Environmental compliance training

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ENVIRONMENTAL COMPLIANCE TRAINING
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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Course Objectives
Objective and Approach
The objective of this course is to ensure the proper understanding
The approach towards this presentation should be as the
and knowledge of the environmental requirements, to initiate
vehicle for all the facilitators and participants to lead and
discussion, to facilitate the exchange of ideas and experiences and
participate receptively to an interactive and interesting training
to conclude to a common ground, belief and attitude from all the
session that includes valuable information exchange and
participants regarding the Environmental Compliance.
personal development and improvement.
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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Environmental Compliance
Training (ECT)
For Masters and all Engine Officers
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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What is ECT?
Environmental Compliance Training - Initial
A systematic and controlled way for ensuring that all seafarers
meet or exceed the minimum requirements of the Company’s
Environmental Management System (EMS) requirements.
It consists of 3 different basic modules:
Environmental Compliance
MARPOL and legal environmental requirements
Handling of E/R Waste – ORB entries
This is module 1: Environmental Compliance Presentation
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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Training Agenda
1. Introduction
2. ‘I CARE’ and ECT
3. Background/History
4. Personal Conduct & Behavior
5. Communication Channels & Open
Reporting System
6. Engineering Requirements
7. Conclusion & Personal Commitment
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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1. Introduction
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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Why do we do this
training?
How do you think that this training would benefit you?
Why do we all devote time to it?
Why is it important for the Company and why for you?
To avoid similar cases in the future
To remember our values
To see where we stand
To discuss incidents and cases
To learn from past experience
To ensure continual improvement
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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Our mission
To keep our customers fully satisfied by managing and operating their
ships to the HIGHEST LEVELS OF QUALITY, SAFETY, ENVIRONMENTAL
FRIENDLINESS, ENERGY EFFICIENCY AND ECONOMY, in accordance
with their needs and expectations and in full compliance with
international and national legislation, as well as other industry
standards and guidelines, FULLY COMMITTED TO ZERO ACCIDENTS,
ZERO LOSSES, NO HARM TO THE ENVIRONMENT AND REDUCTION IN
PERMITTED EMISSIONS, and fully recognising the vital importance of
all our employees, ashore and onboard, in achieving this Mission.
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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EMS teams
The EMS teams meet quarterly, under the leadership of the
Environmental & Energy Management Representative to:
An Environmental & Energy Management System (EMS) Team for the office
• Discuss significant environmental aspects and areas of energy
use, relevant objectives, as well as the Environmental & Energy
Performance
and one for the fleet:
Monitor the results of the environmental programs and
propose corrective action if the targets are not achieved
Evaluate of regulatory, customer or supplier feedback
Assess new technologies available
Benchmark the environmental and energy performance across
the fleet and against the oil/marine industry as a whole (if
possible)
Assess responsibilities and deadlines
established and approved by the Top Management
consist of representatives from various departments nominated by their
Line Manager
are led by the Environmental & Energy Management Representative
The Company’s Environmental Compliance Manager is a permanent
member of both teams.
The EMS Teams will meet annually to review:
T a r g e t
The EMS-Teams are making sure all significant environmental aspects as
well as the significant areas of energy use are taken into account when
establishing, implementing and maintaining the Environmental & Energy
Management System (EMS).
M i n u t e s
Minutes of these meetings and relevant presentations are circulated to all
Company employees and have to be discussed during QIC Meetings
Revision of the Environmental Aspects and Impacts due to a
change in the:
Activities, products or services provided;
Legal and other requirements.
Evaluation of the program results to determine whether to:
Continue with the program;
Propose corrective action if the targets are not being
met;
Discontinue the program.
Proposal of changes to the system to Management as
necessary.
ashore, respectively HSE Meetings onboard.
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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TOP
ECM
Environmental Compliance Manager
MANAGEMENT
He shall have primary responsibility and authority for:
• Ensuring that the procedures and measures required by the EMS are established,
implemented and maintained
The Top Management of the Company is
appointing and authorizing a Senior
Officer as the Environmental Compliance
Manager (ECM), who irrespective of
other responsibilities is authorized to
ensure full implementation of the
Environmental Management System and
