require ships to maintain an elaborated seal record.

For example Fleet management has a good format of seal record. They also have the seal management in their PMS system.

Fleet management seal record

Most of the companies require masters to maintain this seal record. It is Masters who have the inventory of seals with them and it is Masters who issues the new seals to the chief engineer when required.

This puts the master’s role in the picture and masters must get themselves involved in ensuring compliance with Marpol.

As a first step, Master upon joining must personally check the correctness of this seal record.

Masters must also verify that the required locations are effectively sealed. By effective sealing I mean that it should not be possible for anyone to remove the seal and repaste it. Or it should not be possible to tamper the seal without anyone knowing about it.

But what if your company do not have the requirement of maintaining seal record ? Least a master can do is to suggest that to the company in the Master’s review.

2. Know the Amount of sludge produced

Masters must be aware of how the sludge produced is handled on their ship. The first step in doing that is to know how much sludge is suppose to produce and how much sludge is actually produced.

There is this 1% rule for the production of engine room sludge.

As per this rule of thumb, the sludge generation from purification of heavy fuel oil is usually not less than 1% of the total oil purified.

This 1% rule is used by many port state authorities specially German port state as the first sign of marpol related violations.

For example in one of the incident, German port state while inspecting a 100000 GT bulk carrier  Found the following facts

  • As per the 1% rule, the sludge generated should have been 15 Tons
  • As per the oil record book, only 2 Tons of sludge was generated in that period

German authorities use this as the first indication of detailed Marpol inspection. In this case bulk carrier was found to be violating number of aspects of Marpol Annex I.

Masters can use this 1% rule to check any irregularities in handling of sludge in engine room.

We must also keep in mind that it is not necessary that ship’s sludge production cannot be less than 1% of fuel oil used.

But it can is a good first indicator of some bad practices in handling of sludge.

Actions on discovering false oil record book entries

As i said earlier, actions in these cases are not so easy. I am being practical here.

But before we discuss that, first let us bring some clarity to the term “false entry”.

There are two type of entries that do not represent the actual picture or facts

  • Wrong oil record book entries
  • False oil record book entries

Wrong oil record book entry is unintentional. These are the entries that are either

  • not made in the format it is required by the rules; or
  • date entered is wrong but was unintentional; or
  • was the case of typo error

The action required in case of wrong entry is simple. Just ask the chief engineer to correct the entry by Code “I”.

But when we talk about false entry, it is meant to be an entry that is factually wrong and it made intentionally with full knowledge of the fact that he/she is making a false entry.

This is serious crime. Now let us divide the term “False entry” in two broad categories

  • Pollution false entry
  • Non-pollution false entry

Actions on discovering a Non-Pollution false oil record book entry

Non-pollution false ORB entry is the one where a false entry is made but there is no pollution involved.

Case : Transfer of Oily waters/Sludge from IOPP tank to non-IOPP tank

This could be one of the case where oily waters/Sludge is transferred from IOPP tank to non-IOPP tank and the fact is not recorded in the ORB.

There is no pipeline connecting IOPP tanks to a non-IOPP tanks. If this transfer was done, it has to be intentional and not by a mistake.

The transfer would most likely be with the use of welden pumps and loose hoses.

If this fact is not highlighted in the oil record book, this would be falsification of record with no actual pollution involved.

In this case Master must inform the company and ask the company to inform the flag of the vessel.

Company also need to advise the flag about the proposed remedial action and inform the flag again when remedial actions has been completed.

The email from the company to the concerned flag may look something like this.

Email to flag state for transfer of sludge to non iopp tank

Flag state would ask to make the entry about this transfer in the oil record book and send them the scan of this entry.

Chief engineer can then make the correct entry in the oil record book and send the scan to company. Company will send the scan of this entry to the flag.

On completion of the corrective action (Disposal of the sludge ashore), entry need to be made in the oil record book.

Master will forward to the company the scan of the oil record entry of the disposal of the sludge to shore facility.

Company need to forward this email from master to the flag as the evidence and confirmation of completion of corrective actions.

closure of notification to the flag

This communication with the flag can be kept in the oil record book for future reference. This will close the case with no further implications.

Actions on discovering a false oil record book entry that involves pollution

Now let us come to a case where some crew members are involved in the illegal disposal of the oil and in oil record book this disposal is shown as legal disposal.

