MARPOL Annex I issues

Under current MARPOL regulations, older bilge filtering equipment is "grandfathered". Older ships are permitted to keep existing equipment and are able to repair same, but are required, under resolution MEPC.107(49), to fit new equipment when replacing defective/ non-repairable equipment.

Before MEPC.107(49) was adopted the United States submitted a request for phase-out of existing (older) equipment, requiring the fitting of MEPC.107(49) compliant bilge water treatment system with the next dry-docking of the vessel. This proposal was not adopted, because replacing bilge separators on something like 50,000 ships within a five year span would have been difficult.

It seems the United States keep pushing for this phase out at MEPC meetings, to date it has not been recommended for adoption.

From a practical point of view, the US proposal seems like a mute point. Technical progress and port state control take pretty well care of this matter because:

• Bilge separators (meeting resolution A.393(X) or MEPC.60(33)) can be repaired and do separate oil from water to prevent an oil sheen.
  
• Bilge Alarms A.393(X) compliant have been out of production since 1995; technology has progressed and the after sales market has disappeared, so repair of these units is virtually no longer possible.
• Similarly, the MEPC.60(33) compliant equipment faces the same road to extinction; it's just a matter of a few years before these bilge alarms are no longer repairable.
• By changing older bilge alarms to the MEPC.107(49) compliant unit, the owner (generally) requires an upgrade of the bilge separator to current generation, because the effluent quality from the old coalsecer type separator will not meet the <15>

For ship owners adhering to Green Marine, upgrading to more efficient pollution prevention equipment is one of the criterias to achieve the level of industrial leadership.