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1. Effective 1 January 2011, is it necessary to change the Oil Record Book since the ‘List of
items to be recorded’ is amended?
Ans: There is no need to change the Oil Record Book. However, a printout of the relevant pages
from MEPC.187 (59) should be attached to the ORB.

2. Is it necessary to write the entries in the format as specified in MEPC.1/Circ.736 Guidance

for Recording of Operations in the Oil Record Book Part I – Machinery Space Operations (All
Ans: YES. In addition to the above, if any guidance is provided by Flag State, Owners and
AESM, it is also required to be followed.

3. Does the Chief Engineer need to countersign each entry?

Ans: All entries are to be signed by the officer or officers in charge of the operations concerned.
Each completed page shall be signed by the master of the ship. However, as per company policy
each ORB entry will need to be checked and counter signed / initialed by the Chief Engineer.

4. If sludge is burned in the boiler, is the entry to be made under C 12.3 or C 12.4?
Ans: The entry is to be recorded under C 12.4. However, item 3.2.2 of the supplement to IOPP
certificate should allow for this type of disposal operation. C 12.3 is to be used only for
incineration in an incinerator.

5. Are the entries under C 11.1/11.2/11.3/11.4 to be made weekly only for particular tanks?
Ans: NO. C 11.1/11.2/11.3/11.4 entry is to be made as and when oil residue (sludge) is
transferred by ship staff mainly by pump (not automatic) into the oil residue (sludge) holding

Examples of such operations could be (but not limited to):

 Collection of oil residue (sludge) from fuel oil drain tanks.
 Collection of oil residue (sludge) by draining engine sump tanks.
 Adding fuel oil to an oil residue (sludge) tank (all content of a sludge tank is considered
 Collection of sludge from bilge water holding tanks – in this case a disposal entry for bilge
water is also to be made under D 13/14/15.3.

An exhaustive list of operations could be as below:

 Collection/Transfer of waste oil to oil residue (sludge) holding tanks for subsequent disposal
(Main engine sump oil, Aux. engine sump oil, steering gear hydraulic oil, Stern tube oil, etc)
 Collection/Transfer of residues collected during cleaning of Bilge Holding Tank to oil residue
(sludge) holding tanks.
 Collection/Transfer of residues collected during cleaning Fuel Oil Settling and Service tanks
or other lubricating oil tanks to oil residue (sludge) holding tanks.
 Collection/Transfer of Oil residues collected due to accidental spill / leakage in engine room
to oil residue (sludge) holding tanks
 Collection/Transfer of OWS oil residues manually drained after cleaning to oil residue
(sludge) holding tanks

 Collection/Transfer of residues in F.O./L.O./sludge tanks leftover before and after cleaning to
oil residue (sludge) holding tanks.
 Collection/Transfer of water containing oil residue from E/R bilge wells during/after cleaning
to oil residue (sludge) holding tanks.
Note: Manual transfer without a pump of small quantity, say about 30 ~ 40 liters per day is not
required to be entered in the ORB.

6. Is it necessary to record the following operations in the Oil Record Book?

 M/E air cooler condensate draining into Bilge Holding Tank.
 Continuous draining of dirty oil from the scavenge spaces to the BSOT.
 Manual draining of fuel oil settling/service tanks into BSOT.
 Automatic draining of ME/AE back wash filters into BSOT.
Ans: It is not necessary to record these operations in the ORB as this is a natural inflow and does
not involve any pump for the transfer operation. However engineers are to be well aware of the
reasons for such rise in level and should be able to explain to PSCOs.

7. In Example # 18 – Bunkering of fuel or bulk lubricating oil, item 26.2 states….Start dd-mm-
yyyy Stop dd-mm-yyyy, whereas in the ORB code H 26.2 refers to time of bunkering.
Ans: This seems to be an error in IMO guidelines. As mentioned in the Oil Record Book – List
of items to be recorded in the first few pages, please mention time in 26.2 as Start: hh:mm Stop:

8. Is there any restriction in firing the incinerator during UMS period if the incinerator is
automated with alarms and trips and if the machinery spaces are fully compliant to EO class?
Ans: There is no restriction with regards to firing of the incinerator in the UMS period, provided
that all its safeties and trips are functional and that the incinerator is operated in the auto mode
and none of its alarms or safeties are bypassed.
However, if necessary, this should be done with the permission of Superintendent.

9. Is it possible to use the incinerator in port, during harbour steaming, at anchorage or in port if
the incinerator is operated within the designed parameters and thus emissions are within
regulated limits?
If the vessel is using only LSFO and hence the sludge has low sulphur content then why
not use the incinerator in an Emission Control Area (ECA)?
Ans: MARPOL specifically does not prohibit the use of incinerators in areas specified above;
however, local regulations may not allow the same. The local authorities/agents must be
contacted for guidance after taking permission from the Superintendent.
Incineration in a boiler even if approved and mentioned in the supplement to the IOPP certificate
is NOT allowed as per MARPOL in ports, harbour or estuaries but can be done only out at sea.