to report directly to the Top
Management.
• Monitoring the environmental compliance and pollution prevention aspects of the
operation of each ship
• Reporting to the Top Management on the implementation of the EMS, including
recommendations for improvement
• Liaising with those onboard ships and any external parties on matters relating to the
protection of the environment
• Ensuring that adequate training is provided to the employees ashore and onboard with
regards to the proper implementation of the EMS
• Ensuring the promotion of awareness for the marine environmental protection
requirements throughout the Company
• Maintaining an Open Reporting System (ORS) and ensuring that crew members are
informed of the availability of such ORS prior to each term of employment.
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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Values
What are your personal values?
Commitment
Trustworthiness
Patience
Respect
Solidarity
Accountability
Integrity
Altruism
Sustainability
Honesty
Generosity
Family
Consciousness
Consistency
Diversity
Compassion
Transparency
Team working
Authenticity
Equality
Social Responsibility
Determination
Excellence
Passion
Loyalty
Competence
Do these values drive your work also?
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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Discussion
• Are your personal values implemented on your work?
• Would you support your personal values even if your
choice isn’t popular and it puts you in the minority?
• Do you feel that if you did that you would endanger
your employment or be put in minority?
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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What are the Company values?
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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CSM values
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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Discussion
How do you feel about these values?
Can you remember examples where these values
apply?
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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‘I CARE’ & ECT
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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Does the ‘I CARE’ philosophy
relate to ECT?
What is the relevance of this philosophy to
environmental violations?
What are the values of the ‘I Care’ that
apply to the environmental Compliance?
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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COMMITMENT
I CARE PHILOSOPHY
How can commitment coincide with the
Environmental Compliance?
Are there ways to show your commitment to the
Environmental Compliance Requirements?
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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APPRECIATION
I CARE PHILOSOPHY
Can you think of personal actions that demonstrate
appreciation that can also be combined with the
Environmental Compliance Requirements?
Are these actions only addressed towards you or the
Company?
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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RESPONSIBILITY
I CARE PHILOSOPHY
Do you feel responsible regarding the Environmental
Compliance implementation?
How do you think you could demonstrate your feeling of
responsibility?
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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EVIDENCE
I CARE PHILOSOPHY
Do you think evidence is required when it comes to
the Environmental Compliance?
If yes, by what means and to whom should evidence
be addressed?
Is your personal attitude and actions part of the
evidence?
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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Personal Attitude
What is your personal attitude to the Environmental
Compliance?
Please discuss examples and cases that describe an
attitude experienced or witnessed that demonstrate
the previously discussed values.
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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Background / History
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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History
2012
2013
2012
2013
2014
‘10
ECP
Probation 4 years
CAPE TROY Incident
KING EMERALD Incident
CAPE MAAS Incident
NORDIC PASSAT Incident
2017
2018
2024
‘10
End of probation
period
I CARE
Revised EC Training
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
CAPE TAFT Incident
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History
Illegal discharges were made from KING EMERALD, CAPE
MAAS, NORDIC PASSAT, CAPE TAFT and CAPE TROY and Oil
Record book on the vessels were falsified in order to
conceal the illegal conduct
Several Chief Engineers and Engineering Officers and Engine
Ratings were involved in making intentional and illegal
discharges and deliberately falsifying the Oil Record Book
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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2012
KING EMERALD
• Government’s investigation was initiated as a result
of ship inspection on 7 May 2012.
• “Tricking” – The OCM sensor on the OWS was
“tricked” by flushing the sensor with fresh water.
• “Bypassing” – A “magic pipe” was fabricated and
utilised for bypassing the OWS and discharging oily
waste directly overboard.
• General Service and Fire Pumps were used for
discharging overboard oily bilge waters.
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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2012
CAPE MAAS
• Government’s investigation was initiated as a result of ship
