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Monday, December 18, 2017

The slop disposal conundrum

The lack of guaranteed slops and dirty ballast discharge facilities available to tanker operators at a reasonable price and able to accept a reasonable discharge rate is nothing new. INTERTANKO has long been pressing for Port States to honour their undertakings at the IMO. The EU Commission, assisted by EMSA, has been pushing some EU Member States to do what they have said they will do.

 

But the disposal of slops, often perceived as the owner’s sole responsibility, is actually a shared responsibility. Slops are but cargo residues, collected together into one tank and stored until a disposal facility is available. In a single-voyage-chartered ship the cargo residues belong to the ship once the single-voyage is over. But on a period-chartered ship the slops are the charterer’s property and responsibility.

Slops may be discharged by the ship correctly and in accordance with all regulations – but what happens to these slops after the ship has sailed? There have been some lingering doubts over what some slop disposal companies actually do with the slops. These doubts were reinforced by recent high-profile events in West Africa where the period charterer of a ship, claiming that the slops were allegedly discharged under the supervision of customs, port and environmental officials, has now filed a lawsuit against the disposal company, after eight people died and thousands suffered vomiting and stomach pains after waste was disposed of incorrectly.

In this sort of high profile situation, people are remarkably reluctant to find out the facts before pointing their finger – usually at the ship operator. Senior politicians are heard accusing the ship of “operating in an unethical and criminal manner” without considering that perhaps it is others in the chain of responsibility who have behaved in such a way.

Knee-jerk reactions - promises to upgrade implementation of EU legislation on hazardous waste transport … ports requiring declaration of waste for all tankers, and stricter enforcement of waste removal in some cases.

 

But if adequate, viable and accountable disposal facilities were provided at all the main discharge ports, especially those in Europe and in the U.S., then there would be no need for a tanker to carry an increasingly mixed bag of slops around with her, adding one more cargo residue to the mixture each time disposal is frustrated.

 

This situation also highlights the critical importance of accurate information being provided to the ship for all cargo – not just Annex II but also Annex I and bunkers – and therefore of a rapid adoption of the IMO’s Marine Safety Data Sheet requirements for Annex I cargoes at  MSC in December.

 

Contact: Bill Box