Cargo Slops/Wash Water Residues - Spain

The disposal and landing of cargo slops/wash water residues has long been a concern to ship owners and coastal states.

Under Royal Decree 1381/2002 all vessels must discharge waste generated by the vessel before leaving a Spanish port. An exception can be granted if the Harbour Master expressly authorises it. A decision to exempt the vessel will be based on the information provided by the vessel in the mandatory pre-arrival notification or after an on board inspection by the Harbour Master. If the declared information and/or the inspection confirm that the vessel has sufficient storage space for the slops on board and for those that are likely to be generated during the voyage to the next port of call, the vessel can be issued an exemption. An exemption will not be granted if:

• There are reasonable grounds to believe the next port of call does not have sufficient facilities for the discharge of slops;
• or the next port of call is unknown and there are grounds to suspect the vessel might discharge slops at sea; or
• prior notification of the slops on board has not been provided; or
• the Harbour Master views the storage conditions for slops on board as inadequate or could reach capacity during the intended voyage.

Members have raised concerns over the regulations and the way in which they are being used by the Harbour Master’s in Tarragona and Cartagena. Here the Harbour Masters are allegedly only allowing the vessel to depart with cargo slops/waters when the following circumstances are complied with:

• The vessel has less than 40m³ of slops on board.
• When the vessel is going to another Spanish port with an authorised MARPOL Waste Management Company and that the Master undertakes to discharge the slops there and then send the MARPOL Discharge Certificate to the Harbour Master upon completion of discharge.

When cargo slops/wash water residues are required to be discharged at a waste management facility, it can result in a significant additional cost being borne by the owners. If the vessel was to berth at a terminal that can accept fluids into their shore slop tanking arrangement, then costs would be in the region of approximately €9 – €15 per m³ plus survey costs. Use of an authorised residue treatment company commonly requires slops/wash water to be transferred to a barge and subsequently to lorry and then to the final waste treatment plant. This has resulted reported costs of €116 – €148 per m³ depending on the specific flashpoint of the residue.

For engine room bilges/sludge and garbage, the regulations state that if the vessel has 5m³ or more on board, it is obligatory to discharge this prior to departure. The cost of this is covered in the residues duty which is paid by all vessels to the Port Authority and is a fixed cost based on the vessel’s GT.

When planning a vessel’s itinerary, Members should liaise with the nominated terminals to assert if they can receive the slops and if not consider whether cargo slops/wash residues can be discharged more cost effectively at earlier ports or establish that the next port of call has sufficient capacity to take the slops/residue.

Failure to comply with regulations may result in the Harbour Master not allowing the vessel to depart.

This article has been produced in conjunction with correspondents Hispania P&I, Barcelona.