inspection on 22 October 2012.
• OWS was operated with sampling line removed.
• “Tricking” – The OCM sensor on the OWS was “tricked” with fresh
water during overboard discharges.
• Oil Record Book contained numerous false entries.
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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NORDIC PASSAT
• Government’s investigation was initiated as a result of ship
2012
inspection on 22 October 2012.
• Portable pump was used for delivering oily bilge water from holding
tank to soot water system where from it was discharged overboard
via sewage system discharge piping.
• Oil Record Book entries of soundings in the Bilge Holding Tank were
false and fictitious.
• “Tricking” – The OCM sensor on the OWS was deliberately “tricked”
with fresh water during overboard discharges.
• Engine Room sludge was transferred to a Cargo Tank and this
transfer was not reported in Oil Record Books.
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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CAPE TAFT
• Internal investigation held on January 2013 revealed that the ship’s
2013
Oily Water Separator had been used improperly.
• Sample of overboard discharge was flushed with fresh water by the
crew and ship’s oil record book revealed 16 instances of falsified
information.
• CSM disclosed this violation to US authorities and this case was also
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
considered when decision regarding penalty and ECP was taken.
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2014
CAPE TROY
• OWS intermediate sensor was tampered on 18 November 2014.
• OWS discharge sample was diluted during overboard discharge on
25 November 2014.
• Bilge water was transferred to Grey Water Tank on 1 December
2014.
• The environmental breach was not registered as an incident in the
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
US records.
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Root Cause
The root cause of the incidents was the engineers’ willful
acts of misconduct in violation of Company policies as a
result of a combination of technical and operational
problems that were encountered prior to the incidents.
A failure of the ship command to manage those problems
in accordance with company procedures and regulations
appears to have contributed to the engineers’ decision to
attempt improper means of dealing with the problems.
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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Consequences
In order to avoid costly and endless trials with the United
States Government, a Plea Agreement was accepted by
the company
As a result, a 4-year probation, fines according to
Company’s financial capacity and implementation of an
Environmental Compliance Plan (ECP) to the whole
company, office and vessels were imposed
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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Personal Conduct
& Behaviour
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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Who drove over the speed
limit this weekend/today?
Who texted or talked on the
phone while driving this
weekend/today?
Who picked up a weight with
the wrong posture?
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
Speed limit
%
Cell phone
%
Weight
%
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Personal conduct
Do you think that your personal conduct
plays a role?
How can your behavior affect others?
Does it affect the Company?
There are two ways to influence human behavior:
You can manipulate it or you can inspire it
Simon Sinek (writer)
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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What would you do
in case…
A supplier offers you an expensive present
A superior officer asks you to violate
MARPOL
Someone asks you to share a Company’s
confidential information against a present
or a favour?
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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What would you
do with regard to…
Environmental Protection
Compliance with Regulations
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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Communication Channels & Open
Reporting System
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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Discussion
Do you think there are means to report any concern?
What are these means?
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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Communication Channels
Open Reporting
Report freely and even anonymously to the Company
any occurrences that are forming a violation of
International and National Rules and Regulations, as
Call, e-mail or SMS to the
DPA or ECM or the Top
Management (TM)
Third Party Hot Line
Raise the concern with the appointed
Third Party by sending an e-mail or
calling the Hot Line
well as the Company’s Policy
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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Other Communication Channels
Safety Observation
Near Miss Report
HSE Meeting
"Unsafe Act or Unsafe Condition" and "Good or Safe
Report unsafe acts and conditions
Discuss issues relevant to Health, Safety,
Practice" may be completed anonymously and
that form part of a Near Miss.
Hygiene, Environment & Energy and Quality
placed into an easily identifiable collection box.
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
and initiate actions for improvement
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Other Communication Channels
Inform the Master
Inform Head of
Department or
Superintendent
Vessel Debrief
