environmental assessment management in the mme · lakewide management plans (lmp) are being...
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ENVIRONMENTAL ASSESSMENT AND MANAGEMENT IN THE M M E
SWPLNG LNDUSTRY
A Thesis
Presented to
The Faculty of Graduate Studies
of
the University of Guelph
by
MICHAEL PAUL DYSZUK
In partial fulflrnent of requirements
for the degree of
Master of Arts
November, 1997
O M. Paul Dysmk
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ABSTRACT
ENVIRONMENTAL ASSESSMENT AND MANAGEMENT iN TEE MARINE SHIPPING INDUSTRY
Michael Paul Dyszuk
University of Guelph, 1997
Advisor:
Professor R. D. Kreutzwiser
This thesis explores a mechanisrn for the deterrnination of environmental
cornpliance on Canadian, Great Lakes merchant marine ships. It involves the
developrnent, application and evaiuation of an environmental compliance audit.
An environmental cornpliance audit was chosen as these audits are a recognized
tool for assessing compliance. Upon completion of each audit of four ships, a
determination of the degree of environmental cornpliance was made, then an overall
consensus was established. The ships surveyed in this study complied with the applicable
regulations and guidelines.
The audit instrument and protocol were evaluated using comprehensiveness,
relevance, workability and receptiveness as criteria. Critical questions and a rating system
were used to substantiate each evduation criterion. Data sources included: the Canada
Shipping Act; Canadian Coast Guard personnel and documents; the ships' official
record/log books; interviews with the ships' personnel and a walk about. The ratings were
synthesized and a general evaiuation was rendered for each criterion. Then an overall
evaluation judgement was then made based on the results of each criterion. The audit's
strengths and weaknesses were then evident from these evaluative conclusions.
The evaluations of the comprehensive, relevance and receptiveness criteria
indicated the audit provided an informeci judgement on the degree of environmental
compliance. The workability was rated as moderate, due only to time restrictions.
Overall, the rating of the audit instrument and was favourable. Enough
information cm be collecteci to cover dl environmental issues and provide enough
information to make an accurate assessrnent regarding a ship's degree of environmental
compliance.
Acknowledgernents
1 would sincerely like to thank Dr. Reid Kreutzwiser, my advisor, for his continuous
guidance and encouragement throughout this thesis. Kis ability to meet me and return
numerous dr& copies with constructive criticisms, on short notice is greatly appreciated.
Also, sincere thanks to Dr. Richard Kuhn for being a mernber of my cornmittee and for his
edito~ai work, and to the Department of Geography for its continued suppon of a part-
time student who never seemed to be there, but always rernembering me.
The development and application of the thesis' audit questionnaire and protocol
would not have been possible without the valuable assistance given to me by Captain John
D. Pace of Canada Stearnship Lines and Captain John Greenway, Captain Wayne
Hemessy and Eric D. McKenzie of the ULS Corporation. Through their support and the
use of their vessels the field component of the thesis was made possible. The crews of the
ships used in this study are also thanked for their time, helpfulness and willingness to
partake in this research.
ïhanks must also be extended to the Canadian Coast Guard for the extensive use
of their library facilities and Captain Tito DeConcilys for bis unending telephone support
and helping to keep me abreast of the ever changing marine pollution regulations.
Finally, many thanks to my wife, Barbara and Our daughters, Emily and Sarah-Jane
who endured this process dong with me and adjusted to my absence on several occasions.
Their mord support and hugs will not be forgotten.
TABLE OF CONTENTS
Acknowledgements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i
LISTOFTABLES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v
LISTOFFIGURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . vi
1.0 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
. . . . . . . . . . . . . . . . 1 . 1 Marine Pollution and the Merchant Marine Industry 1
1.2 Problem Statement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
1.3 Aim and Objectives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
1.4 Thesis Organization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
2.0 ENVIRONMENTAL MANAGElMENT AND THE GREAT LAKES SHWPINGINDUSTRY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
2.1 Water Resources and Their Management . . . . . . . . . . . . . . . . . . . . . . . . 7
2.2 Marine Pollution . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
. . . . . . . . . . . . . 2.2.1 Marine Pollution From Shore Based Activities 17
. . . . . . . . . 2.2.2 Marine Pollution From Maritime Shipping Activities 22
2.3 Environmental Audits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
. . . . . . . . . . . . . . 2.3.1 Environmental Audits as a Management Tool 31
2.3.2 The Audit Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
3.0 DEVELOPMENT OF AUDIT QUESTIONNALRE AND PROTOCOL . . . 39
3.1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39
. . . . . . . . . . . . . 3.2 Development of the Draft Marine Audit Questionnaire 40
3.3 Initial Ship Visits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40
. . . 3.4 Shipowner Consultation and Preparation of the Final Questionnaire 4 1
Shipboard Visits and Application of the Audit Questionnaire andProtocol . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EVALUATION METHODOLOGY 47
4.1 Evaluation of the Audit Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4.2 Comprehensiveness 48
4.3 Relevance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4.4 Workability 50
4.5 Receptiveness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53
. . . . . . . . . . . 4.6 Overail Evaluation of the Audit Instrument and Protocol 53
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4.7 Data Sources and Analysis 55
5.0 APPLICATION OF AUDIT AND RESULTS . . . . . . . . . . . . . . . . . . . . . . . 56
5.1 introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56
5.2 General Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5.3 Vesse1 History .. ... 59
5.4 Deck Department . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60
5.5 Galley Department . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65
5.6 Engine Room . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67
5.7 LoadingKJnloading Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 77
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5.8 Overall Findings 79
6.0 EVALUATION OF AUDIT INSTRUMENT AND PROTOCOL . . . . . . . . 81
6.1 Evaluation Findings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 81
6.1.1 Comprehensiveness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 82
6.1.2 Relevance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 84
6.1.3 Workability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 89
6.1.4 Receptiveness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 93
6.2 Conclusions . Overd1 Evaiuation o f the Audit Instrument . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . andProtoco1 95
7.0 CONCLUSIONS AND RECOMMENDATEONS . . . . . . . . . . . . . . . . . . . . 98
7.1 Summary of Objectives and Findings . . . . . . . . . . . . . . . . . . . . . . . . . . 98
7.2 Research Contributions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 100
7.3 Recornrnendations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 102
7.4 Future Research Opportunities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 103
8.0 BIBLIOGRAPHY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 104
APPENIDIX A: MARNE ENVIRONMENTAL ASSESSMENT QUESTlONNAiRE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1 1
LIST OF TABLES
4.1 Comprehensiveness Evaluation Questions and Rating System . . . . . . . . . . . . . 49
4.2 Relevance Evaluation Questions and Rating System . . . . . . . . . . . . . . . . . . . . . 5 1
4.3 Workabiihy Evduation Questions and Rating System . . . . . . . . . . . . . . . . . . . . 52
4.4 Receptiveness Evaluation Questions and Rating System . . . . . . . . . . . . . . . . . . 54
6.1 Comprehensive Questions and Findigs for the Audit instrument . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . andProtocol 85
6.2 Relevance Questions and Findings for the Audit hstrument andProtocol . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 88
6.3 Workability Quesiions and Findings for the Audit Instrument andProtocol . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 92
6.4 Receptiveness Questions and Findings for the Audit Instrument . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . andProtoco1 95
6.5 Summary of Evaluation Ciitena Ratings for the Audit Instrument andProtoco1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 96
LIST OF FIGURES
2.1 Sources of Pollutants Entering the Marine Environment . . . . . . . . . . . . . . . . . . 18
. . . . . . . . . . . . . . . . . . . . . . . . . . . . 2.2 Pollution From Marine Shipping Acîivities 23
1.0 LNmODUCTION
1.1 Marine Pollution and the Merchant Marine Industry
Marine pollution is any hurnan action that degrades or impairs the use of water as a
resource (KupcheiIa, 1986). However, marine pollution "... varies not oniy with the
nature of the poliutants, but also with the intended use of the water" (Miller, 1982).
Through the United Nations Convention on the Law of the Sea, there is the
beginning of a cornprehensive global marine environmental management SC heme. The
current state of affairs is one of a multitude of protocols, conventions and regulations at
both the national and regional levels (Côté 1992).
Intemationaily, there are two conventions that address marine pollution - the
London Dumping Convention, 1975 (LDC) and the International Convention for Pollution
fiom Shipq 1973, as modified by the Protocol of 1978 relating thereto (MARPOL 73/78).
These conventions specifically regulate ship generated pollution and the dumping of
wastes at sea (Wafdichuk, 1989). Both conventions are recognized by Canada. Most
countries, including Canada, have additional agreements dealing with other environmental
issues such as shore-based pollution (Waidichuk, 1 989).
The management of the Great Lakes marine environment is complicated by the fact
that part of the CanadaRTnited States border divides the lakes between the two countnes
(CarroU, 1986). The first treaty designed to strengthen bi-national CO-operation was the
Boundary Waters Treaty of 1909 (LeMarquand 1986). In 1970, Canada introduced two
acts to control pollution in the Great Lakes - the Fisheries Act and the Canada Water Act
(LeMarquand, 1986; Nemetz, 1 986).
The Water Quality Agreements of 1972, 1978 and Protocol of 1987 (GLWQA)
committed the governments of Canada and the United States "to a range of programs and
other masures to restore and maintain the integrity of the waters of the Great Lakes
Basin Ecosystem." (Acres, 1991 ). Four Annexes in the GLWQA are directly focused on
pollution fiom shipping activities (Acres, 199 1 ). Under Annex II of the GL W Q A
Lakewide Management Plans (LMP) are being developed. Part of the mandate of these
LMP's is to d u c e the loading of critical discharges fiom maritime shipping activities
(Acres, 199 1 ). The Federal Green Plan, introduced in 1990, lists one of its priorities as
the protection and enhancement of water quality (Governrnent of Canada, 1990).
Ln Ontario, there are several programs and regulations aimed at restoring the Great
Lakes basin and preventing further pollution (MOEE, 199 1). Programs and legislation
including the Canada-Ontario Agreement Respecthg Great Lakes Water Quaiity (COA);
Remediai Action Plans (RAP); Ontario Environmentai Protection Act (EPA) and the
Ontario Water Resources Act (OWRA) are just a few to mention. The control and
regdation of pollutants discharged into the Great Lakes fiom mantirne shipping activities
is enforced by the Canadian Coast Guard (CCG) under the Canada Shipping Act (CSA)
@&onsilys, 1993).
Although there are a plethora of regulations and protocols, pollution fiom
maritime shipping activities still accounts for approximately 12% of the pollutants entering
the marine environment (International Chamber of Shipping (ICS), 1993). What is lacking
is a mechanisrn that cm be used to evaluate the extent of marine poilution fiom individual
ships. Presently the CCG and the United States Coast Guard WSCG) utilize spot
(Little, 1983). These audits measure existing environmental liabilities, current
environmental performance and environmental risk at the tirne the audit was conducted
(Consulting Engineers of Ontario, 1993). Industries are finding that an environmental
audit completed by a third party brings to light areas of environrnental concern that are
often overlooked by in house audits (Harrison, 1984). Canadian environmental audits are
presently based on guidelines that are drawn fiom current environmental legislation
(Livesey, 1 99 1 ).
