Ems manual by Capt. Ioannis Theodorakas

THETA MARINE CONSULTING LTD. theta@thetamarine.net www.thetamarine.net

ENVIRONMENTAL MANAGEMENT SYSTEM MANUAL - POLLUTION PREVENTION

THETA MARINE – IMO NO. ACKNOWLEDGEMENT LIST All crew members are to review the plan and confirm by signing the attached list:

NAME

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RANK

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DATE

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THETA MARINE – IMO NO. RECORD OF CHANGES

No.

Date

Revised Part

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Approved By : Name / Signature

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THETA MARINE – IMO NO. TABLE OF CONTENTS PAGE ACKNOWLEDGEMENT LIST ..................................................................................................2 RECORD OF CHANGES .........................................................................................................3 1.COMPANY POLICIES.........................................................................................................11 ENVIRONMENTAL POLICY. ..............................................................................................................................11 CODE OF ETHICS AND CODE OF CONDUCT ............................................................................................ 12 NON- RETALIATION POLICY STATEMENT ................................................................................................. 13

2.ORGANIZATION , PERSONNEL & OVERSIGHT ............................................................... 14 2.1 Purpose ............................................................................................................................................ 14 2.2 Responsibility ................................................................................................................................... 14 2.2.1 Environmental Compliance Manager ........................................................................................... 14 2.2.2 Master ......................................................................................................................................... 14 2.2.3 Chief Engineer ............................................................................................................................ 15 2.2.4 Superintendents/Port Captains/Port Engineers .......................................................................... 15 2.3 Communication ............................................................................................................................... 15 2.3.1 Internal Communications ............................................................................................................ 16 2.3.2 External Communications ........................................................................................................... 16 2.3.3 Contractors and Vendors ............................................................................................................ 17 2.3.4 Suggestion / Anonymous Reporting Box .................................................................................... 17

3. RESPONSIBILITY & ACCOUNTABILITY .......................................................................... 18 3.1 3.2 3.3 3.4 3.5 3.6 3.7

Purpose ........................................................................................................................................................ 18 Accountability and Responsibility ............................................................................................................. 18 Familiarization Record ............................................................................................................................... 18 Declaration of Environmental Commitment ............................................................................................ 18 Declaration of Environmental Compliance on Sign-off ......................................................................... 19 Non Compliance ......................................................................................................................................... 19 Evaluation and Appraisals of Company Personnel ............................................................................... 19

4. ENVIRONMENTAL REQUIREMENTS ...............................................................................20 4.1 Purpose .......................................................................................................................................... 20 4.2 Responsibility ................................................................................................................................. 20 4.3 Ongoing Compliance Monitoring ................................................................................................... 20 4.4 Legal and other requirements ....................................................................................................... 20

5. ASSESSMENT, PREVENTION & CONTROL .................................................................... 21 5.1 5.2 5.3 5.4 5.5 5.6

Purpose .......................................................................................................................................... 21 Responsibility ................................................................................................................................. 21 Procedure for Identification/Evaluation of the Environmental Aspects Impacts ............................ 21 Significant Aspects ......................................................................................................................... 22 Hand-over notes ............................................................................................................................ 22 Feedback –Fleet Engineering Survey ............................................................................................ 22

6. ENVIRONMENTAL INCIDENT & NON-COMPLIANCE INVESTIGATIONS ....................... 23 6.1 6.2 6.3 6.4 6.5 6.6 6.7 6.8

Purpose .......................................................................................................................................... 23 Responsibility ................................................................................................................................. 23 Non-Conformities ........................................................................................................................... 23 Corrective actions .......................................................................................................................... 23 Preventive Action ........................................................................................................................... 23 Result of Corrective and Preventive Actions ................................................................................. 24 Emergency Preparedness and Response ..................................................................................... 24 Feedback ....................................................................................................................................... 24

7. ENVIRONMENTAL TRAINING , AWARENESS & COMPETENCE ................................... 25 7.1 Purpose .......................................................................................................................................... 25 7.2 Responsibility ................................................................................................................................. 25

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THETA MARINE – IMO NO. 7.3 7.3.1 7.3.2 7.3.3 7.3.4 7.3.5 7.3.6 7.4 7.5 7.6

Crew Training ............................................................................................................................... 25 Crew Recruitment ...................................................................................................................... 25 Pre-Boarding Crew Education and Briefing .............................................................................. 25 Ship Specific Familiarization ..................................................................................................... 25 Onboard Training ...................................................................................................................... 25 Specific Instructions to Chief Engineer ..................................................................................... 26 Annual Refresher Training ........................................................................................................ 26 Shore Based Company Personnel ............................................................................................. 26 Other Means of Awareness ........................................................................................................ 27 Feedback .................................................................................................................................... 27

8. ENVIRONMENTAL PLANNING & ORGANIZATIONAL DECISION-MAKING ................... 28 8.1 8.2 8.3 8.4

Purpose ......................................................................................................................................... 28 Responsibility ................................................................................................................................ 28 Environmental Planning ................................................................................................................ 28 Objectives and Targets ................................................................................................................. 28

9. MAINTENANCE OF RECORDS & DOCUMENTATION ..................................................... 29 9.1 9.2 9.3 9.4

Purpose ......................................................................................................................................... 29 Responsibility ................................................................................................................................ 29 EMS Manual ................................................................................................................................. 29 EMS Records ................................................................................................................................ 29