In SECA area before burning any sludge, it should be checked with local agents / authorities and
the sludge being burnt should be from fuel of less than 1.0 % sulphur.

10. Whenever incineration operation is done, should the entry be made in the beginning or at the
Ans: All entries should be made in chronological order i.e. date and time wise when the
operation is completed. This is because the quantity retained in the tank will only be known after
the operation is done.

11. Is it alright to make one tabular entry for the weekly Code C 11.1/11.2/11.3 entry, i.e. with
just one date?
Ans: A separate entry with date and signature will be required for each tank mentioned in item
3.1 of the supplement to the IOPP certificate. A sufficient stock of oil record books will need to
be kept on board.

12. If the OWS is required to be run everyday for – say 3 days; is it necessary to put seals on the
overboard valve every day after stopping it?
Ans: No. There is no need for fitting MARPOL sealson overboard valve in E/R.

13. If the contents of the F.O. drain tank (sec. 3.1 tank in the supplement to the IOPP certificate)
is transferred to the F.O. settling tank, then how is this entry is to be recorded?
Ans: This operation should be mentioned under C 12.2.

14. Is it necessary to record Additional Voluntary Recordings (i.e. examples 25, 26 & 27)?
Ans: Example 25 entries to be made. For Example 26 & 27 entries are not required.

15. As per Example #18, H 26.3 ISO number of bunkered fuel is to be recorded but what if the
same is not mentioned in BDN?
Ans: All bunker fuels supplied are generally to ISO 8217 standards and hence this number must
be written.

16. For the purpose of entry can the tank soundings be taken 12 noon to 12 noon?
Ans: All entries should be recorded in chronological order i.e. date and time and quantity at the
time of making entry should be recorded.

17. Vessel is Marshal Island flagged, is it a requirement as per the flag state to log (HFO/LSFO
to LSMGO- for EU ports) or (HSFO to LSFO- for SECA) changeover details to be written in
ORB (Part 1), in addition to the Engine room log book.
Ans: At present, only Panama flag state requires these entries to be made in the Oil Record Book
as Part 3 entries. However as per Marpol Annex VI requirements these entries are to be made in
the Engine Log Book Supplement (GEN 11).

18. Vessel presently does not have sealing arrangement on the OWS over board valve, it is only
locked with the covering arrangement and key is with Ch. Eng, is it required to put sealing
arrangement every time after OWS operation and then break the seal in order to run OWS, and to
enter them under OWS Code-I, as per example #26 and #27 of new guidance Annex.
Ans: Sealing is not required.

19. Is it required to make separate entries as per the example #12 and example #14 for pumping
out bilge overboard through 15 ppm equipment, even though both the start/stop time and position
under D-14, 15.1 and E-16, 18 are same?
Ans: Code (E) is for automatic starting and stopping of bilge transfer or disposal only and such
operations recommended to avoid.

20. Also the same query goes for Bilge water transfer from bilge well to bilge holding tank,
should we have to make 2 entries, one under D-13, 14, 15.3 and other under E-17,18, even
though the timings will be the same?
Ans: Same as Q 19 above.

21. Presently we are writing the weekly sounding of sludge tanks in the following format.
Date Code Item No. Record of operation/Signature
01-Dec-10 C 11.1/11.2/11.3 Tanks Capacity (m3) Retained (m3)
F.O.S 36.5 10.5
L.O.S 16.2 2.0
Oily bilge 17.1 1.8
Signature D/E Signature C/E
Noted that the tank name should be same as in the supplement (3.1) to IOPP.
Totally there are 8 numbers of oil residue (sludge) tanks mentioned in the supplement to the
IOPP certificate.
Whether to follow the same format or to write all these tanks separately with code number &
item number?
Ans: These entries should be made separately exactly as shown in the circular i.e. 4 lines will be
required for each entry, in this case 32 lines.

22. Even though Fuel oil drain tank is listed in the supplement (3.1) to the IOPP certificate,
incase of any emergency, is it possible to transfer to the main bunker fuel oil tank? Normal case
we avoid this transfer because of Catfines, but because of some accidental leakage or continuous
drain from F.O auto filter etc if F.O drain tank level increases abnormally, is it possible to
transfer to a bunker tank and in that case whether that bunker tank content will be considered as
Ans: If approved pipeline is provided for such purpose, with the permission of Superintendent,
such transfers can be made. But entry should be made under 12.2

23. Item No. 3.2.3 or 3.2.4 of IOPP supplement (other acceptable means) includes waste oil tank
nos.1 & 2 fitted with heating coils, is it not a requirement to amend the certificate since these
coils are means of disposing oil residues (thru evaporation).
Ans: Yes. Please remind the Superintendent before the next annual survey and class will issue
the new certificate.

24. Some Australian ports prohibit the discharge of black and grey water to overboard, so on that
time piping was temporarily modified in order to contain / process these water to sewage tank
then overflows to bilge water tank. Sewage tank is not included in IOPP certificate and in this
process, there is no specific new IMO guideline example to which the operation entry fits into
the oil record book.
Ans: This is a designed overflow according to existing sewage pipeline system and not a
transfer by means of a pump. Hence, there is no need of recording this in the ORB and C/E
should be able to explain to the PSCO confidently.