An environmental audit is usuaily made up of three activities - the pre-visit
activities, the site activities and the subsequent activities (CEO, 1993). The pre-visit
activities include the collection of ail relevant information about the facility. The site
activities consist of a tour of the plant fadities and related operations interviews, personal
observations (waik about) and a records review. Subsequent activities hclude the
evaluation of the findings in a report that details any conclusions and recommendations
with respect to the agreed objectives, any non-cornpliance issues with present or future
regulations/legislation, areas of potential contamination, areas where fûrther investigation
is required to ascertain the degree of contamination, an overail assessrnent of the facilities
environmental stahis, provision of an action plan for the future, and the associated cost to
remedy the situations (Beak Consultants, 1 993).
1.3 Aim and Objectives
This study will develop, apply and evaluate a marine environmental
audithssessment mechanism to assess the environmentai performance of shipping
activities on the Great Lakes, This evaluation will benefit the Canadian Coast Guard in
their efforts to reduce pollution and, ultimately, the Canadian shipowners who will be able
to implement new measures and management systems both on and off shore to reduce the
amount of pollution generated ftom shipping activities.
The specific objectives of the study are to:
develop a maritime environrnental compliance audit questionnaire and protocol.
representing a normative h e w o r k , that pertains specifically to the maritime
shipping induary in the Great Lakes;
apply the environmental compliance audit on selected Great Lakes freighters to
determine their state of environmental compliance and to provide a b a i s for
evaluating the audit instrument; and
evaluate the marine environmental compliance audit instmment and protocol in
terms of comprehensiveness, relevance, workability and receptiveness.
Thesis Organizntion
Chapter 2 will review the literature used to establish the framework, concepts and
method of evaluation relevant to the research. In particular, the review will focus on
marine pollution and the role that an audit instrument and protocol have in determining the
degree of environrnental cornpliance. Chapter 3 describes the methodology utilized to
develop the questionnaire. This chapter outlines the processes (stages) followed in
developing the marine audit questionnaire and related protocol as specified in Objective
One. In Chapter 4, the framework that specifies the criteria used to evaluate the marine
environmental cornpliance audit process is established. Foliowing the evaluation critena,
data sources and analysis are discussed.
Chapter 5 involves the application of the devised audit questionnaire and audit
process and is directly related to the Second Objective. The audit evaluation criteria and
the developed rating system are used in Chapter 6, to evaluate the marine audit
questionnaire and protocol in accordance with the third objective. Specific questions were
developed to evaluate each aiterion and the results were synthesized and a generai
evaluation was determined.
Chapter 7 summarizes shidy conclusions and offers appropriate recomrnendations
to improve the effectiveness of the audit instrument and protocol. The study's research
contributions and future research oppominities are çummarized.
2.0 ENVIRONMENTAL MANAGEMENT AND THE GREAT LAKES SEIIPPING INDUSTRY
This chapter reviews the concepts and methods of evaluation relevant to the
development and implementation of the marine environmental cornpliance audit. The
marine environmental cornpliance audit is a method used to assess and manage
environmental poilution fiom maritime shipping activities. In pankular, the pro posed
audit instrument and protocol focuses on the maritime shipping activities of Great Lakes
frnghters.
The first section of this Chapter provides the basis upon which resource anaiysis or
assessrnent and resource management ideas are formed, including water and marine
resource management. Section 2.2 focuses on a review of marine pollution, its sources,
impacts and effects. This is followed by a review of environmentai auditing practices and
protocols. Environmental auditing is firther discussed as an instrument used to evaluate
the effects of an activity on the environment.
2.1 Water Resources and Their Management
Resource analysis has had several connotations in the past. Mitchell (1 989, pg.3)
defined it as understanding:
. . . the fundamental characteristics of naturd resources and the processes through which they are, could be, and should be allocated and utilized.
Since resource analysis focuses on the understanding of the naturai characteristics
of resources and the mechanisrn through which they are allocated, resource management
then deals with the control or direction of resource developrnent (Mitchell, 1989).
O'Riordan (1 971, pg. 19) dehed resource management as:
. . . a process of decision making whereby resources are allocated over space and tirne according to the needs, aspirations, and desires of man within the fiamework of his technological inventiveness, his political and social institutions, and his legal and administrative arrangements. Resource management should be visualized as a conscious process of decision involving judgement, preference and cornmitment, whereby certain desired resource outputs are sought fiom certain perceived resource combinations through the choice among various managerid, technical and administrative alternatives.
Additionally, OrRiordan ( 197 1 ) stated that althougb resource management is a
combination of social, political and economic processes, it at best is a compromise. As a
result, resource management is: "becoming increasingly concemed with the protection
and enhancernent of environmental quality and the establishment of new guidelines for the
use of such comrnon property resources as air, water and landscape."
Resources are classified as either renewable or non-renewable. Water, a renewable
resource, can also be classified as a flow resource (Fernie and Pitkethly, 1985). A flow
resource is a resource that: ".. . occurs as part of a closed system of movement such as the
hydrological cycle" (Fernie and Pitkethly, 1985, pg. 4). Additionaily what happens or
what use is made of water at one point in its cycle, will result in repercussions in another
part of its cycle. Furthemore,
Water is a transient resource that has value in itself, such as for domestic use and imgation, or as a conveyance of domestic and industrial wastes, a source for hydroelectric generation, a channel for navigation, and a habitat
for fish and wildlife. Everyone who uses or shares access to the resource has a stake in it.
LeMarquand, 1986, pg. 22 1
Cunha et al. (1 96 1 ) derived general principles of water management while
establishing a new water policy for Portugal (Fernie and Petkethly, 1985). They found:
... the basic goal of water management to be to obtain maximum beneficial use of water resources for society whilst at the same time conserving the ability of water resources to sustain beneficiai uses indefinitely. To do this in a situation of mounting demand pressures requires concepts of planning and comprehensive controls.
Femie and Petkethly, 1985, pg. 283
Water resource management has certain obligations to fuifil. Although these Vary
with the availability of resources and the urgency of demand, the obligations usually
include the construction of water storage facilities, flood control, navigation, imgation,
power supply and water and sewage treatment (Fernie and Petkethly, 198 5). As the
pressure for improving or maintaining water quality increases so does the pressure to
control pollution to the aquatic environment (Femie and Petkethly, 1985; Caldwell, 1993).
Further elaborating on this point, Femie and Petkethly ( 1985, pg. 284) stated that:
"Water resource management must deai with existing situations and therefore much of the
work of water management is integrating established uses with new pressures of demand."
Canada has been taken various rneasures in the management of its water resources.
In 1987 the Federal Water Policy was introduced. Its main goal was to: ". . . protect and
enhance the quality of our water resources and to promote the wise and efficient use of
our water." (Govemment of Canada, 1990, pg. 34). Canada's Green Plan also realized the
importance of water resource management as illustrated by the foiiowing:
Even with ail that is being done, there is growing evidence that we are straining the capacity of nature to suppîy d e and adequate supplies and to maintain hdthy and productive water ecosystems.
and
Reaffirming the strategy and goals of the Federal Water Policy, the federal Green Plan sets out the Goverment's contribution to fiirther national CO-
operation efforts to protect and enhance Canada's water resources. Government of Canada, 1990, pg. 34
Efforts by the International Joint Commission (UC) have also been directed at
water resource management. Although the UC does not have political or enforcernent
authotity, the signing of the Great Lakes Water Quality Agreement in 1 972, revised in
1978 and amended in 1987. signified the need for an international tram-boundary water
resource management approach.
The Canada Shipping Act regulates not only shipping activities in Canadian waters
but also pollution from ships (Nemetz, 1986). The pollution prevention sections of the
Canada Shipping Act outline numerous offenses and penalties. The vast number of these
clauses exemplifies the Governmentts cornmitment to water resource management by
reducing and managing pollution f7om ships (Thompson, 1978). The underlying
assumption is that water as a resource has assirnilative capacity, however, overburdening
this flow resource will result in severe repercussions elsewhere in its cycle (Femie and
Petkethly, 1985).
Through the United Nations Convention on the Law of the Sea, there is the
beginning of a comprehensive global marine environmental management scheme. The
current state of aff'rs is one of a multitude of protocols, conventions and regdations at
both the national and regionai levels (Côté 1992). GESAMP (199 1) recomrnended four
criteria that should be addressed if there is to be a wmprehensive marine environmental
management program. These four criteria are: 1) sustainable development; 2) prevention
of h m ; 3) holistic considerations; and 4) intemationai cooperation (Coté, 1992).
Lntemationally, there are two conventions that address marine pollution - the
London Dumping Convention, 1975 (LDC) and Marpoi 73/78 Convention (MARPOL
73/78) (Nauke and HoUand, 1992). These two conventions specifically address the
problems and control of dumping of wastes at sea and ship generated pollution
(Waldichuk, 1 98 9) and are recognized by Canada. Both conventions are administered by
the International Maritime Organization (IMO). Most countries have additional
agreements dealing with other environmentai issues such as shore-based pollution
(Waldichuk, 1989).
In Canada, there is a plethora of conventions addressing marine environmentai
protection or management. The management of the Great Lakes marine environment is
further complicated by part of the CanadaRlnited States border which divides the lakes
between the two countries (Carroll, 1986), and that the two countries view water resource
management and the management of boundary waters differently (LeMarquand, 1986).
The Americans view water resource issues from the point of equity and equitable
utiiization, where the individual water user rights and obligations are recognized
(LeMarquand, 1986). Canadians, on the other hand, view boundary water resource
management in terms of equality and the rights and responsibilities of the two nations
(LeMarquanâ, 1 986).
The first signifiant treaty that was signed was the Boundary Waters Treaty of
1909, which provided "a fi-amework for guiding boundary water policy" and addressed
such concems as equal and similar rights, exclusive jurisdiction over the use or diversion
of boundary waters, and the waters shall not be polluted so as to create injury of health or
property to the other country" (LeMarquand, 1986, pg. 233). The creation of the
Boundary Waters Treaty led the way to the formation of the International Joint
Commission (UC), a bilateral intergovermental advisoty board that deals strictly with the
management of transboundary waters (Nemetz, 1986).
In 1970 two Acts were introduced that were to control pollution in the Great
Lakes - the Fisheries Act of 1970 and the Canada Water Quality Act of 1970, both
administered by the federal governrnent (LeMarquand, 1986; Nemetz, 1986). The
Fisheries Act of 1970 was designed to protect the aquatic environment "through the use of
specifically designated federal constitutional power" (Nemetz, 1986, pg. 5 55). The Water
Quality Act of 1 970 was more focused on encouraging federal- provincial coo peration
through integrated pollution control than on specific control of pollutants (Nemetz, 1986).
