Tip of the iceberg
Last week the IMO’s Sub-Committee on Implementation of IMO Instruments (III) met for its third session since the committee structure at the IMO was restructured in 2013. The sub-committee has less influence on shipping than many others but it is important in that it attempts to ensure uniformity of implementation in flag and port states of all IMO rules and regulations. One agenda item which has been a perennial cause for complaint was the adequacy of reception facilities at ports for vessels obliged to dispose of garbage, sewage, oil slops and hold and tank washings. All port states have an obligation to provide facilities and many make charges (often considered excessive) that are applied to all vessels regardless of whether they are used or not. There are also severe penalties applied to vessels that discharge waste at sea even when the facilities that are supposed to be provided are not in evidence giving no alternative. It is the lack of reasonably priced reception facilities that is frequently cited as the root cause of so-called magic pipe incidents. There has always been an opportunity to report inadequate facilities but many ships do not bother to do so, either because they see no point in it or because they fear retribution on future calls to the port. It is therefore not surprising that the number of inadequacy reports made each year is low. At this year’s III meeting, it was reported by the IMO secretariat that there were 86 complaints registered in 2015. Of the 86 reports, 63 referred to alleged inadequacies of port reception facilities under the requirements of Annex V only, five reports under Annex II and six reports under Annex I. Eleven reports covered more than one Annex and one report did not specify any waste type but stated that the port has no available reception facility. Tellingly the total responses from port States covered just 13 (15.1%) of the 86 reports on alleged inadequacies submitted by flag Administrations, implying the remaining 85% were ignored. Earlier this year, the introduction of new regulations requiring passenger vessels to dispose of sewage ashore was deferred because of inadequate facilities. Given the considerable history of the issue it is clear that figures reported are very much just the tip of the iceberg. This is important as the shipping industry is under constant attack for its apparent disregard for the environment and is regularly required to outlay considerable sums on equipment. Within a short period, the introduction of the global cap on sulphur will result in a massive increase in the amount of scrubber wash water and sludge that must be disposed of. If many decades of regulation have still not resulted in adequate facilities for oil and garbage waste, it is pie in the sky to think that the facilities for wash water will be provided in time. Image courtesy of IMO.