Key Issues and Concerns

The following key issues and concerns are being addressed:

• Various drains in the Engine Room (ER) which drain/flow automatically into their receiving IOPP-listed tanks as well as non-listed tanks.
• Recording activities of such drains.
• Transfers of such drains to IOPP designated tanks by approved piping and systems.

The recording entries for transfer activities pertaining to IOPP and non-IOPP tanks are elaborated to provide enhanced clarity. Transfers which are without any pump (fixed or portable) and result from direct draining, draining, or manual transfer by gravity/overflow as per design are categorized as the direct flow-through method. Such transfers are not mandated to be recorded in the Oil Record Book (Part-I) and instead are required to be entered in the Engine Log Book and/or Sounding Log.Following instances of such drains are categorized into Case A and Case B:

Case A:

• ME Air Cooler Condensate direct drain to the Clean Bilge Tank/Clean Drain tank.

Case B:

• Direct draining/Filling up of FO Purifier Sludge Tank.
• Direct draining/Filling up of LO Purifier Sludge Tank.
• Direct draining/Filling up of DO Purifier Sludge Tank (if separate).
• Direct draining/Filling up of Sludge Tank (or any 3.1 tank) from the Incinerator Waste Oil Tank.
• Direct draining by gravity from ME Scavenge Drain to an IOPP 3.1 Listed tank.
• Direct draining/Filling up of ME Stuffing Box Drain Tank (Stuffing Box tank listed in IOPP 3.1).
• HFO/LSMGO/MDO Tank daily transfers to Settling Tank/Service Tank.
• Direct draining/Filling up of Wash Water into the Soot Tank during EGE water-washing.
• Direct draining/Filling up of FO Drain Tank by various FO leaks or overflows into the tank (as applicable).
• Direct draining/Filling up of FO Overflow Tank by various FO leaks or overflows into the tank (as applicable).
• Direct Draining by Gravity from any of Non-IOPP listed tanks (e.g., Scavenge Drain Tank, Stuffing Box Tank, FO Drain Tank) into the IOPP 3.1 Listed tanks (e.g., Oily Bilge Tank/Sludge Tank/Waste Oil Tank) by gravity/automatic drain/overflow.
• Filling up of ER Bilge Tank/Oily Bilge Tank due to condensate from evaporation.
• Filling up of ER Bilge Tank/Oily Bilge Tank due to overflow or drain from the Primary Bilge Tank.

• There is no recording requirements for these daily ingress of contents as mentioned for tanks listed above in Case “A” and/or Case “B”. Any abnormal leak in ER which impacts the IOPP tank contents may warrant an “I” entry and guidance must be taken from Tech department Office.
• The tanks if not listed in IOPP Listed 3.1 / 3.3 category tanks, are not required to be recorded in ORB. However, receiving tanks, if they are a part of IOPP, will reflect level rise during weekly ROB recording. Weekly entries will be required for all IOPP tanks. IMO-MEPC.1-Circ.736-Rev.2
• Any transfers done by Pump (Fixed or Portable) from non-IOPP tanks/sources listed in “A” and/ or “B” to other IOPP listed tanks (3.1 or 3.3) will be recorded mandatorily in ORB as per IMO-MEPC.1-Circ.736-Rev.2. In case of doubts, Office advice to be taken for such transfers recording.
• Any transfer done from tanks “A” i.e. clean drain tank/ clean bilge tank direct overboard, will be recorded in Engine Logbook as per EMS-05-06, in which separate guidance has been issued.

Master/CE are encouraged to approach Tech department for clarifying on any doubts with respect to recording.