Investigating Shipping Pollution Violations

1. Investigating Shipping Pollution Violations Pacific Module 11: Sampling

2. Aim • To describe the steps required to obtain high quality and valid samples, and maintain their integrity

3. Overview of Module • Why Sample • Guidelines and Standards • Pre-planning • Sample types and collection • Environment Samples • Suspect Samples • Handling, Chain of Custody, Transport • Laboratory

4. Why Sample? • Identification of the “responsible party” or source of an oil spill incident • Investigation and/or cleanup response • Recover cleanup costs or for enforcement action • Collect samples to • determine it is oil • compare with potential suspect sources • identify the source or polluter

5. International Guidelines/Standards • IMO Guidelines for Sampling and Identification of Oil Spills • Section VI: Manual on Oil Pollution (1998) • INTERPOL Investigative Manual • ‘Illegal Oil Discharges from Vessels’ • Section 6.4: Sampling • Regional/Domestic procedures

6. Pre-planning • Investigating Agency should have access to pre- planned sampling kits • Kits should at least include • Prepared sample jars (clean or sterilised various sizes) • Polymer sheen nets • Nitrile gloves • Paper towel • Wooden tongue depressors or swabs • Sampling logbook • Chain of custody forms • Tape, twine and labels, permanent marker • Other useful items/tools

7. Sample types • Three types of samples: 1) Environment Samples (oil slick, oiled sand, oiled feathers, tar balls etc) 2) Suspect sources (vessel waste oil tanks, bilges. neat oil, multiple vessels, pipelines, factory outlets, shore tanks etc) 3) Reference samples(unpolluted water outside the slick, vessel unused fuel oil, unoiled feathers etc) • Samples should be obtained as soon as possible • Petroleum is a complex mixture of many different chemical components • Spilled oil begins to “weather” • Impossible to collect sample at later date

8. Weathering of oil at sea - Processes • Evaporation • Dispersion 3. Sedimentation 4. Emulsification

9. Collection of Samples • Avoid contamination • Wear gloves once and discard • Collect 10 to 200 mls • depending on size of bottle • Collect duplicate samples • may be required by law in some jurisdictions

10. Environment Samples • Fill sample bottles appropriately • ¾ full if expansion is likely • Collect multiple samples from the spill area • Oil on water • Oil, oily water, heavy emulsified oil, tar balls, lumps on water surface • Take samples from water as soon as possible from the heaviest oil accumulations in a number of locations • Invert sample bottles into oil and gently open lid to allow water to escape and repeat as necessary • Sheens on water • Utilise either TFE fluorocarbon polymer bag/net/sheet to absorb the sheen from the surface of the water

11. Environment Samples • Oil on beaches • sand, pebbles, tar balls, oiled coated debris • Place or scoop inside a sample bottle or evidence bag and seal

12. Oil on animals • Remove oiled feathers or cut sample of oil fur etc and place into sample bottle or evidence bag • Dead oiled birds or animal may be put in plastic bags, labelled and frozen

13. Suspect Sources • Essential to identify suspects and take samples from ALL potential suspect sources • All vessels known to be in the area at the time • Note type of vessel and collect samples from all tanks including fuel tank, day tank, cargo tank, waste oil or slops tank, bilge and bilge wells etc. • Collect samples from other possible sources such as pipelines, factories, shore tanks etc • Do not eliminate sources by appearance or color of the oil

14. Samples from Vessels • A PSC Officer or marine surveyor should be part of the investigation team • familiar with vessels and can examine relevant documentation to identify where samples are taken onboard the vessel

15. Sampling onboard • Take photographs of the sampling activity • Check levels and contents of all tanks etc and record this information • Do not accept samples taken by the vessel crew unless you have supervised the sampling task

16. Samples from Vessels • Samples are likely to be taken from • Tanks, bilge wells or holding tanks including ballast tanks and sewage tanks • Overboard discharge pipes • Take multiple samples from each sampling point in accordance with your country’s procedures • Ensure samples are representative of the tanks contents • Samples may need to be taken from various depths within the tank (ie top, middle, bottom)

17. Precautions on Vessels • Avoid collecting samples from any location which may be a ‘confined space’ • Confined space entry requires specialized training, specialized detection tools, and specialized personal protective equipment • Without specialized training, detection tools and PPE, do not enter confined spaces

18. Handling Samples • Identify all samples by unique number and write all relevant details on the label on the sample bottle (date, time, location etc) • Use unique numbers consistently on all records • Store locked in cool dark location (2° to 7°C is optimal) • Do not allow samples to freeze • Transport samples to laboratory for analysis as soon as possible

19. Chain of custody • Chain of Custody must be completed and continuously maintained from the time the samples are taken and within the laboratory • Careful container and lid markings, container labelling and records • Samples must be kept in a person’s custody or possession under surveillance or under lock and key where they cannot be tampered

21. Transporting Samples • Ensure transport container meets applicable requirements pursuant to ‘Transportation of Dangerous Goods’ regulations

22. Requesting Laboratory Analysis • Laboratory should be authorised or designated by legal system or requirements or seek assistance from another country’s Laboratory • When sending samples to the laboratory • Prepare a request letter • Include relevant paperwork • Advise the laboratory samples are to be delivered • Provide relevant information with the samples such as weather conditions, air temperature possible contamination of the sample etc

23. Laboratory Data Analysis • Utilises recognised international standards • Categories of spill/suspect oil matching using diagnostic biomarker ratios: • Positive Match • Probable match • Indeterminate (Inconclusive) • Non-match

24. Laboratory Analyst Report • Report should have concise statement of the “findings of the investigation” not just data tables • Copies of chromatograms/ion traces and tables of diagnostic ratios • Description of the differences in oil/spill samples eg contamination or weathering if applicable • Report states Chain-of-Custody • Include photos of spill samples, tags, etc. • Must be signed by analyst

25. Laboratories AUSTRALIA: Leeder Consulting Pty LtdForward samples - Attention: Laboratory Manager Melbourne Office & LaboratoryUnit 5, 18 Redland DriveMitcham Victoria Australia 3132Telephone: 61 3 9874 1988Facsimile: 61 3 9874 1933eMail: melboffice@leederconsulting.com

26. Questions?