U.S. Port State Security  (addendum to special circular No.02-002)

15 November 2002 No. 02-008
Please refer our special circular No.02-002, "Criminal Liability in the United States for MARPOL Violations and United States Port State Security". The above circular, quoting a summary of presentation regarding U.S. Port State Control policies given by Mr. John D. Giffin of Keesal, Young & Logan, indicated the following measures to be taken by the ship.

"G. Ship's engineers should be cautioned to insure that all transfers and discharges of bunkers or oil of any type are properly recorded in the ship's Oil Record Book. This includes transfers among tanks within the ship."

However, while MARPOL requires engineers to record transfers of bunker fuel for purposes of ballasting or cleaning of fuel oil tanks, there is no specific requirement that routine transfers of bunker fuel, such as transfers from storage tanks to day tanks be recorded in the ship's Oil Record Books. According to Mr. John D. Giffin who has recently discussed with U.S. Coast Guard in this regard, U.S.C.G.guidelines, followed by U.S.Flag vessels, indicate that such routine transfers should be recorded and also U.S.C.G. boarding officers have, on certain occasions, instructed Chief Engineers on non- U.S.Flag vessels to record such routine transfers in the ship's Oil Record Book. Therefore, though it is not required by the regulations, it is a recommended practice that such routine transfers be recorded.