The Water Quaiity Agreements of 1972, 1978 and Protocol of 1987 (GLWQA)
committed the govemments of Canada and the United States "to a range of programs and
other measures to restore and maintain the integrity of the waters of the Great Lakes
Basin Ecosystem. " (Acres, 199 1 ). In this Agreement? there are four Annexes that are
directly focused on pollution from shipping activities (Acres, 199 1 ). Annex 4 is concemed
with the discharges of oii and hazardous poLluting substances; Annex 5 considers the
dixharge of vesse1 wastes which includes ballast water and cargo hold wash water; Annex
6 request that reviews of pollution fkom maritime shipping activities be undertaken by both
the CCG and the USCG; and Annex 10, defines hazardous polluting substances (Acres,
199 1).
In Ontario there are severai programs and regulations aimed at restoring the Great
Lakes basin and preventing further poilution (MOEE, 199 1 ). The following descriptions
of agreements and programs were taken fiom a Ministry of the Environment and Energy's,
information sheet. The Canada-Ontario Agreement Respecting Great Lakes Water
Quality (COA) is the mechanisrn that allows Ontario to undertake the directives of the
GLWQA that fa11 with in Ontario's jurisdiction. Remedial Action Plans (RAP) result from
those areas of concem in the Great Lakes that do not meet the general or specific
objectives of the GLWQA RAPs for each area will produce a clean-up/management
program that will lead to the restoration and protection of water uses in that area. The
MunicipaVrndustriai Strategy for Abatement (MISA) (now dehnct ) was a program aimed
at reducing andor eliminating water pollution problems fiom shore-based industries.
Legislation like the Ontario Environmental Protection Act (EPA) and the Ontario Water
Resources Act (OWRA) are designed to enforce the prohibition of discharges of hannfùl
material to the water. The Ontario Water Quality Objectives in addition to sewing as the
basis for charges under the EPA and the OWRq also permit the issuance of a control
order upon exceedance of th& established chemical values. The regulation of pesticides
and its usage is controlled under the Pesticides Act. The Environmental Assessment Act
ailows for the environmentai consideration of any planned large development.
The federai Green Plan, introduced in 1990, lists one of its priorities as the
protection and enhancement of water qualiîy (Government of Canada, 1990). Lakewide
Management Plans &MP) developed under Annex II of the GLWQA are being developed
to "assist in the virtual elimination of persistent toxic substances and in restoring and
maint-g the chemical, physical and biological integrity of the Great Lakes Basin
Ecosystem." (Acres, 199 1). Part of the mandate of LMP's is to reduce the loading of
critical discharges fiom maritime shipping activities (Acres, 1 99 1 ).
2.2 Marine Pollution
Pollution is an undesirable change in the physical, chemical or biological
characteristics of the air, water or land that can harmfully affect the health, survival or
activities of humans or other living organisms (Miller, 1982). Taking this definition a step
funher, Kupchella (1986, pg. 183 ) defined water pollution as:
. . any change in water qudity brought about by human activity that impairs the use of water as a resource or that adversely affects other fions of life.
The United Nations Group of Experts on the Scientific Aspects of Marine
PoUution (GESAMP) approach marine pollution fiorn a different view point. GESAMP
defined pollution to reflect the damaging effects (pollution) that the occurrence
(contamination) of inputs (wastes) have on the marine environment (Clark, 1992). As
defined by GESAMP, marine pollution is:
... the introduction by man, diredy or indiiectiy, of substances or energy to the marine environment resulting in deleterious effects such as: Hazards to human health; hindrance of marine activities, including fishing; impairnent of the quality for the use of seawater; and reduction of amenities.
Clark, 1992, pg. 6
GESAMP's focus is on the human-made inputs to the sea and their darnaging
effects, rather than the natural inputs or wastes. Nahird inputs include organic material
subject to bacterial degradation, metals in run-off from metailurgical deposits, oil from
natural seeps' particulate material fiom the process of erosion, hot water from undenvater
themal springs and to some extent natural radioactivity (Clark, 1992). Humanmade
inputs are a result of shore-based activities off-shore activities and the maritime shipping
industry. These inputs or wastes will be discussed fùrther.
Although the Canadian Coast Guard (CCG), through the Canada Shipping Act
(CSA), does not directly define water or marine pollution, they define what constitutes a
pollutant and what is considered to be a discharge from a ship. Part XV of the CSA (pg.
4 9 , Pollution and Prevention Response, defined a pollutant as:
any substance that, if added to any waters, would degrade or alter or form part of a process of degradation or alteration of the quality of those waters to an extent that is detrimental to their use by man or by an animal, fish or plant that is usefùl to man, and
any water that contains a substance in such a quantity or concentration7 or that has been so treated, processed or changed, by heat or other means, from a natural state that it would, if added to any waters, degrade or alter or form part of a process of degradation or alteration of the quality of those waters to an extent that is detrimental to their use by man or by any animal, fish or plant that is useful to man, and, without limiting the generality of the foregoing, includes cmde oil, fuel oil, heavy diesel oil,
iubricating oil, any other persistent oil and any substance of a class of substances that is prescnbed for the purpose of this Part to be a poiiutant.
The discharge from a ship means:
... any discharge of a poiiutant &om a ship that results, directly or indirectly, in the pollutant entering the water and includes, without Iimiting the generality of the foregoing, spilling, leaking, pumping, pounng, emitting, ernptying, throwing and dumping.
Likewise, the International Convention for the Prevention of Pollution from Ships,
1973, as modified by the Protocol of 1978 relating thereto (MARPOL 73/78), defines a
harmfùl substance as:
.. .any substance which , if introduced into the sea, is liable to create hazards to human heafth, to harm living resources and marine Life, to darnage arnenities or to interfere with other legitimate uses of the sea, and includes any substances subject to control by the present convention.
CCG, 199 1, pg. 8
and similarly a discharge refers to:
. . . harrnful substances of effluent containing such substances, means any release howsoever caused from a ship and includes any escape, disposal, spilling, leaking, pumping, emitting or emptying;. . .
CCG, 1991, pg. 8
In sumrnary, marine pollution is basically any hurnan action that degrades or
impairs the use of water as a resource (Kupchella, 1986). However, marine pollution ".. .
varies not only with the nature of the pollutants, but also with the intended use of the
water" (Miller, 1982). That is to say what might not be suitable for human consumption
may be suitable for industrial use. On the other hand, water that is acceptable for human
consumption rnay not be suitable for brewing beer (Miller, 1982; Kupchella, 1986).
According to the International Maritime Organization (Mû), as illustrated in
Figure 2.1,44% of the poUutants entering the marine environrnent are From land sources,
33% fiom atmospheric depositioq 11% from offshore inputs and 12% from maritime
transportation (MO, 1992).
2.2.1 Marine Pollution From Shore-Based Activities
Shore-based sources contribute 77% of the pollutants entering the marine
environrnent (Karau, 1998; International Chamber of Shipping (ICS), 1393). Pollutants
enter the marine environrnent via atmospheric deposition, direct discharge (sewers), and
urban/agriculturai mn-off.
Windom (1992) identified seven major categories of contaminants fiom land-based
sources. The seven categories are as foliows: 1) litter; 2) sewage; 3) heavy metals; 4)
petroleum products; 5) anthropogenically-mobilized sediments; 6) synthetic organic
compounds; and 7) nutrients.
Litter fiom shore, pleasure boats or ships accumulates in the intertidal areas where
it degrades the marine habitat, aesthetically reduces the appeal of coastal recreational
areas, and interferes wit h other recreational arnenities (Windom, 1 992). In generd, the
problem of Iitter is one that cm be related to either inadequate enforcement of waste
management regdations or lack of waste management regdations (Windom, 1992).
Sewage is one of the most widespread problems in the near-shore coastal zone
(Windom, 1992). BOD and suspended solids are the most prevalent pollutants from
sewage discharges (Kupchella, 1987). Although there has been significant progress in the
treatment of sewage (Kupchella, 1987), eutrophication and decreased dissolved oxygen
Shore Activi
Figure 2.1: Sources of Pollutants Entering the Marine Environment
Maritime
Based ties - 44%
Source: London Dumping Convention
still remain a problem in the littoral zones (Windom, 1992). Illnesses resulting fiom
sewage-contaminated seafood are common and contamination of the coastal area with
human pathogens closes the beaches.
Heavy metals have received much attention due to such instances as the Minimata
Bay episode in Japan and the itai-itai disease. As a result they are considered to be a
threat to the marine environment, but " there is no scientific evidence that such is the
case, except in specific local areas receivhg unmanaged industrial discharges such as those
cited above." (Windom, 1992, pg. 33). Atrnospheric transport and river run-off are the
main sources of deposition for heavy metais (Wiidom, 1992). Due to the extreme
sedimentation in estuaries, large quantities of metals are attached and trapped by the
sediment (Clark, 1992). As a result, during periods of dredging, vast arnounts of
contaminated dredge spoil are excavated and disposed of in marine dumping grounds
(Kupchella, 1986).
A petroleum or oil spi11 is highly visible, especiaily one fiom a large tanker
accident. There are international and national mechanisms dealing with oil spills and the
minimization of releasing oil from transportation activities (Windom, 1992). The input of
oil into the marine environment fiom shore-based facilities and activities is aiso a major
concem. Urban run-off, industrial and refinery wastes, and municipal wastes represent
approximately 50% of the input of oil to the marine environment (Windom, 1992). Unlike
oil pollution fiom shipping activities, oil pollution from shore-based industries and
activities can be regarded as if it were in a steady state at a chronic level (Windom, 1992).
Due to the different compositions of oil and the conditions at the time of a marine
oil spill, it is difficult to determine the exact effects that the spill has on the marine
environment. Cnide oil for example has a high concentration of aromatic hydrocarbons
that are highly toxic which results in immediate kills of a number of aquatic organisms
(Miller, 1982). ûther f o m of oil remain on the water surface, wMe other types sink to
the bottom and fom tar like balls (Clark, 1992).
Other hydrocarbons are ingested into the fatty tissues of some marine organisms,
where they biomagniQ. 3,4-Benzopyrene, a known carcinogenic is one of the chernicals
that biornag* and work their way through the food chah (Clark, 1992). There is also a
generai consensus that even ifthe concentration of oil is not ample enough to kill marine
life, it may reduce the organism resistance to infections and other stresses (Miller, 1982).
Floating or suspended oil also reduces the amount of light that passes through the water
resulting in a reduction of photosynthesis. There is also the possibility of that some oil
compounds rnay interact synergistically with chlonnated and other hydrocarbons and
pesticides, and result in a more lethal concentration of a pollutant that wouid cause more
damage to the aquatic environment than that of each chernical separately (Miller, 1982).
Beside the biological effects of oil pollution there is an aesthetic and economic
component to be considered resulting from an oil spill. The fishing industq and fisheries
can sustain related losses due to lack of maturing fish larvae, fish kills, tainting and loss of
habitat (Clark, 1992). Beaches and recreational resorts also lose financially due to
aesthetic reasons and the closure of beaches. The coating of birds in oil not only has a
lethal effect on the birds but also cause aesthetic and health problems dong the shorelines
(Clark, 1 992).