Discuss issues that occurred on the vessel
during your contract
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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ORS Familiarization
01
03
05
Crew members and shore
staff are informed about
ORS prior to each term of
employment
Publications and
organization-wide
announcements issued on
at least a quarterly basis
Any concerns submitted will
be investigated and prompt
steps are to be taken to
resolve them
02
04
Notices for the ORS are
posted in lounge spaces,
Bridge, ECR, common areas,
etc.
Concerns can be submitted
via free mail or toll-free
phone
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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Open Reporting
System
Through the ORS, any shore side and vessel employee may
report any concerns or issues of non-compliance with the EC,
MARPOL rules, any other regulations or the Company’s
Policies.
Freely & Anonymously
Hot Line: +800-19293949
E-mail: [email protected]
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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Direct Reporting to Top
Management
[email protected]
Send e-mail
DPA or ECM Contact Details
Call, e-mail or SMS-texting
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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Open Reporting Rules
Failure to notify grounds for disciplinary action, which may
lead to dismissal and/or criminal charges, subject to
applicable labour laws.
CSM prohibits retaliation against those who report noncompliances
The DPA and the ECM shall be informed of each such Open
Report
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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2023
Illegal Discharge of Fuel Oil
to Shore
• A few days before the occurrence, upon Chief Engineer order, the
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
fitter fabricated a pipe connection of unconventional design. The
connection looked suspicious to him and he shared his suspicion
with some other ratings.
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Illegal Discharge of Fuel Oil to Shore
Upon Chief Engineer order, the
fitter fabricated a pipe
connection of unconventional
design. The connection looked
suspicious to him and he
shared his suspicion with other
crew members.
Shortly after the vessel was
berthed, two tank trucks arrived
and parked close by the ship’s
gangway.
A hose was arranged from the
top of the tank truck running
over the ship’s gangway and
upward to cross deck No.4 (in
way of bunker manifold) to pass
through the apparatus room
manhole.
On the ship, the hose was
connected to the
unconventional pipe connection
(fabricated by Fitter) that was
bolted on the top flange of the
bunker line filter unit after the
original filter cover was
removed.
The Chief Engineer and Second
Engineer jointly with the shore
personnel controlled the
discharge of fuel oil from the
ship to two trucks.
Consequences of the Incident:
• An unidentified quantity of fuel oil was illegally
discharged from the ship to a shore;
• Significant monetary losses for the Charterers.
Potential Outcome:
Cancellation of the charter and commercial
losses;
Damage to the Company's reputation;
Withdrawal of a vessel(s) from the Company
management;
Criminal charges against the offenders.
The Company has Zero tolerance for any forms of bribery or
corruption.
Any violations or illegal activities will lead to administrative
measures and potential prosecution against the violators.
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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Matters which may be raised under
the ORS
A crime is being, or has been,
committed, is suspected, or is
likely to be committed
Dishonesty, either verbally, written
or through intentionally
maintaining official log books or
records inaccurately
Non-compliance with legislation
and/or Company procedures,
particularly in relation to health &
safety at work, protection of the
environment and energy efficiency
Malpractice or unethical conduct
The environment has been, or is
likely to be, damaged
A breach, or likely breach, of any
legal obligation or regulatory
requirement
Miscarriage of justice
The deliberate concealment of
any of the above
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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Environmental regulations to be taken into consideration
MARPOL ANNEX I - Prevention of Pollution by Oil
MARPOL ANNEX II - Prevention of Pollution by Noxious Liquid Substances
MARPOL ANNEX III - Prevention of Pollution by Harmful Substances
MARPOL ANNEX IV - Prevention of Pollution by Sewage from Ships
MARPOL ANNEX V - Prevention of Pollution by Garbage from Ships
MARPOL ANNEX VI - Prevention of Air Pollution from Ships
SEEMP – Ship Energy Efficiency Management System
EU MRV – IMO DCS
EEXI - CII
VGP – Vessel General Permit
BWM – Ballast Water Management
BFMP – Biofouling Management Plan
IHM – Inventory of Hazardous Materials, Hong Kong Convention, EU - SRR
Other Port and Country environmental regulations
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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Notify - Report
If at any time, you know of, or suspect, any of the occurrences listed before, you must report the matter immediately to
the Company, so that actions can be applied to deal with it appropriately.
Failure to notify in these circumstances grounds for disciplinary action, which may lead to dismissal and/or criminal
charges, subject to applicable labour laws.
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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EC Declaration
Why do you think crew members must sign the