10. POLLUTION PREVENTION ............................................................................................31 10.1 Purpose ......................................................................................................................................... 31 10.2 Procedures .................................................................................................................................... 31 10.3 Additional Measures for Engine Room Operations ...................................................................... 31 10.3.1 Tank Sounding Log Book............................................................................................................ 31 10.3.2 Leakage Log Book ..................................................................................................................... 31 10.3.3 Oil-to-Sea Interface Log Book ................................................................................................... 32 10.3.4 Seal Log Books .......................................................................................................................... 32 10.3.5 Primary Bilge Tank ..................................................................................................................... 32 10.3.6 Bilge Holding Tank (Tank for the Retention of Oily Water Mixtures) ......................................... 32 10.3.7 Sludge & Bilge Pumps ............................................................................................................... 32 10.3.8 Oily Water Separator Spare Filters ............................................................................................ 32 10.3.9 Oily Water Separator Overboard Valve Operation .................................................................... 32 10.3.10 Bilge Main Cross-Connections ................................................................................................. 33 10.3.11 Bilge Suction Valves ................................................................................................................. 33 10.3.12 Bilge and Sludge Lines ............................................................................................................. 33 10.3.13 Blank Flanges ........................................................................................................................... 33 10.3.14 Fuel Oil and Lube Oil Management Log Book .......................................................................... 33 10.3.15 Waste Water (Sewage) Discharge Log Book ........................................................................... 33 10.3.16 Inventory of Deck and Engine Room Flexible Hoses ............................................................... 34 10.3.17 Bilge & Sludge Production Monitoring Report .......................................................................... 34 10.3.18 Fluid Segregation Drain List...................................................................................................... 34

11. CONTINUOUS PROGRAM EVALUATION & IMPROVEMENT ....................................... 35 11.1 Purpose ......................................................................................................................................... 35 11.2 Responsibility ................................................................................................................................ 35 11.3 Internal Audit ................................................................................................................................. 35 11.4 Management Review .................................................................................................................... 35 11.5 Management Review Input ........................................................................................................... 35 11.6 Review Output .............................................................................................................................. 35 11.7 Review of EMS Manual by Vessel ................................................................................................ 36 11.8 Master’s Responsibility Under the EMS ....................................................................................... 36 11.9 Report to the Directors ................................................................................................................... 36

12. IMPLEMENTATION SCHEDULE .....................................................................................37 12.1 Purpose ......................................................................................................................................... 37 12.2 Schedule ....................................................................................................................................... 37

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THETA MARINE – IMO NO. APPENDIX LIST ....................................................................................................................38 APPENDIX-1 "ENVIRONMENTAL MANAGEMENT SYSTEM ORGANIZATION"........................................ 39 APPENDIX-2 "ENVIRONMENTAL COMPLIANCE MANAGER & MANAGEMENT CONTACT DETAILS" ........ 40 APPENDIX- 3 "LIST OF ENVIRONMENTAL ASPECTS" ...................................................................... 41 APPENDIX- 4 "ENVIRONMENTAL TRAINING FOR SHIPBOARD PERSONNEL" ...................................... 44 APPENDIX- 5A "STANDARD OPERATING PROCEDURES FOR THE OILY WATER SEPARATOR" ............. 45 APPENDIX- 5B "STANDARD OPERATING PROCEDURES FOR THE INCINERATOR" .............................. 47 APPENDIX- 5C "STANDARD OPERATING PROCEDURES FOR THE SEWAGE TREATMENT" .................. 48 APPENDIX- 5D "STANDARD OPERATING PROCEDURES FOR THE SEAL PROGRAM" .......................... 49 APPENDIX- 5E "STANDARD OPERATING PROCEDURES FOR WASTE DISPOSAL"............................... 56 APPENDIX- 6 "ENVIRONMENTAL OBJECTIVES & TARGETS" ............................................................ 58 APPENDIX- 7 "EMS RECORDKEEPING" (All records are to be retained on board for 3 years) .................. 59 APPENDIX- 8 "ENVIRONMENTAL MANAGEMENT SYSTEM FORMS"................................................... 64

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THETA MARINE – IMO NO.

GLOSSARY

APPS: Act to Prevent Pollution from Ships. MARPOL Protocol, an international treaty implemented in the United States by the “Act to Prevent Pollution from Ships” (APP S) at 33 United States Code (USC) 1901. BIMCO: Baltic and International Maritime Council, to unite ship owners with other related organizations such as Charterers, shippers, merchants, receivers, ship owners, shipbrokers to expedient matters affecting the shipping industry, communicate to members any useful information and instances of unfair charges and claims, freight speculation, objectionable charter parties and other practices, prepares and improves charter parties and other shipping documents in association with Charterers, shippers, merchants, receivers, ship owners, shipbrokers and others connected with the shipping industry, to issue as approved documents for the use of the shipping industry, charter parties and other shipping documents, To assist members in cases of unfair treatment by governments, authorities or other similar bodies ,to take such steps in the interest of the shipping industry as may appear desirable. ECM : Environmental Compliance Manager appointed to monitor the compliance of vessels as with the EMS and other statutory requirements. Certification: Procedure by which a third party gives written assurance that a product, process, or service conforms to specified requirements. Compliance: An affirmative indication or judgment that the supplier of a product or service has met the requirements of the relevant specifications, contract, or regulation; also the state of meeting the requirements. Continual Improvement: Process of enhancing the environmental management system to achieve improvements in overall environmental performance, in line with the organization’s environmental policy. Note - The process need not take place in all areas of activity simultaneously. Corrective action: An action taken to eliminate the causes of an existing nonconformity, defect, or other undesirable situation in order to prevent recurrence. Court Appointed Monitor: A designated monitor appointed by the court to perform reviews and report to the court the process and implementation of the Environmental Compliance Program (ECP). CFR: Code of Federal Regulations. It is a codification of the general and permanent rules by the Executive departments and agencies of the Federal Government of United States. Classification Society: Classification societies are organizations that establish and apply technical standards in relation to the design, construction and survey of marine related facilities including ships and offshore structures. These standards are issued by the classification society as published rules. Example: Class NK, ABS, DNV, Lloyds, etc. CWA: Clean Water Act, as amended by the Oil Pollution Act of 1990. The Clean Water Act (CWA) as amended by the Oil Pollution Act of 1990, 33 USC 1321(b)(3), 1319(c)(2), 1362(7, 8 and 9), and 33 CFR 2.05-15 makes it a crime to knowingly discharge oil in quantities determined by regulation to be harmful in “navigable waters” or within the “contiguous zone” of United States. ECP: Environmental Compliance Program, The environmental standards and requirements included in the signed court Plea Agreement between the US Government and the Company. EEZ: Exclusive Economic Zone. It means the zone contiguous to the territorial sea of the United States extending to a distance up to 200 nautical miles from the baseline from which the breadth of the territorial sea is measured. EMS: Environmental Management System, the part of the overall management system that includes

