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Marpol Annex III -Harmful Substances carried at Sea in Packaged Form

Annex III Marpol 73/78 (Harmful Substances carried at Sea in Packaged Form : This Annex came into force internationally on 1July 1992. It contains regulations which include requirements on packaging, marking, labelling, documentation, stowage and quantity limitations.

It aims to prevent or minimise pollution of the marine environment by harmful substances in packaged forms or in freight containers, portable tanks or road and rail tank wagons, or other forms of containment specified in the schedule for harmful substances in the International Maritime Dangerous Goods (IMDG) Code

There may be following sources of pollution (on containerships):

A) Pollution from hold bilges (contaminated with cargo / oil seepage)
b) Pollution from loss overboard of harmful packaged goods (Marine Pollutant as in IMDG Code)

Handling Cargo Hold Bilges on Container vessels

Hold bilges must be sounded at least once daily and also checked for content on the sounding rod (this will indicate if any oil or cargo effluent exists, mingled with water). They must be pumped out, when well within the bilge well depth.

If vessel is in port, bilges should be transferred to the bilge holding tank (where fitted), but if reached tank top level (due rain), then pumping out must only be done after visual check inside hold for uncontaminated of water.

Handling Bilges from other spaces (but, non E/R)

Bilges need to be occasionally pumped from other spaces like Bow thruster room, Bosun store, Void spaces, Cofferdams, Steering flat, Under Deck Passages, etc. In all such cases, they must be only pumped out at sea after confirmation of contents.

Handling of Harmful Packaged goods

If any Marine Pollutant (as per IMDG) leaks from a container into the hold bilges or on deck, it must be collected taking due precautions, as per EMS and disposed off ashore. Accidental loss overboard of containers must be notified to shore authorities, also mentioning the nature of contents esp. if they are a Marine Pollutant. Handling Chemicals and Hazardous waste)

Note : Residues of chemicals, paint and other items used on board for operational purposes, must be disposed off ashore and recorded in Garbage Record Book.

Disposable cargo

Crewmembers should remember that cargo hold wash water from holds containing Harmful to the Marine Environment (HME) cargoes can only be discharged provided that the master determines that there are no adequate reception facilities at the receiving terminal and the ship is en route and as far as practicable from the nearest land, but not less than 12 nautical miles.

Before washing, dry cargo residue should be removed (and bagged for discharge ashore) as far as practicable and holds are swept and the volume of wash water used should be kept to a minimum. Moreover, filters should be used in the bilge wells in order to collect any remaining solid particles and minimise solid residue discharge. Lastly, the discharge should be recorded in the Garbage Record Book and the Flag State is notified utilising the Revised Consolidated Format for Reporting Alleged Inadequacies of Port Reception Facilities.

Fire and safety

It is particularly important to ensure that procedures are in place to deal with an outbreak of fire and these should include:
  1. The provision of fire-fighting equipment (as required by flag state, local and/or national regulations) in properly maintained and fully operational condition.
  2. The provision of instructions for emergency routines and the regular practice of such routines.
  3. The ready availability of fire fighting apparatus layout and cargo plans to both ship and shore personnel.
Explosions can occur with substances other than those classed as explosives with varying degrees of violence. Where such a characteristic exists, care should be taken to fully comply with any recommendations regarding stowage. Additionally, an explosion would almost certainly be followed by a fire.

When IMO Class 1 or Class 3 cargoes are being handled by mechanical equipment, such equipment must be made safe to operate in the vicinity of such cargo, e.g., electric motors must be spark-proof.

Related articles

  1. Marpol annex I - Preventing pollution by oil -Notes on Oily Water Separators

  2. Marpol Annex II -Noxious Liquid Substances in Bulk

  3. Marpol annex III -Pollution by other harmful substances & harmful packaged goods

  4. Marpol annex IV - Prohibition on Sewage Discharge

  5. Marpol annex V - Pollution by garbage

  6. Marpol annex VI - Pollution by air

  7. Prohibition on use of harmful (TBT) anti-fouling paints

  8. Pollution by ballast water

  9. Prevention of pollution while carrying out overboard maintenance

  10. Environment friendly purchasing

  11. Environmental awareness

  12. Burning of heavy fuel oil & diesel oil - Environmental impacts

Preventing air pollution various guideline:

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