Shore-based poilution fiom anthropgenicdy-mobilized sediients is also of
concem. Land use practices, deforestation, agricultural practices and lack of erosion
control methods dl contribute to the increased delivery of soils through sediment transport
to the coastal waters (Wimdom, 1992). The increased load of sediment in a water course
not only buries or smothers the benthic habitats, but it also creates increased turbidity
which decreases the arnount of penetrable Light in the water column wndom, 1992). An
increase in turbidity will decrease prirnary production of the aquatic organisms and
associated effects will be felt by fisheries (Windom, 1992). When the sediment load is
increased there is a resulting increase in deposition which allows further bonding of the
chetnicals to the sediment particles, thus increasing the arnount of toxins found in
harbours, estuaries, lakes and river beds (Clark, 1992).
Synthetic organic compounds, especiaiiy organohalogen compounds such as DDT
and PCB have found their way into the aquatic environment either through improper
waste disposal methods, agicultural practices or urban nin-off h i e to the large number
of synthetic organic compounds in existence, 100,000 in 1987 (Kupchella, 1987) and the
number of new ones being created, it is impossible to study each to the point where a
definitive answer cm be denved regarding the compounds fate and effects in the
environment (Windom, 1 992). Also there is a lack of data available concerning either
transfer or exchange between nations which results in careless, if not sometimes, lethal use
of the cornpounds (Wmdom, 1992). It is known that several of the compounds cause
birth defects in animals and that other compounds are carcinogenic. Some compounds
will degrade while others might be concentrated in the upper levels of the food chah
(Miller, 1 982).
Nutrients include phosphorus, nitrogen and other substances t hat support and
promote the growth of such aquatic plant iife as algae and water weeds (Miller, 1982).
According ta CrESAMP, "Approximately al1 of the nutrients from land-based sources
delivered by rivers and 90% transported by the atmosphere, are trapped in ocean
margins." (Windom 1992 pg. 35). Nutnents corne from natural sources and from ever
increasing synthetic sources (fertilizers, industrial wastes). The over abundance of these
nutrients to the marine environment creates algal blooms and excessive weed growth,
resulting in changes to structure of aquatic communities and aesthetic problems. When
they eventually die out and sink to the bottom, they deplete the water's oxygen content
through the process of biodegradation (Miller, 1982; Windom, 1992; Clark, 1992).
2.2.2 Marine Pollution From Maritime Shipping Activities -
Ships carry many toxic substances, not only as cargo but also as supplies for the
day-to-day routine operation of the ship (Clark, 1992; ICS, 1993). The major sources of
marine pollution from shipping activities, as illustrated in Figure 2.2, include: 1) exhaust
gases; 2) cargo holdtank gases; 3) chlorofluoro-carbons (CFCs); 4) oil spillage; 5) cargo
residue; 6) ballast water; 7) hull treatments; 8) liquid wastes; and 9) solid wastes (Marine
Engineers Review, 1 993; ICS, 1993).
Exhaust gases or emissions include emission fkom the engines, boilers, generators
and incinerators (The Motorship, 1990; [CS, 1993). The main exhaust emissions are
nitrogen oxides, sulphur oxides, carbon oxides and unbumt hydrocarbon particdates (ICS.
Exhaust
S pillage
1993). The impact of these poUutants in the atmosphere is the creation of smog, acid rain
and with respect to carbon oxides - the greenhouse effect (ICS, 1993).
CFCs are found on refrigerated ships (refiigerated cargo spaces and containers),
air conditioning systems and insulation (Waldichuk, 1989; [CS, 1993). CFCs in insulation
are used as blowing agents in thermal insulation materials and have been in the past a
critical part of the overall design of refkigerated transport (ICS, 1993). The major issues
with CFCs, once having escaped corn the refiigeration systems, is their ability to erode the
ozone layer and the accumulation of CFCs in the atmosphere contributes to the global
warming process (Waldichuk, 1989; ICS, 1993). Research has indicated that the
depletion of the ozone layer increases the nsk of ultra-violet radiation on humans leading
to an increase of skin cancer and eye cataracts incidents and suppression of the immune
system (Waidichuk, 1989). An increase in ultra-violet radiation also may affect species in
the marine environment that have floating eggs or larvae. Excessive exposure to ultra-
violet radiation may destroy the eggs or larvae (Waldichuk, 1989).
Cargo holds on a tanker emit volatile organic compounds (VOCs). VOCs are
generated dunng the Ioading and bailasting operations of tankers and are generated during
transport of the flammable cargoes fiom tanker cargo tanks (ICS, 1993). The formation
of photochernical oxidants fiom the VOCs emissions are responsible for damage to crops
and forest (ICS, 1993). Additionally, VOCs are a known toxin, they affect the earth's
climate and are associated with certain health risks (ICS, 1993).
Spiliage refers tu the discharge of a hannfùl substance into the marine environment
(MARPOL 73/78). The most visible pollutant discharged from ships is oil (Clark, 1992;
[CS, 1993). The largest cause of oil spillage is marine tanker accidents or collisions (ICS,
1993). However tanker incidents are not the only source of maritime oil pollution. Other
sources include: dry docking (for tank repairs, general ship repairs or regulated
inspections) as ail ships must be fuel fke; marine transfer tenninals (where spillage occurs
due to broken pipelines); bilge and fuel 02s (the discharge of additional water carried in
fuel tanks and the pumping of excess water fiom the bilges, which usuaily contain oil);
and non-tanker accidents ( a ship involved in an accident may lose its fiel to the sea)
(Clark, 1992). According to a report produced by the US National Academy of Sciences
. . . out of a total estimated annuai quantity of 568,800 tons of oil entering the sea from maritime transport sources, the annual input of oil into the marine environment due to tanker and non-tanker accidents is 12 1,000 tons compared with about 4 1 1,200 tons due to operationai discharges. (The remaining 36,600 tons is fiom bunker operations and other minor sources). Normal ship operations are therefore responsible for over 70% of the oil entering the sea fiom maritime transportation.
ICS, 1993, pg. 1 1
The effects of oil in the marine environment were detailed in Section 3.2.1.
Cargo residue. the cargo remaining in the holds afler unloading operations, and
spilage on deck during loading/unloading operations is an area of recent concem. The
Canadian Coast Guard has commissioned a study to detemine the amount of cargo
residue that enten the water (Moms, 1993). Annex V of MARPOL 73/78 classifies cargo
residue as garbage (MARPOL 73/78). Canada is not currently party to Annex V,
however the United States of America has ratified Annex V and is actively pursuing
discharge of cargo residues (United States Coast Guard (LISCG), 1993). The USCG has
established a twelve mile limit, inside of which no cargo residue or sweepings are allowed
to be discharged overboard. The intent of this enforcement is to prohibit discharges in
what the USCG feels is an ecologically sensitive area (USCG, 1993). Speculation with
respect to this regulation and Annex V of MARPOL 73/78 has arisen regarding the
discharge of aggregates and iron ore pellets, as it has been suggested that these discharges
in turn create fish habitat areas (Anderson, 1993). A report produced by Melville
Shipping Ltd. (1 993) indicated that no assessment of the effects of most of the
commodities transported on the Great Lakes has been carried out. Furthemore, any
known information regarding the effects has been extrapolated (Melville Shipping Ltd.
1 993).
The introduction of zebra mussels and the spiny water flea to the Great Lakes is
thought to have originated fiom the ballast waters of a European cargo ship (Ministry of
Natural Resources, 199 1 ; Suzuki, 1993). Ballast waters are also thought to transfer
marine-borne diseases and contaminants (ICS, 1993). In some instances water taken on as
bailast in one port has been so polluted fiom land-based discharges (heavy metal
contamination) that discharge of the ballast water at the loading port has been refised
(ICS, 1993). The severity of the ballast water discharge issue is illustrated by the
introduction of the International Guidelines for Preventing the Introduction of Unwanted
Aquatic Organisms and Pathogens from Ships' Ballast Water and Sediment Discharges
(ICS, 1993). The CCG, dong with some of the Western Lake Superior ports (Thunder
Bay, Duluth/Superior, Grand Marais, Twc, Harboun) and Australia have introduced
voluntary ballast water discharge guideluies to prevent further degradation of the marine
environment (Great Lakes Maritime Industry, 1 993; ICS, 1993). Ballast water containhg
sediments and marine organisms has been show to have an adverse effect on marine
aquaculture, commercial fisheries and possibly human health (ICS, 1993).
Hull treatments or anti-fouling paints, used to prevent marine growth f?om
attaching to hulls of ships have been linked to the presence of tributyltin (TBT) in the
aquatic environment (Goldberg, 1992). TBT is extrernely toxic and is lethal to a variety of
plankton and mollusc larvae (Clark, 1992). ûther hull coatings have contained or
presently contain mercury, arsenic, DDT, PCBs and copper (Gerlach, 1 98 1 ) . To prevent
corrosion of steel hulls, sacrificial zinc anodes are used and bottom prirners usually contain
chromium, lead, zinc and cadmium (Gerlach, 1 98 1 ). Anti-fouling paint releases al1 of its
copper to the surrounding waters (Clark, 1992). Mer mercuIy and silver, copper is the
most toxic metal to marine life (Clark, 1992). TBT has been found to produce deformities
in various species of marine life and shellfish (ICS, 1993). In gastropods, TBT causes
what is known as 'imposex', an diction that causes the growth of male parts in the
femaie species (Goldberg, 1992). This affliction reduces the reproductive rate of this
species (Clark, 1992). TBT has also been known to cause the thickening of an oyster's
shell to the extent that the size of the animal inside has Iittle commercial value (Clark,
1992). Bivalves in the larval stage are exceptionally susceptible to copper and zinc and
cannot suMve in high concentrations of either.
Liquid wastes include oil sludge, spent solvents, sewage and cargo hold/tank wash
water. The effects of the cargo holdftank washings are relatively unknown (Pace, 1993).
Oil sludge has the same effect as oil discharges. Spent solvents, although not unially in
large quantities, are ofien mixed with the bunker oil on board s t e m ships (Mcleod, 1993)
or stored in the slop/sludge tank. Sewage £?om ships has the same effect as sewage
discharges fiom shore-based activities.
Some of the solid wastes such as plastic wrap and bonles, discarded dumage and
general household garbage (food wastes newspapers, cans, bottles, etc.) are introduced to
the marine environment through maritime shipping activities (Gerlach, 198 1 ; Clark, 1 992;
ICS, 1993). It has been estimated that ". . . 1.1 - 2.6 kg per person per day of plastic waste
is generated and nearly al1 thrown overboard. Plastic wrappings of cargo add another 290
t (tonnes) per ship per year and the total amount of plastics discarded by ships may be 6.5
m t y f L , most of it within 400 km of land." (Clark, 1992, pg. 120). According to Clark
( 1 992, pg. 1 2 1 ) ". . . plastic litter is an aesthetic nuisance on arnenity beaches but not a
hazard in the marine environment." The major problems associated with plastic litter and
marine life is the loss of seabed to burrowing fauna by sinking plastic sheeting, the
consumption of plastic by marine animais, the tangling of plastic threads and rings around
fish and marine birds causing starvation or loss of rnobility (Marine Pollution, 198 1; Clark
1 992).