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THETA MARINE – IMO NO. PURPOSE OF POLLUTION PREVENTION PROGRAM The purpose is to summarize the procedures for preventing, reducing, recycling, reusing, and minimizing the impact of the discharges or emissions from cargo spaces, ballast spaces, machinery spaces, sewage treatment plants, maintenance waste and shipboard garbage, with a primary emphasis on vessel’s engine room operations, including procedures to encourage material substitutions, where necessary and appropriate. The Company developed operational controls ashore and onboard the vessel, to maintain procedures for key shore and shipboard based activities and operations which directly affect the identified significant environmental aspects, in line with its policy to avoid or minimizing environmental risks and ensures compliance with legal requirements to which it subscribes. The daily management activities of the Company and its vessel shall be designed to be environmentally friendly and shall, wherever possible, be performed in accordance with sound environmental management practice. All Company personnel, ashore and onboard are encouraged to identify material substitutions or processes which reduce occasions of equipment malfunction and deterioration, operators errors or deliberate malfeasance. Such reports of concerns are to be sent to the EMR as soon as practicable. The EMR shall review the reports or concerns with the appropriate head(s) of department(s) and shall monitor the actions implemented, where necessary and appropriate. The Company has informed all employees about potential legal ramifications for departure from specified operating policies/procedures, including disciplinary action up to and including termination of employment, as well as criminal / civil / administrative penalties as a result of noncompliance. The Company’s Management is totally committed in implementing the mandates of the EMS. The Company’s PMS describes the maintenance system to be implemented on the vessel so that the equipment used for processing the waste releases such as OWS, Bilge Pumps, Incinerator, OCM, etc. are tested and their maintenance affected at regular intervals.

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THETA MARINE – IMO NO. 1. COMPANY POLICIES ENVIRONMENTAL POLICY The Company is committed to continual efforts to improve environmental performance in all areas required by its Environmental Management System and throughout its operations and towards a cleaner marine environment. Furthermore the Company is committed:

•

To continuous improvement in environmental performance, including all areas required by the EMS To pollution prevention that emphasizes source reduction, including funding and human resources necessary to effectively maintain and repair the systems, equipment and components found in machinery spaces of vessels, To continual reduction of environmental risks, To sharing information on environmental performance with external stakeholders.

• • •

The Company’s goal is to achieve ZERO spills at sea through continual improvement. For achieving this goal, the Company: • Complies with all applicable environmental laws, regulations and requirements and applies responsible standards where laws, regulations and requirements do not exist. • Responds quickly and effectively to environmental incidents resulting from its operations, in cooperation with industry organizations and authorized government agencies. • Shows concern and respect for the environment, emphasizes every employee's responsibility in environmental performance and fosters appropriate operating practices and training. • Undertakes appropriate reviews and evaluations of its operations to measure progress and to foster compliance with this policy. • Conduct and supports research to improve understanding of the impact of its business on the environment, to improve methods of environmental protection and to enhance its capability to make operations compatible with the environment. • work with government and industry groups to foster timely development of effective environmental laws and regulations based on sound science • Manage its business with the goal of preventing environmental incidents and of controlling emissions and wastes to below harmful levels. • Be against any incentive or bonus programs based on minimizing operational costs associated with the operation, maintenance and repair of machinery space systems, equipment and components to ensure that employees do not avoid such costs and thereby sacrifice environmental compliance. • Designs, operates and maintains facilities to this end.

The Environmental policy has the full support of Senior Management and applies to all employees of the Company.

Date:

/ / 2014 Managing Director

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THETA MARINE – IMO NO. CODE OF ETHICS AND CODE OF CONDUCT The following values and principles have been established and implemented in this respect, shared among all shore based and shipboard employees at all levels: • • • •

•

Date:

The Company shore staff and seagoing personnel shall not be involved in any kind of harassment, abuse or discrimination. The Company shore staff and seagoing personnel shall not conceal any identified unsafe act or event which affects or could affect human health and safety, the environment and the property. The Company shore staff and seagoing personnel shall carry out their duties in a professional and impartial manner. All Company employees shall act in honesty and good faith. All information regarding Company’s operations, projects, reports or any work carried out shall be treated as business confidential to the extent that such information does not conflict with Company’s policy for safety and environmental excellence and is not already disseminated or made generally available to third parties. Any kind of offer, gift or bribe in any form direct or indirect, including kickbacks is strongly prohibited in all Company’s operations and processes. Furthermore, the Company prohibits the use of other routes or channels for provision of improper benefits to, or receipt of improper benefits from agents, contractors, suppliers or employees of any such party or government officials. Procurements are conducted in a fair and transparent manner.