On paper the action required from a master in this case looks too simple. Inform the company, inform the flag, inform the port state and do not sign the oil record book.

In realty, though these are absolutely correct steps but for a Master all these steps are not simple.

Master would be seen with a bad eye by everyone involved. Don’t be surprised if even the company want this matter to be buried. In this case master may find himself in the center stage of everything.

One thing that the Master must understand. When a master is aware of an illegal discharge and he does not inform and record this, he becomes the party to this illegal discharge. It is that serious.

But before a Master jumps to what is required, these are few things he must do.

Talk to chief engineer

One thing the master cannot afford is misunderstanding and mis-communication. It is so important to clarify the matter with the chief engineer.

Master need to be sure that there is actual case of Marpol violation.

Now let us see few cases which master can expect in these situations

Case: Chief engineer agrees to the Marpol violation with explanation

Chief engineer may agree that there is Marpol violation but has one of these explanations.

Explanation # 1

It is just the water with no oil content in it.

Explanation # 2

The water we are throwing out at sea without using OWS is cleaner that the ballast water you have been deballasting inside port.

Explanation # 3

Bilge water is generated from the muddy sea water and OWS gives alarm as OWS detects it as oil even when there is no oil in it.

Irrespective of how logical the explanation might look, the operation which is not as per MARPOL is illegal.

For example even if the bilge water is cleaner than ballast water, it need to be discharged through OWS.  This is because Marpol has set the conditions for discharge for bilge water and not for ballast water.

We are just supposed to follow Marpol and not question it.

Master in this case has to inform the company and company has to inform the flag. When such reporting originates as voluntary reporting by the company, more often than not there are no punitive measures taken by the flag.

For example, USCG has a voluntary disclosure policy where by there will not be any criminal proceeding provided

  • The disclosure is made to USCG voluntarily and
  • The disclosure is made within 21 days of discovery of marpol violation

Voluntary disclosure of Marpol Violations Conclusion

We all have a duty to follow rules and international regulations. Not out of compulsion but as a culture.

Other wise too, technology has made great advancements in the shipping and it is really tough to hide a violation. For example European ports uses cleanseatech to monitor the discharge of oil at sea.

Clean sea Net

CleanSeaNet is the satellite based oil spill and vessel detection service. This can detect even the minor oil sheen in the water and the alert reaches the authorities in less than 30 minutes.

On detection of a Marpol violation, Master will have a tough job. But they have to do it the way that is right.

Related Blogs

Follow us Today on
our social network

Capt Rajeev Jassal

About Capt Rajeev Jassal

Capt. Rajeev Jassal has sailed for over 19 years mainly on crude oil, product and chemical tankers. He holds MBA in shipping & Logistics degree from London. He has done extensive research on quantitatively measuring Safety culture onboard and safety climate ashore which he believes is the most important element for safer shipping.

Search Blog

6 Comments

saketh Reddi
saketh Reddi
Mar 29, 2019

Appreciate your lucid explanation to a topic that is seldom discussed but extremely important.

Ronald Ian A. Juntado
Ronald Ian A. Juntado
Feb 10, 2021

Good day sir, i have question. " How you will know/check if the ORB is falsified?

micheal pan
micheal pan
Jun 22, 2021

BE SMART AND BECOME RICH IN LESS THAN 3DAYS....It all depends on how fast  you can be to get the new PROGRAMMED blank ATM card that is capable of hacking into any ATM machine,anywhere in the world. I got to know about  this BLANK ATM CARD when I was searching for job online about a month  ago..It has really changed my life for good and now I can say I'm rich and  I can never be poor again. The least money I get in a day with it is about  $50,000.(fifty thousand USD) Every now and then I keeping pumping money  into my account. Though is illegal,there is no risk of being caught  ,because it has been programmed in such a way that it is not traceable,it  also has a technique that makes it impossible for the CCTVs to detect  you..For details on how to get yours today, email the hackers on : ( atmmachinehackers1@gmail.com ). Tell your  loved once too, and start to live large. That's the simple testimony of how  my life changed for good...Love you all ...the email address again is ; atmmachinehackers1@gmail.com

