We are all familiar with the criminalization of seafarers, all over the world, in particular with respect of this fine shipboard document, known as the Oil Record Book (ORB). For many years now, headlines read how this “hero caught this guy dumping oil into the sea” and such... What it usually means, is that a discrepancy exists in the ORB, which would suggest a possible pollution incident; not necessarily the action of dumping a pollutants overboard. Another words, successful prosecution are based on the Oil Record Book, and how it was falsified, in the assumed dumping of oily waste overboard.
Therefore seafarers, generally engineers, are parade as villains and hazards to humanity. With the resulting heavy handed penalties levied to the seafarer, and the ship owners - detentions, prison, probation, fines, and so on and so forth. Well of course, this depends on where you’re from, and whom you work for…
There is obviously a fair bit of monkey business going on, there is no denying that. The economic pressures are ever present, and some people somehow feel it necessary to pollute, and this is not acceptable as a society.
I felt compelled to write this entry, after reading one of our company's newest directive, and let out a sizable groan. Then there is also Transport Canada's new ORB instructions, all based on the guidance issued by the International Maritime Organization (IMO) – the worldwide regulating body of the marine industry - in their MEPC 1/Circ 736 bulletin, dated November 8th, 2010. This guidance bulletin is about the adopted changes in regulations, to the way shipboard operation with oil, and its by-products, are recorded vis a vis MARPOL.
The directive discusses the new changes adopted in October 2010, coming into force January 2011. Yes, bureaucracy suddenly moves pretty quick, so quick in fact that Transport Canada has not had a chance to print up new, official ORB, so the office tells me. In its place, they asked me to print some pages off my printer, and start using it as official logbook. Yes, can you imagine the look I would get, presenting a bunch of loose pages with scribble on it concerning oily waste, hell; I may as well just walk down to the gas chamber right now, and make it easy on everyone.
But I digress; I am not sure who came up with this stuff and the reason or background for this, but as I see it, they may as well print up a bulls eye on the neat "Year of the Seafarer" logo, because with all these tedious entry requirements, and the numerous possibilities for a mistake to be made, it is almost certainly akin to presenting a nice big chunk of juicy steak to a rabid hungry dog.
You know these rabid dogs, no, no, not the border people, the other cowboys, harmed to the teeth looking to be "hero", who already don’t hesitate to capitalize on simple mistakes. Hell, our internal auditors give me shit for the way the date was written: “not "March 28, 2011" but rather "28-Mar-2011" he tells me”.
I stand behind what I do and I have a reputation of being a little "earthly" to start with, you know us, "West Coasters" and our tree hugging reputation - which I don’t mind. Nevertheless, I am always uncomfortable dealing with this document, because history shows it's a nice easy way for "regulators" to get "trophies". Luckily for me, on this boat, we actually have very few processes, since we are a small boat, and land our waste. But I feel sorry for the poor schmuck, trying to explain his error in the official ORB, and having to understand these tedious regs, with a limited grasp of the English language to start with. With these new requirements, now in force, the inspector's job is getting easier to exercise their authority at whim; so I suggest you take special care when filling out the ORB. In some shady ports, already plague by deceitful regulator practices, you'd better request some extra cash or ample supply of Johnny Walker, because these things are going to push the thorn in our side a lot deeper.
I feel a bit jaded about these added regulations upon regulations on the shipping industry, more evident if you sail muddy waters like I am currently doing – competing with other forms of transportation. If governments are really concern about pollution, and they should be, please be balanced with the whole transportation sector.
While we watch our every move on board, fearing for incarceration and legal action at every turn, do you think the train engineer worries about the water running off his train. Does he walk the entire train, taking rain water samples for testing, after capturing it (VGP) and filling out a logbook weekly, does he catch all the drips of oil, record it every week and safely dispose of it at an approved facility. Are pilots held responsible for the handling of the fuel they take on, keeping samples on board and logging every drop into which tank (apart from the need to know your capability of getting there) they in the end, are the most prolific air polluters by ton of cargo moved. Same goes for the truckers.
Stringent regulation with a meaningful purpose, equally applied across sectors, is to be championed. I realize that ships move the large majority of the world’s cargo, remarkably, safely and by far the most efficient way, and therefore already with the lowest environmental footprint, so I guess that’s why its an easy target.
But we must have some common sense already! If there is such a fear of oil getting loose in the environment, then why not make it easy for ships to discharge their sludge or slops ashore. Ports were mandated to beef up all kinds of security measures, why can’t they be mandated to supply basic necessities of ships operations, clean potable water, solid and liquid waste infrastructure. It always ends up to the ship owner, and they in turn drill down on the crew; then everybody shrugs their shoulders when trying to explain the worldwide shortage of competent crew.
Happy Year of the seafarer to you; thanks for the new gifts, IMO. Anyways, I will step down from my soapbox now, but please have a look at the IMO bulletin for your own good.
Labels: criminalization, environment, IMO, Regulations, seafarers