/ /2014 Managing Director

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THETA MARINE â&#x20AC;&#x201C; IMO NO. NON- RETALIATION POLICY STATEMENT All Company personnel ashore and shipboard shall not retaliate against or in any way treat adversely any subordinate, co-worker, employee or crew member for their reporting of any environmental, health and safety or integrity violations to the appropriate authority of the coastal state. Company personnel ashore and shipboard who fail to comply with this policy shall be subject to disciplinary action up to and including termination of services. This policy shall be displayed in each of the Company's office ashore. The vessel shall display this policy in the mess room(s).

Date: / /2014 Managing Director

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THETA MARINE – IMO NO. 2. ORGANIZATION , PERSONNEL & OVERSIGHT 2.1 Purpose The purpose of this section is to illustrate the organization of the Company with respect to the EMS implementation and its maintenance, including the means of communicating to the personnel ashore and shipboard.

2.2 Responsibility The top management, comprised of the Managing Director, Designated Person Ashore/Environmental Compliance Manager, Safety & Quality Manager, Technical Manager, Operations Manager, Crew Manager, Supply Manager, and vessel Masters, shall actively support adherence to the Environmental Management System (EMS) prescribed in this Manual. To ensure the EMS is carried out throughout the organization, the Company has appointed a Environmental Compliance Manager (ECM). The role of the Designated Person as required by the ISM code is also carried out by the ECM. In the absence of the ECM, the duties shall be taken over by the Safety & Quality Manager. Appendix 1 describes the organization and duties of the personnel involved with the EMS. These duties are in addition to the duties described in Safety Management System (SMS) Manual provided as per ISM code. Company personnel shall include all contractors and consultants hired by the Company for their short term assignments.

2.2.1 Environmental Compliance Manager The duties and responsibilities of the ECM are as follows: 1.

Coordinate and communicate with the Managing Director, Chief Financial Officer, Safety & Quality Manager, Technical Manager, Operations Manager, Crew Manager, and Supply Manager of the Company and vessel’s Master regarding matters pertaining to the EMS.

Develop and implement all systems required by the EMS.

Establish and implement training programs for the vessel’s staff pertaining to environment protection

Ensure that audits and surveys are carried out as required by the EMS.

Ensure that all documents as required by the EMS including Anonymous Reporting Forms are made available to all staff for submitting as applicable.

Ensure that reports as required by the EMS – quarterly reports, annual reports are made on a timely basis for submitting to the various parties.

Report and document non-compliant condition of the vessel relating to environmental requirements to the relevant Authorities as required.

Review, investigate and document reports of non-compliance by employees in a timely fashion and initiate, monitor and document all actions taken as a result of the reporting.

Develop and maintain a database documenting each vessel’s machinery space waste quantities on a day-to-day basis as reported by the vessel.

2.2.2 Master The Master of each vessel shall ensure proper compliance with the procedures established under the EMS and make known the Company structure with respect to the EMS among his crew. Following are the duties and responsibilities of the Master: 1. Ensure crew compliance with the EMS, MARPOL and all applicable maritime pollution prevention requirements, including ‘sealing’ requirements and other Company specific procedures. 2. Report any non-compliant condition onboard to the relevant Authorities / parties as per the EMS.

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THETA MARINE – IMO NO. 3. RESPONSIBILITY & ACCOUNTABILITY 3.1 Purpose The purpose of this section is to specify accountability and responsibilities of the Company for environmental protection and risk reduction measures. This section also specifies accountabilities and responsibilities of Company personnel and crew.

3.2 Accountability and Responsibility The Managing Director has the ultimate responsibility for environment protection and risk reduction measures, assuring compliance, required reporting to regulatory agencies and corrective action implemented. The ECM shall act on behalf of the Managing Director in making immediate decisions concerning these matters. Any discharges, spills or releases (potential or otherwise) in contravention to the MARPOL and/or any other applicable environmental laws and regulations of the coastal state (federal and state) are to be reported promptly and accurately to the regulatory agencies by the Master. In case of unavoidable circumstances, where the Master is unable to report to the regulatory agencies, the ECM shall report on his behalf, as soon as practicable under the circumstances. Each department head in the Company’s office shall ensure proper compliance with the environmental and safety procedure and notify the ECM if any irregularities or non-conformities are detected. The ECM, in turn, shall immediately notify the Directors. The organization chart described in Appendix 1 of this Manual provides details of the responsibility between the departments in the shore office, which ensures that each vessel is closely monitored and supervised by the Company. All personnel in the Company, ashore and shipboard are responsible for identifying, proposing and participating in the legal and regulatory compliance within their areas of expertise. The Master of each vessel shall ensure proper compliance with the procedure and all applicable laws and regulations and shall notify the ECM if irregularities and/or non-conformities are observed. All crewmembers are responsible for identifying, proposing and participating in the legal and regulative compliance within their areas of expertise. The ECM shall be responsible for coordinating with the various vessels and departmental heads ashore for administering and implementation of the EMS Manual procedures throughout the organization and vessels under the Company’s management.

3.3 Familiarization Record Within seven (7) days after sailing from their port of embarkation, each newly joining crewmember shall be familiarized with the EMS policies and procedures contained in this Manual. The Master of each vessel shall document EMS familiarization and shall keep a copy of the signed record of familiarization of each crewmember. The EMS Familiarization Forms contained in Appendix 8 to this Manual shall be used. Familiarization forms are separate for deck and engine department personnel – Form EMS 001 "EMS Familiarization for engine department personnel" and Form EMS 002 "EMS Familiarization for deck department personnel".

3.4

Declaration of Environmental Commitment nd

The Master, Chief Engineer, Chief Officer, 2 Engineer, 3 Engineer & 4 Engineer upon joining the vessel shall sign a “Declaration of Environmental Commitment”, which states that the signatory will report through his chain of command any environmental violations of which he becomes aware. Appendix 8 contains a sample of this declaration for the Master and Chief Engineer, Form EMS 003, nd rd th as well as Form EMS 004 for the Chief Officer, 2 Engineer, 3 Engineer & 4 Engineer. Any noncompliance of the concerned person with any pollution prevention regulation will lead to legal action and dismissal.