Pollution fiom vessels operating in Canadian waters (e.g., the Great Lakes) is
controlled and monitored through the Canada Shipping Act (CSA) (DeConcilys, 1993).
On February 16, 1993 Canada acceded to Annex I of MARPOL 73/78 which allowed
Canada to implement the international regulations conceming oil pollution. The intent of
acceding to MARPOL 73/78 was to "enhance Canada's stature in the eyes of the
international comrnunity in regard to the fight against global marine pollution (Canada
Gazette, Part I, 1992, Pg. 2429). In addition, other regulations or programs, with respect
to protecting the marine environment, 30 in totai, include the CSA - Air Pollution
Regulations, Dangerous Bulk Material Regulations, Dangerous Goods Shipping
Regulations, Garbage Pollution Regulations, Great Lakes Sewage Pollution Prevention
Regulations, Voluntary Guidelines for the Control of Ballast Water Discharges from S hips
Proceeding up-River beyond Quebec City and the Pollutant Substances Regulations.
Although there exisî numerous regulations and programs to control marine
pollution there are few mechanisms that can be used to determine the extent of marine
poUution resulting fiom maritime shipping activities. Presently the CCG and the USCG
utilize spot inspections to determine the nate of environmental compliance of a ship. As
fuiancial resources are low, the CCG is unable to pursue this activity to its fullest extent
('DeConciIys, 1993). However, most Canadian merchant ships have been inspected by the
CCG with respect to mandatory pollution abatement equipment (DeConcilys, 1994).
What is lacking is a holistic means for assessing the state of environmental compliance on
board ships. The CCG is looking to address this problem in the near future @eConciIys,
1 993; Morris, 1993).
2.3 Environmental Audits
Environmentai Assessments and monitoring programs either evaluate the effects of
a proposed activity prior to development or the effect that the development/activity is
having on the environment (National Research Council W C ) 1990). Most marine
environmentai monitoring programs fail to assess the effects of human activity on the
marine environment (NRC, 1990). Secondly, environrnental managers are unable to
codirm to the public that protective or corrective resource management strategies will be
successfùl in protecting the marine environment (NRC, 1990).
According to the Consuking Engineers of Ontario (CEO) ( 1993, pg. 1 ),
environmental investigations refer to:
. . . a group of activities which measure existing environmental liabilities, current environrnental performance and environmental ris k. These a r a s of investigation are ofien related, in that common elements cm be found in each type of investigation.
The C E 0 breakdown environrnental investigations into three types - liability
assessments, audits and risk assessments. Liability assessrnents are focused on past or
historicai activities of the entity in question. Audits focus on the current activities and risk
assessments are concerned with future environrnental problems associated with the entity.
As the intent of this research is to address the current environmental and
management problems associated with maritime shipping activities, this section will focus
on environmentai audits. Environmentai audits as defined by Du@ and Porter ( 1992, pg.
1706) are:
. . . a systematic, documented, periodic, and objective evaluation of an organization's cornpliance with governmental and Company requirements. Arnong mature environmental auditing programs, audit objectives increasingly include an evaluation of the effectiveness of faciiity environrnental management programs and an assessrnent of the po tential risks associated with site operations.
2.3. Environmental Audits as a Mangement Tool
The Canadian Standards Association (CSA) (1993) viewpoint on environmental
audits parallelled the preceding definitions of environmental audits, and added that an
environmental audit is a means of comrnunicating the results to the entity requesting the
audit. The Arthur D. Little, hc. (1 983), in an environmental auditing workbook prepared
for the Edison Electric Institute, stated that environmental auditing had established itself as
a dominant component of an environmental management program. Thompson ( 1994)
stated that the environmental audit has become a regular part of corporate management in
Canada and that the information gathered from an environmentai audit can be used to
facilitate and enhance environmental management.
ISO 14000, an international environmentai management systern (EMS) guideline
published by the International Organization for Standardization in 1996, has provided
organizations with the elements of an effective EMS that can be integrated with other
management requirements. Additiondy ISO 14000's overall aim is to support
environmental protection and prevention of pollution (ISO, 1996). The ISO has
developed a standardized guide towards UUtiating and rnaintaining an EMS. With the
advent of a detailed initiative such as ISO 14000, there is now a guideline that will be
accepted worldwide for companies to follow to set up and improve their EMS. Part of the
process involves third party auditing, with the audits conforming to ISO 14000 (Standards
Council of Canada, 1 996).
An environmental management system provides the fiamework for a Company to
achieve and sustain environmental efficiency in response to changing regulations,
econornic, social and financiai pressures and environmentai risks (Little, 1983).
Environmental auditing is one means of evaluating overall environmental management and
environmental performance (Little, 1983).
"Environmental audits cm improve a company's environmental management
practice by improving time and resource cornmitments to environmentai issues; refining
predictive capability and assessment methods; enhanchg the quality of project
management; and enhancing a corporate image" (Thompson and nierivel, 199 1, pg. 36).
As Thompson and ThenveL ( 199 1 ) point out, the key to achieving environmentai
compliance is a supportive management that believes in environmental compliance and is
aware of the pertinent regulations. Environmentai audits, however will not provide
oveniight solutions to areas of non-cornpliance but wili indicate to what degree a company
is achieving sound environmental management (Thompson and Thenvel, 199 1 ). An
environmental audit in an environmental management system is a long term management
tool designed to prevent environmental crises (The Task Cornrnittee on Environmental
Auditing, 1986)
Environmental audits, according to Buckley ( 199 1 ), are a vaiuable management
tool for any corporation that uses any publicly owned resource and whose activities and
practices could create some form of public concern, or to obtain developrnent approval.
The same rasons also apply to any finance company who wants to determine prior to
refinancing, whether they face any form of financial risk due to environmentai
management of an entity (Buckley, 1991).
Blumenfeld (1989, pg. 5) indicated that there are at least five important criteria for
initiating an environmental audit. The cnteria are:
1 ) wncem for consequences of non-cornpliance; 2) the belief that environmental &airs should be rnanaged like
financial affairs (with control and frequently by exception); 3) the importance of corporate image to sales and the community; 4) the real belief that protection of the environment is a duty of
operating management; and 5) the environmental liabilities of a property transaction mua be
estimated or determined pnor to the deai proceeding."
Kingsbury ( 1 99 1 ) further elaborates by saying that environmental audits are a
systematic assessment that can be repeated to either evaiuate any improvernents and/or
changes in performance since the last audit and a standard audit that can be used to
evaiuate one port against another.
In conjunction with Kingsbury, Rennis ( 1993, pg. 16 1 ) stated "environrnental
auditing has developed as a tool to rnonitor environmentai performance agauist agreed
policy." Additiondy, Rennis indicates that environmental audits should be conducted at
periodic intervals so the effectiveness of the environmental management program can be
assessed to determine if the policy is meeting its objects, and if so to what extent.
Furthemore, environmental audits, if conducted over t h e , will usually lower the
costs of a corporation's environrnental liability insurance as they indicate that the
corporation has been taking a positive managerial role towards preventing any
environrnental mishap (Harrison, 1984).
The outcorne of an environmental audit is a report that details any non-cornpliance
issues with present or future regulations/legislation, areas of potential contamination, areas
where further investigation is required to ascertain the degree of contamination, an overall
assessrnent of the facilities environrnental statu, provision of an action plan for the future,
and any recomrnendations regarding non-cornpliance issues and the associated cost to
remedy the situations (Be& 1993).
2.3.2 The Audit pro ces^
Environmental audits are now becoming integrated with Total Quality
Management (TQM) prograrns (Du@ and Porter, 1992). Management is not ody
looking at how it c m improve its productivity but aiso how it can promote a stronger
commitment to the environrnent. Industries have begun to realize that there are benefits
associated with promoting environmental awareness. In sorne cases, afler a review of
theïr waste streams, companies have been able to reduce their wastes and its associated
costs by recycling and reusing materiais used in the production of goods. Their
cornmitment to protecting the environrnent has also resulted in a pro-active management
tool used to "ident@, assess and address environrnental concems" ( D u e and Potter, pg.
1706, 1992). In tum, industries are finding that an environmental audit completed by a
third party bring to light areas of environmental concern that are often overlooked by in
house audits (Hamison, 1984).
An environmental audit is usuaily made up of three activities - the pre-visit
activities, the site activities and the subsequent activities (CEO, 1993). The pre-visit
activities generally include: a detailed outline of the agreed objectives of the audit; a
description of the operation(s) (flowchart); a review of the company's environmental
organization, management systems and enwonmental procedures; a review of any
environmental control processes; a history of site operations and a review of any historical
information available (fire insurance plans, aerid photographs, land titleddeeds); a listing
of the applicable regulations and iegislation; any certificates of approval or permits
associateci with the site; and the identification of any hazardous or regulated materials
used on-site.
The site activities consist of a tour of the plant facilities and related operations;
interviews with supervisory and non-supe~sory personnel; examination of records
pertaining to permits, sarnpling results waste rnanifests, hazardous material storage
facilities, monitoring and accident reports; observations of hazardous substances and
waste material storage and handling, storage tanks (undedabove ground); observations of
the facilities property and surrounding land uses; assessment of any areas that indicate
possible environmental contamination; and inspection of d l environmental protection
systems including applicable permits and test results.
Subsequent activities include an evaluation of the findings with respect to: the
performance of the environmental management system; the degree of cornpliance with
relevant regulations; legislation and Company policies; the identification of any problem
areas prioritized with respect to matters with high environmental liability; an assessment of
the environmental control and monitoring systems; a foiiow-up with the regdatory
agencies conceming any outstanding issues or unclarified matters; and the deliverance of
an audit report that details the findings and any conclusions and recornmendations with
respect to the agreed objectives.
Most environmental audit prograrns use some form of guide (a checklist, a
questionnaire) to assist the auditor in an evaluation of the site. (Little, 1983). The use of a
wrinen guide, or protocol, adds congruity to the audit approach and keeps the objectives
of the audit in focus (Little, 1983). The audit guide or protocol is a plan of how the
auditor will accomplish the objectives of the audit. The audit protocol is usually cross
referenced with the auditor's field notes and the completed protocol and field notes serve
as the working papers for the audit report (Little, 1983).
