The management and control of marine pollution is steadily assuming a higher priority for ship owners and masters as governments, official bodies and politicians focus increasingly on MARPOL infringements and threaten key personnel with criminal prosecution.
However, the industry should not simply react to authorities’ requirements but take a positive approach to avoid damaging the marine environment during operations.   
Lloyd’s Register’s Alan Gavin and the UK P&I Club’s Karl Lumbers stressed these considerations in launching their joint publication, Marine Pollution Prevention Pocket  Checklist, at Lloyd’s Register in London on February 12th. 
The checklist provides practical advice for owners, operators and particularly seafarers to help them comply with the MARPOL Convention and prepare for Port State Control inspections----given a context of commercial disruption, fines and the growing threat of criminal proceedings against key personnel and the spectre of imprisonment.  
Mr. Gavin, Lloyd’s Register’s Marine Director, said PSC rankings provided the industry with a tangible measure of the quality of the world’s tonnage. PSC authorities had  become increasingly effective at squeezing sub-standard operators out of the market, particularly through targeted inspection campaigns.
The Paris and Tokyo Memoranda of Understanding and the US Coast Guard’s annual reports gave the industry an effective measuring stick for gauging performance and deciding on methods of improvement.
”However, marine pollution and the criminalisation of seafarers have become increasingly intertwined in recent months. Increased vigilance, particularly by USCG and European coastal state authorities, has revealed ‘magic pipes’ to bypass oily water separators and the falsification of oil record book entries.
“The operational, social and political realities of life at sea have changed dramatically and seafarers now work in an environment where they can go to jail if they make a mistake,” continued Mr. Gavin. “We are seeing masters, chief engineers and shore-based managers being charged with and convicted of criminal offences such as conspiracy and obstruction of justice.”  
In 2005, PSC found over 220 MARPOL infringements among vessels classed with Lloyd’s Register. The top 10 detention items related to oil filtering equipment (40), shipboard oil pollution emergency plan (SOPEP) (36), oil record book (27), 15 PPM (parts per million) alarm arrangements (23), retention of oil on board (22), other MARPOL Annex I (19), prevention of pollution by oil (IOPP Certificate) (18), garbage record book (17), garbage management plan (11) and oil discharge monitoring and control system (9). 
Mr. Gavin pointed out that Lloyd’s Register monitored its fleet’s PSC detentions to identify areas needing improvement. ”Since 2002, we have used this data as the basis of a comprehensive PSC benchmarking system and migrated the data to ClassDirect Live, our online class information system. This ensures  surveyors have up to date PSC information at their fingertips, providing the most detailed possible view of any ship they are about to board.”
The system allowed Lloyd’s Register to identify potential risks to the safety of the ships themselves and the personnel on board. “Where a confluence of factors might not individually be cause for alarm but together represent a significant risk, we are able to warn the owner and take action. For instance, a dirty engine room with flammable material close by, an unattended machinery space and an inoperable emergency fire pump would not necessarily pose substantial risks in themselves. Occurring at the same time and in close proximity, they would amount to a significantly hazardous situation.” 
Karl Lumbers, the UK Club’s Loss Prevention Director, emphasised that the UK Club supported the PSC system. However, lowering detentions was not just about cutting down on deficiencies but reducing environmental damage and insurance claims. “Class looks at environmental problems from a position based on rules and standards. Insurers focus on risk.” 
Pollution accounted for 18 per cent of all UK Club claims outgoings in 2005. Deficiencies with oily water separators were down from 30 in 2001 to 14 in 2006. However, other MARPOL deficiencies were up from zero in 2001 to 22 in 2006, an especially worrying trend as the increase in the past 12 months was considerable. Taken together, MARPOL and OWS violations were the most frequent reasons for UK Club ship detentions in 2006. 
“The variety of vessels involved in pollution claims in 1987-2004 is perhaps surprising,” continued Mr. Lumbers. “As might be expected, tankers featured in 46 per cent of incidents (24 per cent of Club entry). However, the claims were spread widely across the entire fleet, with bulk carriers (13 per cent) and dry cargo ships (10 per cent) prominent. 
“It follows that the sources of large environmental claims are also widely spread. Crude oil and fuel oil as cargo accounted for just under one quarter each, with chemical, clean and dirty products, dirty ballast, bilges and smoke appearing in the analysis. However, 33 per cent were down to bunkers. 
“This is highlighted by comparing the quantities spilled in 1990-94 with those in 2000-04. Pollutions of five to 1,000 tons have dropped dramatically from 59 to 16. Those under five tons have only eased from 53 to 49. This illustrates how important it is to guard against the smallest spillages. The authorities can be expected to target all incidents with increasing zeal, larger fines and, possibly, imprisonment for certain onboard and shore personnel.” 
Underlying causes of pollution incidents included failure and misuse of valves, overflows, defects in plate and pipes, hose rupture, contaminated bilges and faulty gauges. 
Mr. Lumbers stressed the importance of human error in causing large spills. Given their responsibilities, deck officers are most likely to commit the errors. They were at fault in 27 per cent of incidents in 1987-2004. However, taken together, crew, engineering officers, pilots and shore personnel slightly exceeded this figure. Further, 75 per cent of claims by value involved human error. 
 He concluded: “Deficiencies discovered by Port State Control should be seen in a wider context. Oil filtering equipment shortcomings mean pollution; an inadequate shipboard oil pollution emergency plan means a reduced capability to contain spills; and problems with the oil record books lead to fines and prosecutions. 
“The onus is on every ship owner and master to take a responsible and constructive approach in managing those operations which involve a risk of pollution. This checklist will serve as a practical aid for doing so.”