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THETA MARINE – IMO NO. 4. ENVIRONMENTAL REQUIREMENTS 4.1

Purpose

This section describes the process for identifying, interpreting and effectively, communicating environmental requirements to affected Company personnel.

4.2

Responsibility

The ECM shall be responsible for the administration and implementation of this procedure throughout the organization. Each department head shall ensure proper compliance with the procedures. Each Master shall ensure proper compliance with the procedure onboard.

4.3

Ongoing Compliance Monitoring

Section 2.3.1 of this manual describes the procedure for internal communication for identifying, interpreting and effectively communicating environmental requirements to Company personnel.

4.4

Legal and other requirements

The Company’s policy and goal at all times is to be in full compliance with the applicable requirements of: • Classification Societies, • Flag Administrations, • IMO (SOLAS, MARPOL), • STCW • (USA) Federal (OPA-90), Clean Water Act, APPS, PWSA and all applicable laws and regulations of all states upon whose waters the Company’s vessels operate, • Port Authorities, • Industry Code of Practice, • Local Regulations, Laws, and Requirements. The Company has established various subscription agreements for international maritime legislation in order to be informed about legal developments. Further, the Company subscribes to various informative news media in the Industry. The Technical, Quality & Safety, and Operations Departments of the Company shall continuously monitor the information available from the various sources identified above, and shall evaluate the potential impacts of these laws and regulations on the Company and its activities, processes or services. The ECM shall further evaluate all new or amended laws and regulations and their significant impact on the environmental activities of the Company. He shall inform appropriate personnel and disseminate such applicable laws and regulations to the vessels in the form of circular or amendments to the EMS Manual.

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THETA MARINE – IMO NO.

5. ASSESSMENT, PREVENTION & CONTROL 5.1

Purpose

This section describes the process of assessing operations, for the purposes of controlling and, where applicable, preventing or minimizing reasonably foreseeable waste stream releases, thereby ensuring environmental protection and maintaining compliance with environmental requirements, with a primary emphasis on vessel engine room operations.

5.2

Responsibility

The Company shall determine and control environmental aspects in order to reduce environmental load in the operation of its ships. The Company shall also establish and maintain procedures to identify the environmental aspects of its activities and services, over which it has control or influence and which have or can have significant impacts on the environment. The ECM shall be responsible for the administration and implementation of this procedure throughout the organization. All shore side and shipboard personnel in the Company are responsible for identifying, proposing and participating in the evaluation of the environmental aspects that affect them or the Company. Furthermore, the Company shall also ensure that environmental targets will be established, while taking into consideration such environmental aspects. The Master of each vessel shall notify the ECM if environmental aspects are noted aboard their respective vessels, but not properly described or provided for in this Manual. The senior officers comprised of the nd Master, Chief Engineer, Chief Mate and 2 Engineer are responsible for identifying, proposing and participating in the evaluation of the environmental aspects that affect the Company.

5.3

Procedure for Identification/Evaluation of the Environmental Aspects Impacts

The identification of the environmental aspects is an ongoing process that determines the past, current and potential impact (positive or negative) of the Company activities on the environment. The process includes the identification of the potential environmental regulatory, legal, and business exposure, as well as the identification of health, safety, and environmental impacts. The process also includes, when required, a “root cause” analysis of any problems or non-conformities reported. The ECM shall instruct managers and the ships’ Masters to identify and enumerate the environmental aspects, which have or can have significant impacts on the environment in accordance with this procedure. The Technical Manager and the Master shall enter the identified environmental aspects into Appendix 4 – The List of Environmental Aspects. The Safety & Quality Manager and Operations Manager shall further review this list. Those aspects related to these significant impacts are considered in setting the environmental objectives. While identifying the environmental aspects, the Managers and the ship’s Masters should identify the environmental aspects which can be controlled and which are expected to have an environmental impact in case of occurrence of an actual environmental: •

Release to sea

•

Release to air

•

Waste management

•

Use of raw materials and natural resources

•

Breaking out of noise, vibration and stink

•

Seafarer’s health

In evaluating the identified environmental aspects, the following should be considered: •

The scale of the impact

•

The severity of the impact

•

Probability of occurrence

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6. ENVIRONMENTAL INCIDENT & NON-COMPLIANCE INVESTIGATIONS 6.1

Purpose

The purpose of this section is to provide procedures for internal and external reporting of potential violations relating to waste stream release incidents, with a primary emphasis on vessel engine room operations.

6.2

Responsibility

The ECM shall be responsible for the administration and implementation of this procedure throughout the organization. Each department head shall ensure proper compliance with the procedure. Each Master shall ensure proper compliance with the procedure onboard.

6.3

Non-Conformities

All incidents and violations, potential or otherwise, relating to waste stream management contrary to the requirements of the EMS and Company procedures shall be considered a Non-Conformity. All such Non-Conformities shall be reported to the ECM as soon as practicable after their occurrence. Shipboard environmental Non-Compliances (Non-Conformities, Defects, Damages etc) will be noted by the Master of the concerned vessel and will be reported, using the SMS Forms VM-16 "Defect Report" and VS-05 "Non-Conformance Report", to the appropriate ECM, who will evaluate the report and where necessary will arrange accordingly.. Any environmental non-conformity noted by Port Captains/Port Engineers or other Company personnel during their visits onboard shall recorded on SMS Form VS-05 "Non-Conformance Report" and brought to the attention of the ECM. When appropriate, SMS Form VS-04 "Near Miss, Accidents, and Incidents Analysis Report" shall be completed. A thorough investigation process, including, when appropriate, root cause analysis to aid in developing corrective actions shall be carried out by the Master or his designated representative.