25. For clarification - Steam LNG carrier burning HFO without FO purifiers
OWS operation in auto mode:
Entry for OWS operation in Auto mode is being made as follows since the
bilge pump for pumping ER bilges to Bilge holding tank is left in Auto all
the time and also overflow from OWS floc tanks to Oily bilge tank happens

during OWS operation.
E 16 : System put into Auto mode for Overboard discharge of Bilge Holding Tank
through 15 ppm equipment
Start: Time and Position
Ctr: (Overboard flow meter ctr)
E 18 : System put into manual mode
Stop: Time and position
Ctr: (Overboard flow meter ctr)
Qty discharged: Diff in stop and start ctrs
Qty retained in Bilge holding tank: m3
Qty retained in Oily bilge tank at end of operation: m3
Ans: OK.

26. Manual transfer of oil / oily residues to Oily Bilge tank - example 2, C 11. Will oil collected
from galley also need to be accounted for? This will be very small quantities of 20 liters at a time
and hence make it difficult to account for in m3.
Ans: There is no requirement for recording disposal of galley cooking oil in the ORB if the
quantity is small.

27. Since our IOPP certificate 3.2.4 allows for transfer of oily residues to boiler tank - what type
of entry would be required here? Would a standard C 12.2 entry do? The boiler tank is NOT
listed in the Sludge tanks list 3.1.
Ans: Yes. 12.2 for transfer to boiler tank and 12.4 for burning in boiler.

28. For example, “xx m³ bilge water from (Name of sec 3.3 Tank & Designation)”. What does
this word “Designation” signify?
Ans: Some ships have tank numbers for each tank and also a name. The name as mentioned in
sec. 3.1 or 3.3 of the tank should be written exactly as it is given in the supplement to the IOPP

29. Example # 8: presently the evaporation is not being entered. Please clarify under new
regulations this is to be entered.
Ans: If the evaporated quantity is considerable then this must be entered to account for the
reduction in level such as for Waste Oil Settling / Service tank.

30. Please note presently for the tanks listed under item 3.1 in the Supplement to the IOPPC, the
quantities are being entered with up to ONE DECIMAL POINT only but entering up to TWO
DECIMAL POINTS is more practical & convenient. Please advice.
Ans: Keep entries simple and up to one decimal point.

31. As viewed in the revised Guidelines there are quite a few changes in the method of entries.
We understand that all the required changes as viewed in the Guidelines are applicable from 1st
Jan 2011 or is it that only Example 2 is applicable from 1st January 2011 and the other changes
will be applied in due course of time We hope that our understanding is right on this matter.
Ans: It is advisable to follow the guidelines as soon as possible. However the usage of Code C
11.1, 11.2, 11.3, 11.4 is to be done from 1 January 2011.

32. In case of manual operation the actual total quantity (m3) retained in a tank is 11.3 or 11.3 +
11.4. i.e. 11.3 means NORMAL ROB or NORMAL ROB + MANUAL OPERATION?

Ans: C 11.3 refers to total contents of tank after manual collection and C 11.4 refers to contents
collected by manual collection.

33. If manual transfer is done three times in a week then is it correct to consider 11.4 as a sum of
all three operations? If not then how to record?
Ans: This manual transfer or collection is to be recorded chronologically as and when done i.e.
in this case 3 different entries under C 11.1, 11.2, 11.3, 11.4.

34. Is quantity in 11.4 is to be carried over to next week entry i.e. if x m3 is declared against 11.4
in one week & y m3 is again transferred by manual operation in next week then next week entry
will be y m3 OR x m3 + y m3.
Ans: Only the quantity transferred at the time of entry to be entered.

35. C 11.1/11.2/11.3/11.4 Entry to be made weekly or along with every manual operation.
Ans: Code C 11.1, 11.2, 11.3, 11.4 entry is to be done as and when the collection is done.

36. Request advice under which column transfer of Aux engine lub oil sump to be recorded
during renewal at 2000 hrs.
Ans: Such a transfer / collection is to be recorded under Code C 11.1, 11.2, 11.3, 11.4 (Ex: 2).

37. Scavenge/under piston cleaning sludge being kept in 20 ltrs. or 200 ltrs. drums, shall we
have to record this under C 11.4 & what should we do with this sludge, landing as well as
incinerating in the incinerator has a problem view damaging incinerator refractory & refusing by
shore authorities.
Ans: No need of entry in ORB. Since this would be hard carbon sludge/mixed with oily rags
used for cleaning, the best option would be to land ashore – Disposal of this is required to be
recorded in GRB.

38. Under "Additional Voluntary Recordings" example #26 ,example #27, generally we did not
put any environment seal on overboard valve of 15 ppm bilge water separator. We used to keep
it lock and key is kept with Chief engineer. My question is "Is it require to break and put new
seal every time before and after starting of 15 ppm bilge water separator from 1st January
Ans: No.

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