Questionnaires are one form of guide or protocol. There are three basic types of
questionnaires - the yesho questionnaire, the open-ended questionnaire and the scored
questionnaire/ rating sheet. The yeslno questio~aire tends to be a questionnaird inquiry
driven audit rather than a review/exarnination audit; the open-ended questionnaire
promotes a fact finding and recording type of audit. The scored questionnaire results in a
grading type of audit report (Little, 1983). The other types of guides are a basic protocol
which is :a step by step sequence of topics to be reviewed, how they are to be examined
and what is to be recorded in the working papers; the typical outline which lists the topics
to be reviewed and the marner in which each is explored is left to the discretion and
expenence of the auditor; and the detailed audit guide which provides the standards and
requirements upon which the audit is based and oflen is in a flow chart format (Little,
1983).
Developing an environmental audit that can be applied to the maritime shipping
industry to monitor and assess the activities on board a merchant marine vessel. not ody
involves the practicality of waste management issues but also the growing change in
corporate environmental policies. According to the ICS (1993, pg. 4):
The comerstone of good management is cornmitment fiom the top. It is therefore essential that senior management provides directions, guidance and standards that are: consistent with international and nationd law and with relevant industry codes of practice; redistic, practical and easy to follow; understood by al1 personnel; and evduated, reviewed and updated on a regular basis.
Canada's federai Green Plan (1 990) recognizes audits as a highly useful tool that
cm measure performance against desired objectives and goals. The Green Pian (1990)
also recognizes audits as a means of assessing employee training and intemal
communications.
The audit instrument and protocol developed in this research is one method of
monitoring the enwonmental management system on board a ship. The literature review
indicated that enwonmental audits are a valid tool for assessing environmental cornpliance
and awareness. As maritime shipping activities utilize one of our most vaiuable resources,
the water, the geographer or resource analyst has an important role in the formulation of a
method of appraisai for resource use. Additionally, the concept of assessing and
monitoring madime shipping activities involves a interdisciplinary viewpoint. Mitchell
(1 989, pg. 14) indicated that "The complexity of resource analysis suggests that more
than one discipiinary viewpoint is required to conduct the necessary research."
Environmental auditing of maritime shipping activities requires that the bais of the
questionnaire be founded not only in the engineering discipline, but a is0 in marine biology,
waste management, and marine transportationhavigation. Marine engineering plays a
vital role in the design of the questionnaire with respect to the operation of the engine
roorn. Marine biologykcology is used to determine what chemicais are detrimental to the
marine environment and their impactdeffect. Waste management on a ship is different
fiom that of on-shore facilities - the ship is constrained in its waste disposal methods and
availability to do so. Finally a marine transport/ navigation technologist is a vital Iink to
understanding what safiety measures are incorporated into the d e and efficient operation
of the ship, to further prevent the chance of an environmental mishap and the management
of cargo loaded or unloaded frorn the ship.
An oppominity has emerged not only to examine the environmental practices and
management of the maritime shipping, but also to assess and monitor the effects the
industry has on the marine environment. The irnpiementation of an environmental
maritime shipping audit will be a useful mechanism in assessing the impacts of maritime
shipping (Objective 2).
3.0 DEVELOPMENT OF AUDIT QUESTIONNAIRE AND PROTOCOL
3.1 Introduction
This research involved six stages. The first stage was the development of a draft
marine environrnental cornpliance audit questionnaire. The questionnaire was based from
the literature review, shipboard orientatiodinventory, and k t pnnciples frorn the
researcher's experience in conducting shore-based facility environmental compliance audits
and work experience in the merchant marine industry. The second stage involved the
application and revision of the draft pre-test questionnaire and protocol. Upon completion
of the draft questionnaire and protocol, the third stage required consultation with the
respective shipowners. The questionnaire and protocols were reviewed and changes were
made to ensure that concems of the shipowners were addressed. The fourth stage
involved the selection of the ships used in the study. These ships represented the bulk
cargo type of ships currently engaged in the Great Lakes trade. The fifih stage involved
the application of the marine environmental compliance audit and protocol on the four
Canadian Great Lakes freighters. This stage focused on adrninistering the questionnaire
and following the developed protocol. The final stage involved developing and applying a
framework and criteria to evaiuate the environmental compliance audit mechanism.
The purpose of this chapter is to outline the process (stages) followed in
developing the marine audit and questionnaire and related protocol. The subsequent
chap ter describes the fiarnework and critena developed to evahate the marine instrument
and protocol.
3.2 Developrnent of the Draft Marine Audit Questionnaire
The following methodological approach was adopted to meet the first stage
objectives:
A questionnaire khecklist was developed from issues identified in the literature review as well as the researcher's experience with shore-based audits and the marine shipping industry;
Regdations and related material, such as the Canada Shipping Act regdations pollution control, were obtained and reviewed;
If the regulations/guidelineiprotocols reviewed were unclear, a Canadian Coast Guard Pollution Prevention Officer was contacted for clarification;
A standard environmental cornpliance audit questionnaire, developed fiom existing audit questionnaires used by the researcher for conducting shore-based audits, was used as a template for the development of the maritime audit; and
Information acquired fiom the above steps was used to formulate a new questionnaire that applied specificdy to the marine industry.
Initial Ship Visits
Three Great Lakes' ships were initially boarded to re-familiarize the researcher
with ship board activities, operations and inventory. The ships for the initial visits
represented a straight-back - a ship without any shipboard provisions for cargo unloading
and which is indicative of the older style of bulk can-iers on the Great Lakes an older self-
unioading ship, and a self-unioader of newer construction. The ships chosen were from
two different companies engaged in Great Lakes marine transportation. During these
visits, the initial audit questionnaire and protocol were used as a guideline and revisions
were made to incorporate areas of concern that were identified.
The ship visits were conducteci in late November/earIy December, 1994, while the
ship were in port discharging buk cargo. During the ship visits the researcher was
accompanied by shipboard personnel who were familiar with the daily operations of the
ship. Shipboard personnel included the Captai% the Navigation Officer of the Watch
a d o r the Ship's First Officer for activities relating to the deck department, the Chief
Engineer andor the Engineer on Watch for matters concerning the mechanical operation
of the ship, and the Chief or Second Cook for Galley related maners.
3.4 Shipowner Consultation and Preparation of the Final Questionnaire
The shipowner consultation stage involved meeting with representatives of two
different shipping cumpanies to discuss the environmental audit questionnaire. During the
consultation meetings, the drafi questionnaire was reviewed in detail and additional
changes were made to incorporate concems of the shipowners. The meetings aiso
provided feedback and the opportunity to assinulate areas of concem fkom a ship
management point of view.
The questionnaire was divided into the following 5 general sections:
Section 1 - General Information. This section included general information regarding the vessel classification, owner(s), vessel configuration, environmental and health and d e î y particulars and record keeping. The purpose of this section was to ascertain background information on the ship and its general features for comparisun with other ships.
Section 2 - Vesse1 History. The purpose of the second section was to determine if the ship had any inherent problems that might lead to environmental mishaps and to provide a general history of the ship and its past operation.
Section 3 - Deck Department. The third section was divided into seven subsecîions to provide information regarding the type of navigationai equipment used on board, communication systems, d e t y equipment, deck stores and supplies, types of solid and hazardous wastes generated from the deck department, any waste reduction programs and designated substance awareness. The information obtained from this section provides an insight into d d y operations, awareness of environmental issues and how these issues are managed. It also provides the auditor with an insight to the procedures and practices utilized by the deck department to prevent, address and respond to environmentai issues.
Section 4 - Galley department. This section was divided into four separate categories including stores and supplies, soiid, Liquid and hazardous wastes generated from the daily activities in the galley department, waste reduction prograrns and designated substance awareness. The purpose of this section was to provide the researcher with a sense of environmental awareness on board the ship. Programs that the gdey staffutilized to minimle environmental issues and any program that assisted in the reduction of waste materials from the daily operations in the galley were noted. It aiso provides insight to how the staff have changed practices that reflect environmental awareness.
Section 5 - Engine Room. This section was subdivided into eight sections to include general information about the engine room for cornparison purposes, air emissions ( exhaust systems, incinerators, etc.), heating and air conditioning systems, stores and supplies used in the engine room, solid and hazardous wastes generated designated substances found in the engine room and awareness, fuel transfer operations and the cargo unloading system, if equipped. The information coilected in this section dows the auditor to compare practices on different vessels environmental awareness and preventative programs in place, response to environment ai and any associated training.
After the consultation stage some minor changes were made to the questionnaire in
the fom of more specific questions, e. g., Does the ship have the ability to deploy the oil
containment boom by boat? Al1 ships surveyed were equipped with an oil spill
contingency kit, however it was thought that the effectiveness of the equipment was
related to the amount of time that it would take to deploy the boom. Additional changes
included the rewording of the voluntary bailast discharge controls to reflectfincorporate
any guidelines that were in place on the lakes and not just f?om vessels entering the St.
Lawrence Seaway.
One shipping Company requested that more questions regarding painting and
chipping practices on board be added. For example, is any painting to ship's side
completed when the ship is at berth? What happens to the residual matenal produced
during sand blasting operations and how is it subsequently handled?
In the engine roorn section, more questions were added regarding the maintenance,
history and associated sump operations for the bow t h s t e r . Questions were also
incorporated to reflect the regulations regarding the fuel tank pipes, specific procedures
for overboard pump outs, sludge hose inspection and segregated air fIow ventilation
systems The final audit questionnaire is included as Appendix A..
3.5 Study Ship Seleetion
Upon cornpletion of the audit questionnaire review, four ships were selected that
represented a cross section of the ships employed in the Great Lakes marine trade.
Although pollution from maritime shipping activities is an international problem, the
research focused on the Great Lakes. The scope of this project was detemiined by ease of
accessibility to the Great Lakes fi-eighters, and familiarity with the Great Lakes shipping
industry and its rules, regulations and guidelines. Time and financial constraints also
lirnited the scope of the researcb.
Maritime shipping on the Great Lakes involves various types of ships, such as bulk
chernical tankers, package freighters, automobile/passenger femes, tug and barge units,
bulk carriers and self-unloading carriers. During the 1992 shipping season there were 42
Canadian Great Lakes bulk canying ships sailing with a tonnage of greater than 5,000,000
M/t (Canadian Coast Guard, 1993). Since legislation and regulations regarding chemicai
tankers and their operation have recently been under extensive review not only by the
Canadian govemment but dso international govemments, it was decided not to include
chemicai tankers in this researc h. Passengedautomobile femes were not of particular
conceni as they represent a small fiaction of the shipping activity on the lakes. Barge and
tug units were ornitted for the same reason. The construction and built in safety rneasures
for tanker barges is also under close scrutiny due to recent mishaps.
For the purpose of this study, four Great Lakes bulk carriers were chosen. Due to
the similarity among ships of the same class/type, a large sample section was not
considered necessary. Moreover, the purpose of the research was to develop, apply and
evaluate a marine environmental audit instrument and protocol rather than to
comprehensively assess the environmental cornpliance of the marine shipping industry.
The four ships chosen consisted of one straight back and three self-unioaders. Of the self-
unloaders, one was of older constmction and design, one of newer construction with
different cargo udoading systems, and the fourth ship selected was sailing in a trade that
requires additional equipment due to environmental considerations.