6.4

Corrective actions

The Master of each vessel shall initiate temporary or permanent corrective action in consultation with the shore staff to mitigate any non-conformity, potential or otherwise. The corrective action taken is appropriate to the significance level of the non-conformity to ensure all Class, Flag, and Port State regulations are complied with. Such procedures shall ensure the following: • Review of any non-conformity • Determination of the immediate cause of non-conformity • Determination of the correct action required to eliminate the non-conformity • Implementation of the required action • Monitoring of the results of corrective action • Review of corrective action taken. • Completion and reporting of the corrective action

6.5

Preventive Action

The Company shall initiate action to eliminate the causes of any environmental non-conformity from reoccurrence and also to prevent the occurrence of potential non-conformities. Preventive action taken shall be appropriate to the significance level of the non-conformity or potential non-conformity. Such procedures ensure the following: • • •

The carrying out of root cause analysis for non-conformity and/or potential non-conformity Determination and implementation of appropriate action needed to eliminate the root-cause Monitoring of the results of preventive action

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THETA MARINE – IMO NO. 7. ENVIRONMENTAL TRAINING , AWARENESS & COMPETENCE 7.1

Purpose

The purpose of this section is to identify employee training needs, document and evaluate the training and provide a process for improving the training provided to shipboard and shore based employees who are involved in handling/management of waste streams.

7.2

Responsibility

The ECM shall be responsible for the administration and implementation of this procedure throughout the organization through the Crew Manager. Each department head shall ensure proper compliance with the procedure. Each Master shall ensure proper compliance with the procedure onboard.

7.3

Crew Training

As per Company’s Safety Management System (SMS) Manual, the General Manager and Crew Manager shall identify training needs for its crew on an ongoing basis to ensure that they have the required skills that will enable them to carry out their duties in an effective manner. The Company shall make the arrangements for the provision of such training through internal resources. Appendix 4 describes the environmental training required for the crew onboard Company vessels. Identification of training, in addition to training prescribed in Appendix 4, is based on each vessel Master’s crew evaluation, superintendent visits, and analysis of non-conformities. Crew training includes all applicable SMS implementation and processes, Environmental Compliance and reporting requirements required by applicable international, Flag state, and Port state regulation/laws, including, but not limited to, and without limitation, SOLAS, the ISM Code, MARPOL (including oily water separators and oil record book requirements and procedures), and all applicable United States statutes and regulations.

7.3.1

Crew Recruitment

Company’s Procedures Manual describes the procedure to ensure that Company vessels are manned with qualified, competent and medically fit personnel. The Company entrusts selection, employment and arrangement for joining of seafarers to manning offices by contract and in accordance with the Company’s recruitment policy as set forth herein and agrees to adhere to such policy in the selection and hiring of seamen to serve on the Company’s vessels.

7.3.2

Pre-Boarding Crew Education and Briefing

Each crewmember, prior to joining the vessel, shall be briefed by the Manning Office on the Company Environmental Policy, Organization, Procedures and reporting requirements. Relevant extracts of this EMS Manual, MARPOL & SMS Manuals shall be provided as per the level of responsibility of the individual crewmember.

7.3.3

Ship Specific Familiarization

Within seven (7) days after sailing from their port of embarkation, all crewmembers shall be familiarized with the vessel’s environmental policies, procedures and equipment as per Forms EMS 001 and EMS 002 as applicable. The Master shall keep a copy of the signed record of each crewmember, acknowledging having received familiarization training.

7.3.4

Onboard Training

The Master and Chief Engineer of each vessel shall conduct training session concerning environmental matters onboard their vessel for the crew monthly. Such training shall be over and above the training conducted on board as per Chapter 6 of the SMS Manual. All crew, except the crew standing watch at the time, shall attend such training sessions. The Master shall record details of training conducted, using SMS Form VC-05 "Training Drill Report". The Master shall adjust the training schedule and/or the

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THETA MARINE – IMO NO. 8. ENVIRONMENTAL PLANNING & ORGANIZATIONAL DECISION-MAKING 8.1

Purpose

The purpose of this section is to describe environmental planning as it relates to activities for environmental performance and organizational decision making, including plans and decisions on capital improvements, product and process design, training programs and maintenance activities. It also describes the establishment of environmental targets and objectives.

8.2

Responsibility

The top management of the Company comprised of the Managing Director, CFO, Safety & Quality Manager, Technical Manager, Operations Manager, Crew Manager, Supply Manager and vessel Masters, and which includes the ECM, shall be responsible for the administration and implementation of this procedure throughout the organization. The Technical Manager shall be responsible for collecting all information that shows compliance with the EMS and related logs, forms and reports for their department and ensure that the information is forwarded to the ECM. Each Master shall ensure proper compliance with the procedure and notify the ECM about the progress onboard their respective vessel. All personnel onboard are responsible for compliance with the EMS and related logs, forms and reports within their areas of expertise and shall report the progress to their superior.

8.3

Environmental Planning

The ECM oversees the environmental planning. He is charged with providing environmentally oriented review of all the development proposals, which are brought before senior management. The ECM also coordinates the review, research and evaluation of environmental internal audits, anonymous reports, and suggestions from officers and crew. He is also tasked with providing management with the environmental significance impacts and lends support to the evaluation and implementation of policies, objects, and targets as they pertain to the environment. 8.4

Objectives and Targets

Environmental objectives are overall goals for environmental performance. Environmental targets are descriptions of how environmental objectives will be achieved within a specific timeframe and should be specific and measurable. Objectives and targets shall be reviewed and revised at least once a year and shall take into consideration the following factors: •

Relevant findings from environmental reviews and audits.