“Environmental Compliance Declaration” before joining
the vessel and upon completion of their contract?
What may be the consequences of failing to comply
with the policies and procedures mentioned in the
“Environmental Compliance Declaration” ?
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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Engineering Requirements
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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Environmental Seals – Tamper Securing
In order to prevent unauthorized by-passing of the OWS or other
equipment, the “Environmental Seals Handling and Tracking” is a
system of using non re-usable and uniquely numbered seals in various
positions in the E/R & Shore Connections
the C/E Environmental Seal
Log Book (CE-ESLB) for the
Engine Department
OR
the C/O Environmental Seal
Log Book (CO-ESLB) for the
Deck Department
The seals that the Master hands over
must be crossed out on the
Environmental Seals - Vessel Tracking
Document (ES-VTD)
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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Seal Types
Old Type
New Type
Plastic seal
Sticker
Steel
Is the primary type and intended for
To be used where fitting of plastic seals is
To be used on piping flanges with
general use of sealing piping flanges,
impossible, such as:
sealing pipe couplings of small diameter
that cannot have rings welded on
to seal closed the OCM and other electric
equipment
high temperature, where a plastic
blank flanges, valve wheels, etc.
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
seal would melt (e.g. the boiler blow
down pipe)
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Seals location
Where should the Seals be placed
Any overboard valves connected to
ejectors situated in compartments such
as but not limited to steering gear,
bow/stern thrusters, and compartments
such as the Bosun store forward, pump
rooms etc.
Piping connections, fittings, the
OCM, and other control equipment
of the OWS
System crossover and connection
valves where bilge systems tie into
ballast, general service and other
pumping or ejector systems, and
systems capable of bilge removal
without the use of the OWS
Every blank or potentially removable
flange associated with any piping
leading overboard
Sludge and dirty oil tanks manholes in
engine room spaces and all attached
level, temperature and other removable
accessories fitted to them as far as
practically possible
On Tankers:
Blank flanges on the bilge, sludge and sewage transfer
• MARPOL Annex I and II overboard discharge lines
system manifolds for transfer to shore reception to be
• Entire piping system including flanges and valves
blanked and fully bolted when not is use.
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
connected up to the ODME.
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OWS & OCM
Tamper Securing
The OWS and OCM must be made tamper proof
to ensure that no bilge water is discharged
overboard deliberately or inadvertently.
The sample line from the OWS discharge
connection to the sample /flush line
control valve must be painted red to
distinguish it from other tubing and
piping.
The end nearest to sample/flush line
control valve and any tubing in between
the control valve and OCM must be
protected to prevent any disassembly of
the sensing system.
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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Instructions of Seals use
Flange connections and blank flanges should be
assigned a number based on the piping diagram.
This number should be entered in column ‘SEAL
POSITION’ of the CE-ESLB
A
B
Affix seals so that the seal will be broken if bolt
removed or if valve operated
B
Affix
C
Used seals
C
Used Environmental Seals (all types), which have
been removed (or broken/damaged) must be
handed over to the Master by the C/E and the C/O
and be registered in the Used Seals Log.
D
Worn seals
A
D
Number blank flanges
Worn seals which are lost in tanks or bilges and
cannot be retrieved, must be reported to the
Master by the C/E and the C/O, and he will register
relevant comments in the Used Seals Log.
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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Breaking the seals
What are the reasons and
circumstances that allow
the breaking of seals?
Routine Maintenance
Class / PSC Survey Requirements
Repair Works
EC Auditing Process
Normal Discharge
Emergencies
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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Master
Responsibilities
Maintains replacement seals in a secure location
Verifies that seals do not have duplicate numbers
Maintains the Environmental Seal Register (ESR)
The new seals, handed over each time, must be crossed out on
the Environmental Seals - Vessel Tracking Document (ES-VTD)
Receives the worn or damaged seals, makes a relevant entry in
the Used Seals Log (USL, form GOF-7.3) and places them in a
dedicated secured place
Ensures proper handover of the used and unused seals, the ESR
and the ES-VTD to the new Master
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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Master Responsibilities
Environmental Seal
Register (ESR)
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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Master Responsibilities
Environmental Seals Vessel Tracking
Document (ES-VTD)
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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Master Responsibilities
Used Seals Log
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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64.