The sample seleetion for the study was based on the maximum variation sarnpling
technique. Maximum variation sampling comprises selecting a sample that has diverse
characteristics such that the data collection and analysis wiil result in two types of findings
- detailed descriptions that are suitable for documenting uniqueness as well as common
patterns amongst al1 that are of significant value derived fiom a heterogeneous sample
(Patton, 1 987)
3.6 Shipboard Visits and Application of the Audit Questionnaire and Protocol
In mid-December of 1994, the four ships were boarded while in port and
discharging their cargoes. As in the first stage of the methodology (Section 3.2), the
researcher was accompanied by personnel familiar with the various aspects of shipboard
operation. The scope of the audit consisteci of three activities: the application of the
questionnaire including in t e~ews with shipboard personnel; direct observations; and
review of pertinent documents or records. This format parallelled the qualitative research
rnethods outlined by Patton ( 1980, 1987) and Marshall and Rossman ( 1989). Patton
( 1 987, pg. 7) stated that:
qualitative methods consist of three kinds of data collection: ( 1) in-depth. open-ended interviews; (2) direct observation; and (3) written documents, including such sources as open-ended A n e n items on questionnaires, personal diaries, and program records.
The open-ended interviews were conducted with those personnel directly
responsible for the various management aspects of the ship. Following the interviews, a
walk about of the ship was conducted so that direct observations, supplementai notes and
photographs could be taken. During the interviews ancilor the walk about, the ship's
records were examined. Canadian Coast Guard records and documents were not
exarnined as part of this assessment. Usually in this type of environmental assessment, a
review of the pertinent agencies' records would be conducted to determine if there had
been any prior matters of concem not revealed throug!! the questionnaire, the ships'
records, the walk about, or as the personnel interviewed may not be completely farniliar
with the history of the ship. [As this was a research project, the researcher did not wish to
draw unnecessary attention to the companies that voluntarily participated in this study].
4.0 EVALUATION METBODOLOGY
This stage of the research involved establishing a fiamework that would speclS. the
criteria used to evaluate the marine environrnental compliance audit process. Following
the discussion of evaluation criteri* data sources and data analysis are discussed.
Evaluation of the Audit Process
To address the evaluation of the audit process, the following criteria were used:
cornprehensiveness;
relevance;
workability; and
receptiveness.
Evaluation, as described by Rossi and Freeman (1 982) and Merman et al. (1 987),
relates to the systematic collection of information or the creation of data about how a
prograrn operates and what effect it is having. Ofien the information collected is used to
determine how the program or subject being analyzed can be improved. Shore-based
industries utilize an environmental compliance audit to collect information about the
effectiveness of their environmentai prograrn at the time of the audit. These audits are an
important component of an environmental management program (Little, 1983) and
mesure a company's existing environmental liabilities, current environmental performance
and environrnental risk (Consulting Engineers of Ontario, 1993). The marine audit
questionnaire and protocol developed by the researcher, is intended to be a similar
evaluation instrument.
The following sections describe in greater detail and justifies the critena used to
evaiuate the marine environmental audit questionnaire and protocol developed and applied
in this research.
4.2 Comprehensiveness
Cornprehensiveness, with respect to the abjects covered in the audit process,
refers to the nurnber and type of activities that are regulated because of environmental
concern. This criterion also addresses whether al1 environmental matters were revealed in
the audit process. Cornprehensiveness can be rneasured against the information revealed
in the literature review, relevant environmental liability issues firom first principles and
topics of concem that are raised by others dunng the implementation of the audit process.
With respect to the type of activity regulated, comprehensiveness also refers to the
degree to which the activity is regulated. In this instance, cornprehensiveness refers to
whether the activity is regulated to the minimum of the standards or whether there is
evidence that suggests extra precautionary steps have been taken (Sabatier, 1977).
Comprehensiveness has been used as a cnterion in evaluating cornpliance with land use
planning regulations (Kreutzwiser and Slaats, 1994; Englander et al. 1977) and tree
conservation regulations (Puddister and Kreutrwiser, 1984).
To masure the comprehensiveness of the audit process, the questions in Table 4.1
were used.
TABLE 4.1: Comprehensiveness Evaiuation Questions and Ratiog System
Criterion and Measurement Variabks
Comprehensiveness
1) Were al1 issues identified in the literature review covered durhg the audit?
2) Were the issues addressed in sufficient detaii?
3) Does the audit instrument provide any means of assessing other activities?
Rating System
comprehensive - 95- 100% of issues identified are covered moderately comprehensive - 75-94% of issues identified are covered not comprehensive - <75% of issues identified are covered
- - - - - - - - - - -
comprehensive - -3% arnbiguity in results obtained rnoderately comprehensive- 5-25% of issues identified were ambiguous required, more detail required not comprehensive - >25% of issues identified were ambiguous; insufficient detail
comprehensive - process allowed for recognition of such actions not comprehensive - no provision for rewgnizing additional precautions
4.3 Relevance
Relevance refers to whether or not the issues addressed in audit process related to
the overall objective - is the ship in cornpliance with environmental replations and what is
its degree of environmentai liability. The relevance of the audit program should provide
the user with a sound basis for deciding whether or not the results lead to determining the
outcome of the program (Hudson et al., 1992). For the program to be relevant, it must
address issues that pertain to the matter being investigated. In the contea of
implementing regdatory programs, Sabatier and Mamanian (1 98 1) have demonstrated
the importance of the reievance of regdatory requirements to the particular problem
addressed. Demonstrating the relevance of regdatory interventions helps to develop
support for the regdations and enhances cornpliance (Kreutrwiser and Slaats, 1994;
Sabatier and Mazmanian, 198 1 ). To measure the relevance of the audit process the
questions and rating system outlined in Table 4.2 were used.
4.4 Workmbility
The workability of the audit program indicates whether the instrument is a
practicd mechanism for determining a ship's state of environmental cornpliance. The
workability of the audit pertains to the ease of access to the information required to base a
decision on. It also relates to the degree of difficulty in implementing the instrument. For
the audit process to be efféctive "it must be practicd, that is, it can be implemented in the
"real world" within the constraints of the situation" (Drawetz et al., 1987, pg. 13). Herman
et ai. (1987, pg. 24) reinforce this by stating that for the process to be feasible (workable),
one rnust "seek to ensure that an evaluation will be redistic, prudent, diplornatic, and
hgal. This includes practical procedures, political viability. and cost-effectiveness."
Additionally, if the audit process is to be a truly workable instrument, it must be repeated
by another person and yield sirnilar results (Harrison, 1984).
To measure the workability of the audit process the questions in Table 4.3 were
used.
TABLE 4.2: Relevance Evaluation Questions and Rating System
1 Criterion and Measurement Variables
1 Relevance
1 ) Were the overall results of the audit supportive of the analysis?
2 ) Was the waik about a relevant exercise in deterrnining the status of compliance on the ship?
3) Was the record search necessary for the final conclusions of the ships' environmental status?
Rating System
Relevant - 95- 1 00% of issues addressed were required to assess level of compiiance Moderately Relevant - 75-94% of issues addressed were required to assess level of cornpliance Not relevant - <75% of issues addressed were required to assess level of compliance
Relevant - 95- 100% of observations made were required to assess levei of corn pliance Moderately Relevant - 7594% of observations made were required to assess level of compliance
- Not relevant - <75% of observations made were required to assess level of cornpliance
- Relevant - 95- 100% of information reviewed was applicable to issues addressed Moderately relevant - 75-94%of information reviewed was applicable issues applicable to issues addressed Not relevant - <75% of information reviewed was applicable to issues addressed
TABLE 4.3: Workability Evaiuation Questions and Rating System
( Criterion and Measurcrnent Variables
1 Workabüity
1) Was the questionnaire a workable instrument within the given ship's port time?
2) Was the record search a workable segment of the audit process?
3 ) Was the walk about a workable part of the audit process?
Rating System
Workable - 95- 100% of questions and answers were completed, accurate and appropriate Moderately Workable - 75-94% of questions and answers were completed, accurate and appropriate Not Workable - <75% of questions and answers were cornpleted, accurate and appropriate
Workable - 95- 100% of the records were accessible and beneficial in determinhg the level of compliance; a thorough record search was completed Moderately Workable -75-94% of the records were accessible and beneficial in determining the level of corn pliance; a satisfactory record search was completed
- Not WorkabIe - <75% of the records were accessible and beneficial in determining the level of compliance; the search was not completed; inconclusive evidence
- -
Workable - 95- 100% of the results obtained tiom the walk about greatly influenced the outcome; easily completed within the port time Moderately Workable - 75-94% of the results had some influence on the outcorne; difficult to complete within the port time Not Workable - <75% of the resuits were of no significance to the outcome a d o r could not be completed in the port t h e
4.5 Receptiveness
Another cnterion that was used to evaluate the audit instrument was the
receptiveness of the ownerdpersomel to questions being asked. If there is a lack of
receptiveness, there exists a stronger possibility that information could be withheld from
the auditor. If information is withheld, the degree of comprehensiveness, relevancy and
workability will decrease. The main problem, assoàated with receptiveness towards the
audit process or auditor, is that information collected rnay not be able to be verified or
checked. For an audit program to be successfut, the cornmitment to undertake an audit
must corne from the top management level. This hopefùlly prevents employees fiom
hiding or covenng up areas of concem (Little, 1983; Blumenfeld, 1989).
To masure the receptiveness of the audit process, the questions and rating system
presented in Table 4.4 were used.
4.6 Overall Evaluation of the Audit Instrument and Protocol
Each criterion will have equal weight in the evaluation of the audit instrument as
they are al1 significant in ternis of the function of the audit. Comprehensiveness ensures
that al1 the issues are identifieci and assessed to the point which the degree of
environmental compliance can be estabiished. Al1 issues regarding environmental matters
must be addressed and evaluated. Relevancy determines whether or not the various
components of the audit process are required to complete the audit to the high degree of
proficiency that is required to determine the overall objective - the extent of environmentai
compliance at the time of the audit. The workability of the audit ensures that this
TABLE 4.4: Receptiveness Evduation Questions and Ratiog System
Criterion and Measurement Variables
Recep tiveness
1 ) Were the shipping company's executives contacted receptive to the undert aking?
2) Were the shipboard personnel receptive to the undertaking?
. - -
3) Were the personnel helpfûl in locating, providing information?
- - - - - - - - - - - --
- Receptive - no hesitancy, very willing to co-operate Moderately Receptive -hesitant at first, after reassurance were receptive Not Receptive - not will'mg to participate
Receptive - no hesitancy, very willing to CO-operate Moderately Receptive - hesitant and cautious at first, but soon warmed up Not Receptive - wanted nothing to do with audit process
Very Helpfùl - information was produced forthwith by al1 personnel; "just ask and you shall receive" Moderately Helpful - personnel reluctant to produce the information requested; would point out where the information could be found, some hesitancy Not Helpful - personnel were not willing to provide the information requested: information was very difficuk to obtain .
evafuation instrument can be completed and is a practical mechanism for detemiining a
ship's state of environmental cornpliance. Workability also indicates whether or not the
audit can be repeated by another person and yield the similar results. Finally,
receptiveness plays a key role not oniy in the ease of obtaining information (in a timely
and efficient manner) but also in obtainïng appropriate and tnithful information required to
evaluate the ship. The degree of receptiveness encountered throughout the audit process
will affect its level of comprehensiveness, relevancy and workability.
