Proposal for Cross Disciplinary Investigation of OWS operational failures

1. Proposal for Cross Disciplinary Investigation of OWS operational failures SNAME T&R Ship repair and conversion committee Rik van Hemmen

2. OWS weirdness OWS are the first wave of a new type of shipboard equipment Before OWS, all shipboard equipment was designed to make the Owner money or to save the Crews’ skin OWS exist to protect the public; it doesn’t do anything for the Owners or the crew, but cause a nuisance Next are incinerators, trash separation, sludge incinerators, sewage systems, emission systems and ballast water management

3. What are Oily Water Separators supposed to do? • Required equipment under Marpol to prevent pollution • Allow vessel crews to separate water from shipboard generated oil/water mixtures • Perform this operation with minimal maintenance and crew attention

4. How should a vessel crew operate the OWS? • When there is a significant amount of oil/water mixture in the designated holding tank the crew should start the OWS • The OWS should run until there is no water left • The OWS will alarm and shut down • The crew logs the operation of the OWS in the Oil Record Book • Remaining oil waste is incinerated or discharged to shore

5. What actually happens? NOBODY KNOWS………..!?

6. Possible truths • A large part of vessel engine crews is pumping oil over the side without using the OWS • Some crews try to operate the OWS, but they don’t work as advertised and crews are decanting manually • Some crews keep the OWS in excellent repair, but don’t actually use it since they don’t trust it • The vast majority of crews use the OWS properly, but the USCG uses thin evidence to convict crews incorrectly

7. Why can’t we find the truth? • Crews are not talking • Ship owners are only getting partial information from the crews and have no real data on the effectiveness of OWS’s • There are too many OWS manufacturers and they themselves have only limited shipboard experience • OWS enforcement/conviction is politically popular • There are huge rewards for crewmembers who point the finger at other crewmembers • All technical evaluation is embroiled in adversarial criminal investigation processes

8. Have there been efforts to evaluate the technology? • The USCG has asked for public comment on OWS operating experience • There were about 35 published responses (some anonymous), but as far as is known, there has not been a review or report on these responses • There was wild variation in the responses

9. What needs to be evaluated on a technical level? • Do present equipment, installations and systems actually work? • If there is a working system how should it work and what does a working system look like? • Can present systems be improved? • Do we need to have an entirely new approach to Oil/Water mixture management? • Many other aspects of OWS design/operation

10. Proposed SNAME T&R involvement with this issue • Provide a neutral forum • Become a repository for information on the subject • Provide suggestions for improvements

11. Some suggested areas of investigation • Human factors (Human factors committee) • System design (Ship design committee) • Equipment design (Ship machinery committee) • Maintenance (Ship operations committee) • Conversion (repair and conversion committee)

12. Human Factors • Would well-paid union protected crew members violate the law? • What makes it difficult for engine room crews to use OWS properly from a psychological point of view? • What incentives can be provided to make engine room crews use OWS properly? • How can third world crews protect themselves against dishonest shipowners? • Is more or different training needed? • Go aboard and observe crews in action

13. Ship Design • Are ships properly designed to deal with oily waste? • Should the OWS be located in a different part of the ship? • Are the bilge and slop tanks located in the best part of the ship?

14. Ship Machinery • Do the OWS actually do what they are advertised to do? • How can OWS be altered to make them more user friendly to shipboard crews in the ship environment? • Is there other oil/water separation technology out there?

15. Ship operations • Ship’s crews are small and overworked. Let’s not make it worse • What should a properly operating OWS look like? • What is a proper OWS operating process? • What is a proper OWS maintenance routine? • What are “standard” waste oil generation rates?

16. Repair and Conversion • What do proposed changes cost? • When should proposed changes be made? • Are proposed changes realistic from a conversion/cost/schedule point of view?

17. What is needed to get this program to roll? • Formation of a multi disciplinary ad hoc committee • USCG and other regulatory agency support • Member support • A central organizing location (university?) • Money • Possibly a patent/reward system • Maybe an entirely different approach from that described above

18. A final thought Today there are crew members and owners who break the law, and who are being punished for polluting our oceans. At the same time there are almost certainly Crew members and Owners who are innocent and who are being unjustly punished. As Naval Architects and Marine Engineers let’s see if we can stop the guilty and protect the innocent