•

Applicable legal and other requirements.

•

Identification of environmental aspects and associated impacts.

•

Technological, financial and operational requirements.

•

The views and reports of staff and other interested parties

The top management of the Company shall set environmental objectives and targets. "Management Review" meeting, the objectives and targets shall be reviewed.

During the

The objectives and targets MUST consider: legal and other requirements; significant environmental aspects; technological options; financial, operational and business requirements; and views of interested parties. They must also be consistent with the Environmental Policy, including the commitment to pollution prevention (prevention, recycle/reuse, treatment, and disposal). Appendix 6 describes the environmental objectives and targets visualized by the Company.

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THETA MARINE – IMO NO. 9. MAINTENANCE OF RECORDS & DOCUMENTATION 9.1

Purpose

The purpose of this section is to describe the documentation relating to this EMS Manual and to ensure that such documentation is properly reviewed, authorized and controlled.

9.2

Responsibility

The ECM shall be responsible for administering and implementation of this procedure throughout the organization. Each department head shall ensure proper compliance with the procedure. Each vessel Master shall ensure proper compliance with the procedure onboard.

9.3

EMS Manual

All pages • • • • • •

shall contain the following information on the header and/or footer bar: Company Name Name of Manual Approval Authority Revision Date Revision of Specific Page Chapter & Page

This system ensures that every page in this Manual has a unique identity. All documents on board and ashore can only be regarded as controlled where the page format as described above exists. This EMS Manual will not be issued or released to a third party (with the exception of the relevant authorities and auditors provided herein) without the express permission of the ECM. When a section of the manual is copied as a workstation instruction, the copy must be marked as uncontrolled and signed and dated by the Master. Amendments to the EMS Manual shall be made by the ECM and approved by him in consultation with the Managing Director. When an amended section of a document is issued, the relevant page shall be altered as appropriate and forwarded to each document holder, together with a new record of revision page. Change to the Appendices may be authorized by the ECM and are not required to be approved by the Managing Director or relevant government authorities. The distribution of the EMS Manual is detailed in the Distribution List located in Chapter 2, Par. 2.3 of this Manual. The distribution of the controlled copies to the vessels will be maintained by the ECM.

9.4

EMS Records

EMS records are comprised of the records generated as a result of the implementation of this EMS Manual and include the following: • Shipboard checklists and reporting forms of the SMS Manual • EMS circulars • Audit records (including internal audits, third party audits and reports, audit working papers and correspondence, including e- mails about audits) • Oil record books • Garbage record book • Bilge & Waste Tank Daily Sounding Log • Communication records relating to feedback as required by the EMS manual • Training records • Declaration of Environmental Commitment • Declaration of Environmental Compliance • Anonymous reporting box findings • Oil pollution incident log • Fleet Engineering Survey by vessel’s Engineers

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THETA MARINE â&#x20AC;&#x201C; IMO NO. 10. POLLUTION PREVENTION 10.1

Purpose

The purpose of this section is to summarize the program established by this EMS Manual for preventing, reducing, recycling, reusing, and minimizing waste releases, with a primary emphasis on vessel engine room operations, including procedures to encourage material substitutions, where necessary and appropriate.

10.2

Procedures

The Environmental Policy Statements contained in Section 1 provide the framework on which this EMS manual is based. The Management of the Company is totally committed in implementing the mandates of this EMS Manual. Section 5 describes the process for preventing, controlling or minimizing reasonably foreseeable waste stream releases, through identification of significant environmental aspects. Section 8 describes the written targets and objectives of the Company to reduce, recycle, reuse and/or minimize waste releases. Chapter 10 of the SMS Manual describes the maintenance system to be implemented on each vessel so that the equipment used for processing the waste releases such as Oily Water Separator, Bilge Pumps, Incinerators, Oil Content Meters, etc are tested and maintenance affected at regular intervals. All Company personnel, ashore and shipboard are encouraged to identify material substitutions or processes which will reduce occasions of equipment malfunction and deterioration, operator errors or deliberate malfeasance. Such reports or concerns are to be sent to the ECM as soon as practicable. The ECM shall review the reports or concerns with the appropriate head(s) of department and future action implemented, where necessary and appropriate.

10.3

Additional Measures for Engine Room Operations

The Company has identified the following additional measures to be undertaken in the fleet for minimizing waste releases from the engine room.

10.3.1 Tank Sounding Log Book The engine room crewmembers onboard every Company vessel shall maintain a Tank Sounding Log Book. Soundings of the waste oil, sludge, and bilge tanks shall be taken during each watch for vessels having a manned engine room or twice daily at fixed times for those having an unmanned engine room. Each entry in the Tank Sounding Log Book shall be initialed by crewmember that obtained the reading. The Chief Engineer shall also sign each set of soundings, verifying that the soundings are accurate. The Tank Sounding Log Book shall be maintained in the engine control room and made available to Flag and Port State authorities during all inspections and to company and third party auditors during SMS and EMS audits. The Tank Sounding Log Book shall be a bound log with page numbers. All entries in the Log Book shall be made in ink. Corrections made to entries shall be crossed out, initialed by the Chief Engineer, and the proper entry inserted alongside. The Tank Sounding Log Book shall be maintained onboard the vessel for the three years. The form EMS - 014 of the Tank Sounding Log Book is contained in Appendix 8 of this Manual.