Chief Engineer
Responsibilities
Receives the seals from the Master and places them in identified places without
delay
Maintains the C/E Environmental Seal Log Book (CE-ESLB), properly recording
the date, time, seal numbers and persons involved in placing or removing seals
Gives numbers to all flanges with seals starting from discharge of pump or
equipment and ending at overboard valves
Maintains ship’s piping plans with location of seals
Keeps ORB records
Hands over to the Master any worn or damaged seals and reports if any cannot
be retrieved
Ensures that relevant records are retained on board for at least 3 years
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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65.

Chief Engineer Responsibilities
C/E Environmental Seal Log
Book (CE-ESLB)
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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66.

Chief Officer
Responsibilities
Receives the seals from the Master and places them in identified
places without delay
Maintains the C/O Environmental Seal Log Book (CO-ESLB),
properly recording the date, time, seal numbers and persons
involved in placing or removing seals
Identifies valves and flanges that need to be sealed and gives
seal numbers
Hands over to the Master any worn or damaged seals and
reports if any cannot be retrieved
Ensures that relevant records are retained on board for at least 3
years from the date of the last entry
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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67.

Chief Officer Responsibilities
C/O Environmental Seal Log
Book (CE-ESLB)
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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68.

Emergency Bilge
Suction Valve
• Bilge suction valves not connected to bilge
main & Independent emergency suctions to
E/R bilges, like those which may be connected
to sea water pumps, must be painted brightly
(signal red) and labelled “Emergency Bilge
Suction – Emergency Use Only”
• Valve wheel to be sealed with
Environmental Seal, capable of breaking, in
case of emergency, testing or maintenance
– Use of seals to be logged
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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69.

Cross Connection
Valve Marking
Use of cross connections and any
other system capable of pumping out
the bilge water and wastes, for any
reason other than emergency, is
prohibited!!!
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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70.

OWS / OCM Testing
03
Pre-operational Test, for at least 15
minutes, via recirculation is required
prior any normal operation
Monthly operational tests of OWS &
OCM under actual operational
conditions (if possible) for 15 minutes
continuous processing of the
contents of the Bilge Holding Tank
Annual Test
02
Monthly Test
01
Pre-operational Test
Annual operational test of the OWS & OCM for
at least 1 hour of continuous operation by the
C/E and any involved E/R personnel, in the
presence of a Technical Superintendent (TSI) or
a Third Party Auditor (TPA)
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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71.

OWS / OCM Testing
During operation or testing, set points of
any alarms related to oil content or
sample flow MUST NOT be modified
WITHOUT COMPANY’S EXPRESS
WRITTEN PERMISSION
Sequence of entries in the ORB
for testing prior discharging
through the OWS:
Code I: Test of OWS and OCM for 15 minutes via recirculation
Code I: Unsealing of the OWS Overboard valve
Code D 13, 14, 15.1: OWS normal operation
Code I: Sealing of the OWS Overboard valve
Records of the tests shall be kept in the
ORB
Code I: Above overboard discharge via OWS carried out as
monthly (annual) OWS test
A copy or a photograph of the E/R alarm
printout to be retained and appended in
the ORB page documenting the test
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
Entries must be made in the CE-ESLB and the used
seals must be handed over to the Master
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72.

Criteria of satisfactory OWS/OCM test
1. Absence of alarms (Long run alarm, Motor overload alarm, Oil
alarm, etc.)
2. Effluent and sample flow are continuous remain within
normal operational limits set by equipment manufacturers
3. System components function and operate within the
parameters and without abnormalities
4. Sample reading remains within the range and inconstant
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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73.