KETINA BARLEY
KETINA BARLEY
Jun 28, 2021

I want to say thanks once again to this great man called Dr Zuma and his spiritual way of helping people i lives in USA with my husband we love each other and also he care about me always look forward to make things easy for both of us 9 years after our wedding, we both work harder to make a family greatest surprise, we have a kid after some times again, we have another one so with this, we live in peace and he was so honest to me shortly, he started misbehaving that i don’t know what is going on then i asked him. Darling what is going on? you are so strange to me this few days hope i have not offended you? he said no. Not knowing he have an affair with one lady out side who promised him a car and apartment in one estate were i cannot see him also when he cannot see me i manage to stay with him pleading him he should forgive me if i have wrong him he started complaining he has no money that he has lost all his money in his business that he needs some money then i asked him how much is this money you are looking for? he did not know i can afford it. Then, he said $14,000USD i promised him i we give it to him just for him to care about his family. My greatest surprise, the next day, i went to work and our two kids were in school not knowing his going to leave the house before i come’s back i met some of his things outside i was waiting for him to come back he never come back i cried i miss him so much and he have taking all my money away i was only left with $800USD. One day, as i was ready a blog i saw a testifier made by someone in Australia called Jessica telling people about how this man call Dr Zuma helped her and the man’s contact email was there and his mobile number then i contacted him for a help and really, he brought back my husband now am so happy my brothers and sister if you are in such relationship problem kindly via Email spiritualherbalisthealing@gmail.com or Whatsapp +15068001647 Blog: https://spiritualherbal.blogspot.com he will help you solve all your problems.

Jessica Smith
Jessica Smith
Jul 13, 2021

After being in relationship with Wilson for seven years,he broke up with me, I did everything possible to bring him back but all was in vain, I wanted him back so much because of the love I have for him, I begged him with everything, I made promises but he refused. I explained my problem to someone online and she suggested that I should contact a spell caster that could help me cast a spell to bring him back but I am the type that don’t believed in spell, I had no choice than to try it, I meant a spell caster called Dr Zuma zuk and I email him, and he told me there was no problem that everything will be okay before three days, that my ex will return to me before three days, he cast the spell and surprisingly in the second day, it was around 4pm. My ex called me, I was so surprised, I answered the call and all he said was that he was so sorry for everything that happened, that he wanted me to return to him, that he loves me so much. I was so happy and went to him, that was how we started living together happily again. Since then, I have made promise that anybody I know that have a relationship problem, I would be of help to such person by referring him or her to the only real and powerful spell caster who helped me with my own problem and who is different from all the fake ones out there. Anybody could need the help of the spell caster, his email: spiritualherbalisthealing@gmail.com or WhatsApp him +15068001647 blog: spiritualherbal.blogspot.com you can email him if you need his assistance in your relationship or anything. CONTACT HIM NOW FOR SOLUTION TO ALL YOUR PROBLEMS

Mrs. Santana Valdez
Mrs. Santana Valdez
Aug 3, 2021

i am giving this testimony cos l am happy My name is Mrs. Santana Valdez from Houston,taxes.i never believed in love spells or magic until i met this spell caster once. when i went to Canada in June 28th 2021 this year on a business summit. i meet a man called Dr Zuma zuk.He is powerful he could help you cast a spells to bring back my love's gone, misbehaving lover looking for some one to love you, bring back lost money and magic money spell or spell for a good job. i'm now happy & a living testimony cos the man i had wanted to marry left me 3 weeks before our wedding and my life was upside down cos our relationship has been on for 2 years. i really loved him, but his mother was against me and he had no good paying job. so when i met this spell caster, i told him what happened and explained the situation of things to him.. at first i was undecided, skeptical and doubtful, but i just gave it a try. and in 6 days when i returned to taxes, my boyfriend (is now my husband ) he called me by himself and came to me apologizing that everything had been settled with his mom and family and he got a new job interview so we should get married..i didn't believe it cos the spell caster only asked for my name and my boyfriends name and all i wanted him to do. well we are happily married now and we are expecting our little kid, and my husband also got a new job and our lives became much better. in case anyone needs the spell caster for some help, email address spiritualherbalisthealing@gmail.com Great Zuma zuk i thank you very much thank you in 1000000 times.. if not you i would have been losted and wasted thank you. Email Him Through his email address... spiritualherbalisthealing@gmail.com please make sure you contact him for any financial difficulties okay...What a powerful man such as Dr Zuma zuk.. he is so much powerful..\\ email him for any difficulties.. spiritualherbalisthealing@gmail.com His whatsapp +15068001647

Leave Comment