10.3.2 Leakage Log Book Leakages from pump glands, however minor shall be attended to as soon as practicable; the purpose being to reduce the amount of water or oil contributing to engine room bilges. The Chief Engineer of the vessel shall instill such procedures amongst the engine crew through his standing orders and training sessions. All leakages shall be recorded in the Leakage Log Book. In addition, anytime any line or component on a fuel, lube, or waste oil system fails, including high pressure lines on diesel engines, a record shall be made in the Leakage Log Book with a notation given as to the quantity released and an explanation given on how the unintended released fluid was handled. Additionally, unintended releases

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THETA MARINE – IMO NO. 11. CONTINUOUS PROGRAM EVALUATION & IMPROVEMENT 11.1

Purpose

The purpose of this section is to describe the procedures for continuous evaluation and improvement of this EMS Manual.

11.2

Responsibility

The ECM shall be responsible for the administration and implementation of this procedure throughout the organization. Each department head shall ensure proper compliance with the procedure. The Master of each vessel shall ensure proper compliance with the procedure onboard.

11.3

Internal Audit

The ECM or a person designated by him shall carry out an internal EMS audit onboard the vessel to verify compliance with the procedures set forth in this EMS Manual and all other applicable environmental requirements. Each Company vessel shall be audited annually. The procedure for an internal EMS audit shall follow similar procedure as detailed in Safety Management Manual relating to internal audits carried out for verification of compliance to ISM code. Initially to implement the system more frequent audits may be required and shall be so carried out.

11.4

Management Review

The Environmental Management Review Committee comprised of Department Heads and the ECM/DPA shall conduct management reviews of the Environmental Management System at least once a year to verify the continuing suitability, adequacy and effectiveness of the system. The review is intended to provide opportunities for improvement and to identify the need for any changes to the organization of the EMS. These management reviews shall also serve as a basis for the annual report to the Managing Director. Documentation of the Management Review shall be maintained as part of the EMS recordkeeping.

11.5

Management Review Input

The input to the management review may include the following: • Results of all audits • Feedback from Company personnel • Masters’ and Chief Engineers’ feedback by way of hand-over reports and Fleet Engineering Surveys • Status of preventive and corrective action taken • Follow-up actions from previous management reviews • Brief details of the training conducted • Planned changes that affect the EMS, including this Manual • All recommendations for improvements • Suitability, adequacy and effectiveness of the EMS, including this Manual.

11.6

Review Output

The minutes of the management review shall be recorded and made available to the Company personnel ashore. Relevant sections, if any, of the management review shall also be sent by the ECM to the vessels for training and compliance. The minutes of the management review shall be included in the report to be sent to the Directors of the Company, regarding the implementation of the EMS and this Manual.

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THETA MARINE â&#x20AC;&#x201C; IMO NO. 12. IMPLEMENTATION SCHEDULE 12.1

Purpose

The purpose of this section is to describe the implementation schedule of the procedures as set out by this EMS Manual.

12.2

Schedule

Except where stated, the procedures as described shall be implemented within Two (2) months of the date of approval of this EMS Manual by the Company.

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THETA MARINE – IMO NO.

APPENDIX LIST APPENDIX- 1 APPENDIX- 2 APPENDIX- 3 APPENDIX- 4 APPENDIX- 5A APPENDIX- 5B APPENDIX- 5C APPENDIX- 5D APPENDIX- 5E APPENDIX- 6 APPENDIX- 7 APPENDIX- 8

"ENVIRONMENTAL MANAGEMENT SYSTEM ORGANIZATION" "ENVIRONMENTAL COMPLIANCE MANAGER & MANAGEMENT CONTACT DETAILS" "LIST OF ENVIRONMENTAL ASPECTS" "ENVIRONMENTAL TRAINING FOR SHIPBOARD PERSONNEL" "STANDARD OPERATING PROCEDURES FOR THE OILY WATER SEPARATOR" "STANDARD OPERATING PROCEDURES FOR THE INCINERATOR" "STANDARD OPERATING PROCEDURES FOR THE SEWAGE TREATMENT" "STANDARD OPERATING PROCEDURES FOR THE SEAL PROGRAM" "STANDARD OPERATING PROCEDURES FOR WASTE DISPOSAL" "ENVIRONMENTAL OBJECTIVES & TARGETS" "EMS RECORDKEEPING" "ENVIRONMENTAL MANAGEMENT SYSTEM FORMS"

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THETA MARINE – IMO NO. APPENDIX- 8 "ENVIRONMENTAL MANAGEMENT SYSTEM FORMS" 001 002 003 004 005 006 007 008 009 010 011 012 013 014 015 016 017a 017b 018 019 020 021 022 023 024 025 026 027 028

EMS Familiarization for Engine Department Staff EMS Familiarization for Deck Department Staff Declaration of Environmental Commitment for Master & Chief Engineer Declaration of Environmental Commitment for Chief Officer, 2nd Engineer, 3rd Engineer & 4th Engineer. Declaration on Sign-Off for Master, Chief Engineer, Chief Officer, 2nd Engineer, 3rd Engineer & 4th Engineer. Environmental Component of Master’s Handing-Over Notes Environmental Component of Chief Officer’s Handing-Over Notes Environmental Component of Chief Engineer’s Handing-Over Notes Environmental Component of 2nd Engineer’s Handing-Over Notes Environmental Component of Bosun’s Handing-Over Notes Environmental Component of Electrician’s Handing-Over Notes Environmental Component of Chief Cook’s Handing-Over Notes Fleet Engineering Survey Sounding Log Leakage Log Oil to Sea Interface Log Engine Room Seal Log Book Deck Environmental Seal Log Book Master’s Seal Log Book Fuel Oil / Lube Oil Management Report Refrigerant Leak Log Deck & Engine Room Flexible Hose Inventory Waste Water Discharge Log Bilge and Sludge Production Report Fluid Segregation / Drain List Environmental Protection Procedures for Non-Crew Members Environmental Management System Audit Checklist Environmental Critical Equipment Spare Parts Inventory "Environmental Familiarization Report - Shore Personnel"

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