Portable Pumps
The pump to be secured with a chain lock and key to be
kept by the C/E
The chain lock to be fitted with a seal and relevant entry
to be made in the C/E’s Environmental Seals Log Book
The pump may only be used with the express
permission of the C/E
Date, time and person who performed task to be
recorded in the E/R Logbook and in the ORB (if
applicable)
Take photographs of the pump when in service, for
objective evidence of its use. Photos to be retained by
the C/E
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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74.

Logs
What are the log that you should keep?
E/R Bilge & Sludge Tank
Sounding Log
• Maintained in the ECR for at least three (3) years
• Completed and signed by the officer or rating
who takes the soundings
• Twice per day at 08.00 and 17.00 hour
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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75.

Logs
What are the log that you should keep?
Leakage Log MSOF-11.5
• Any time, a line or component on a fuel, lube or
waste oil system fails, including high pressure
lines on diesel engines
• A notation as to the quantity released and an
explanation on how the unintended released fluid
was handled
• Unintended releases of salt or fresh water,
condensate or cooling fluid shall be recorded
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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76.

Logs
What are the log that you should keep?
Oil to Sea Interface Log
MSOF-10.4
• Any replenishment of oil into the head tanks, operating
systems reservoirs or other receivers associated with this
equipment shall be logged, regardless of the quantity
involved
• Any ingress of water or drainage of water into or from these
systems must also be logged
• Stern tube lube oil loss
• Log to be sent to ECM and TSI at the end of each month (even
if no entry is made)
• Accidental oil loss or water ingress must immediately be
reported to the ECM and TSI
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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77.

Logs
What are the log that you should keep?
Fuel Oil and Lube Oil
Management Log MSOF-9.4
• The operation of all purifiers on a monthly basis
• Installation of hour meters on purifiers motor controllers
• Records for incidents involving poor quality fuels
• Extraordinary operations (such as frequent draining of FO
service and settling tanks, draining engine LO sump tanks of
excessive water, waxing, compatibility, stratification or
contamination, etc.) shall be recorded in the ORB part I
• Explanations for the handling of unburned oil residues
(sludge), oils, oily wastes and used filters
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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78.

Environmental Compliance Assessment
When?
• On taking delivery of a new vessel under management
• jointly with attending TSI and/or MSI
• One month after embarking the vessel
• Prior arrival to any US port
• Latest four months after the previous assessment
• EC Assessments are also performed during TSI visits on board
Who performs the assessment?
• The Chief Engineer in his role as Environmental & Energy Officer
Who supports the Chief Engineer?
• Master
• Chief Officer
• Second Engineer
Whom to send the assessment (GOF-7.8)?
• TSI
• DPA
• ECM
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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79.

Environmental Compliance Assessment; Guidance
• Complete and submit the Assessment using updated version of GOF07.8 in word format
• Refrain from trying to format or edit the content of the form.
• Do not try to remove the password protection
• Ensure that all items are answered truthfully and accurately
reflecting the actual status of the assessed subject
• Make sure that the “clarification field” for applicable items, shall not
be left blank
For every item marked “NO” ;
• Insert a comment in the relevant section
• Enter the respective requisition number required to be supplied
• Specify a target date for item requiring a rectification, in agreement
with the responsible TSI. Avoid using uncertain time in the future
such as “unknown”, “nearest future”, “next convenient port”
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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80.

Personal Commitment
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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81.

Personal
commitment
What is your personal commitment?
Please write down the action that you will be
committed to after this training (anonymously)
Try to include the reason why
Place the cards into the box/onto the desk
Each card will be then read out loud
At the end you will vote/clap for the most sincere
or ‘touching’ one
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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82.

Personal
commitment
The best personal commitment note said:
…………………………………………………………………………………..
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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83.

It is not about following blindly orders!
It is about believing in the true values!
It is about….
Personal Commitment
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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84.

Thank you for your
attention
Any questions?
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024
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