4.7 Data Sources and Anaiysis
Data sources for the research included reviewinghspecting the Canada Shipping
Act, Marpol73/78, the on board ûfiïcial Documents and the ship's record books ( Master
Logbook, Contingency Plan Book Mates Records, Safety Inspection Books, Safety and
Environmental Procedures book, Trip Log, Stores Inventory and the Inspection Reports
and Records). Data was dso coilected from the interviews with Company representatives,
and the ship's personnel (both licensed arid unlicensed) and the walk about.
Results fiom the above mentioned data sources were analyzed using qualitative
techniques. The open-ended interviews conducted during the research were a fom of
qualitative research. Patton (1 980) stated that qualitative data consists of detailed
descriptions of situations, documents, records, etc. Since the research invoived a smdl
sample size (4), qualitative andysis was used as the results of an audit process should yield
an individualized outcome and one that cm be used for the purpose of improving
environmental Iiabilities and risks on ships. The above two reasons are included in a
checklist of questions described by Patton ( 1987) to detennine if qualitative methods are
an appropnate evaluation strategy.
5.0 APPLICATION OF AUDIT AND RESULTS
5.1 introduction
This chapter addresses the second research objective: "to apply the environrnental
cornpliance audit on selected Great Lakes freighters to detemine their state of
environmental compliance and to provide a basis for evaluating the audit instrument".
During the audit process, notes were made regarding the cornprehensiveness, relevance,
workability and receptiveness of the audit. These critena will be addressed in Chapter 6.
M e r descnbing the audit activities and the findings, the state of environmental
cornpliance and due diligence on board the four Great Lakes freighters surveyed is
summarized. It should be noted that this summay is not intended to assess
cornprehensively the environmental cornpliance of the Canadian shipping industry, as the
purpose of this research was to develop, apply and evaluate a marine environmental audit.
The application of the audit, on board the ships, was divided into the following
segments: 1 ) General Information; 2) Vesse1 History; 3) Deck Department; 3) Galley
Department; 4) Engine Roorn; and 5) LoadinglLlnloading Operations. In this chapter, the
findings of the audit will be categorized under the above divisions for al1 ships, as opposed
to each ship, in order to provide the general state of environrnental awareness and
compliance on the ships audited.
5.2 Generai Information
Each of the ships investigated were of Canadian registry and were of maximum
seaway size (222.5 rn x 22.86 m or 730 fi x 75 fi). AU the ships were designed to carry
bulk cargo, e. g., grain, iron ore, coai. Crew complement varied from 2 1 to 28 personnel
depending on the type of bulk carrier - straight back or self-unloading; the latter having
the higher crew complement. Al1 ships were in operation 24 hours a day and the crew
worked normal seafàring hourdshifls. The watch system is universal in the shipping
industry with the Master and Chief Engineer being on-cd1 24 hourdday, and the galley
staff working standard meal hours.
Al1 the ships conducted regular monthly d e t y meetings and fire boat drills. Each
ship had a Health and Safety Committee, however there was no environmental cornmittee.
Any environmental concems were raised by the crew dunng the monthly safety meetings.
The environmental awareness among the unlicensed crew (those not employed in
Canadian Coast Guard (CCG) iicensed positions, Le., deckhands, oilers, galley staff) was
not high. Licensed and some unlicensed personnel receive formal training usually through
shore personnel. Environmental issues are discussed and relayed to ship board personnel
through regular visits and mernorandums fiom the shore based operational employees.
The cornpanies that took part in this study did have joint environmental and health and
safety personnel who administered and relayed the appropriate environmental legislation
and regdations to the appropriate ship board personnel.
Al1 ships did have a shipboard oil pollution emergency plan and were fitted with
spi11 response equipment consisting of spi11 booms, absorbent pads and materiai, heavy
duty garbage bags, protective spi11 apparel and a small boadpunt capable of deploying the
spi11 boom. The spi11 response kits were kept either in a special locker or a storage room.
In either case the location of the spiil response kits was readily identifiable. Ail spills are
documented and reported to the CCG and appropriate shore based personnel. There is,
however, no formal on board, hands on, training with respect to emergency spi11
procedures. Al1 ships are equipped with video seminardpresentations on emergency
situations and the proper procedures. In addition each employee is given a manual that
highkghts the basic concepts of emergency response actions.
Fire fighting and lifeboat drills are held every month as required by the CCG. It
should be noted that during an emergency situation the safety of the crew and ship take
preccdence over environmental issues. Once the ship and crew are secured, then and only
then are any environmental issues acted upon.
Ail ships follow the Voluntary Guidelines for the Control of Ballast Water. The
ballast water guidelines are designed to minirnize the effect of foreign aquatic species on
local waters, e.g., the spreading of zebra mussels and the tram-Iake shipment of rnetai
contaminated water taken on at one port and discharged at another. Sediments that
accumulate in the ballast tanks also have the potential to contain heavy metals and other
environrnentally degrading contaminants. Records are kept of ballast water
undertakenings (filling and discharges of ballast water) and are available for inspection
upon request from the agencies concemed. The ballast tanks on the ships that took part in
this study had been recently inspected and there were no immediate concems with the
state and or condition of the tanks. On three of the four ships inspected, it was reported
that the interior of the ballast tanks were not coated with any steel protecting coating. On
one ship, white grease had apparently been sprayed on the interior of the ballast tanks to
prevent nisting. It is expected that the discharge from these ballasts tanks wouid contain
oil and grease particles dong with hi& concentrations of metals (from profonged
submersion in contaminateci harbour waters) that would be discharged to the port waters.
This would further contaminate any receivhg waters. Ballast tank coatings should have a
reasonable resistance to contamination from oil, which couid be picked up when ships take
on ballast water (Motor Ship, 1992).
Al1 the ships included in this study had their hulls coated with an antifouling painî.
Although the chernical composition of the hull coating was unknown, it is presumable that
the coating contained either tributylin (TBT), mercury, arsenic, copper, or DDT. The use
of these compounds in antifouling paint is common as not only does the antifouling paint
prevent marine growth but it also reduces hull maintenance and dry docking costs and
increases fuel efficiency due to less fiction. In tum these benefits represent significant
financial savings. Antifouhg paint that does not contain environmentally degrading
chemicals are available but at a substantially higher con. The use of the above toxic
antifouling paints has not been regulated in the Canadian marine industry and, therefore, it
is likely that the ships involved in this survey wntribute to the degradation of the marine
environment through leaching of toxic chemicals from the hull coatings. The use of TBT
on small boats (less than 25m) has been banned in France, Ireland, the U.K. and the
United States, but is still in use on larger ships and naval vessels (Paipai and Brooke,
1990; Clark, 1993)
5.3 Vessel History
The hiaorical handling characteristics and operations of a ship can potentially
negatively affect the marine environment. According to their respective owners, the ships
surveyed in this study had been operated in a safe and efficient manner in the past and had
no inherent problems that could affect the quaiity of the marine environment according to
their respective owners..
The average age of the ships utilized in this study was 22 years and according to
the documentation aboard, none had any record with the CCG or the United States Coast
Guard (USCG) conceming environmental rnishaps or infractions.
5.4 Deck Department
The deck department is responsible for the safe navigation of the ship, the
supe~sion of the loading and offloading of the cargo, the maintenance painting of the
ship's superstructures (intenor and extenor, except the engine room), the ship's sides
(above the water line), deck and any related deck equipment. The deck department is
also responsible for the maintenance and up keep of the fire fighting equipment and life
saving apparatuses.
Ail the ships surveyed were equipped with minimum navigational and safety
equipment required by both the CCG and the USCG. The proper use and maintenance of
the navigational and safety equipment on board a ship helps to prevent errors or
malfunctions that could contribute to a marine environmental occurrence. Ail ships were
equipped with facsimile machines that had the capabiiity of receiving forecasted weather
maps and aorm wamings. Additionally, the avoidance of, or the preparation for, severe
storrns does contribute to the minimization of marine disasters which in turn reduces the
number and extent of environmental problems in the marine industry. Two of the ships
were fitted with ''ECPINS", a satellite navigation system that is used to monitor the shipts
position and display it on electronic charts. The use of this navigational aid is thought to
reduce the number of groundings and collisions; al1 of which again relate to the number
and extent of manne pollution incidents.
Hiuatdous Chernieah and Storage
Generally the ody chernicals that are related to the deck side operation of a ship
are paints and cleaning solvents, floor cleaning liquids, grease and a limited amount of
lubncating oil. As part of a CCG and USCG requirement. al1 ships surveyed were
equipped with paint lockers for the storage of paints and other deck related flarnrnable or
hazardous chemicals. The paint lockers are equipped with COz fire extinguishing systems,
explosion proof lights and firdsmoke waming systems.
Additionaily, the paint Iockers had some form of secondary containment that
would prevent any spillage h m entering the areas adjacent to the paint locker.
Waste Mmagement
The only solid and/or hazardous waste produced from the deck department is the
generation of empty paint and aerosol cans, which are separated ffom the regular garbage
Stream, bagged and tagged, and sent ashore for proper disposal. Other refuse is collected
and taken to either the ship board incinerator or sent ashore, when refuse disposal
containers are available. Cleaning solvents for the paint brushes and rollers are transferred
to the waste oil tank located in the engine room.
On ships where sand blasting activities are occumng, the sand is recycled and used
until the amount of paint chips in the sand make the operation inefficient. The spent sand
and paint chips are bagged and disposed of when on-shore facilities exist or when the sand
blasting equipment is returned ashore. It is not known whether the spent sand is disposed
of as a designated substance at the appropriate disposal facility by the waste collector.
Given the age of the ships, it is likely that the painted surfaces contain lead, a designated
substance. The histoncal use of lead based paints is not of irnmediate concem to the
health and safety of the ship board crew if the painted surfaces are in good condition.
Should however, renovationirepairs or sand blasting activities be undertaken then the
disposal of painted sufiaces or the residual sand should be tested for lead content prior to
disposal. If the paint is found to contain lead. then the material to be disposed of should
be handled according to relevant shore based regdation and guidelines.
Ail the ships surveyed were fitted with incinerators for the burning of regular
garbage including paper, cardboard, food wastes, other packaging, plastic bottles, and
used rags, some of which have been used in the engine room as oil wipes. No air emission
testing has ever been done on the ship board incinerators identified in this study. Ships are
not ailowed to burn garbage when in port, transiting the Welland Canal or other navigable
nvers. Shore side garbage receptacles have now been provided at several ports, so that
ships may separate their garbage, avoid the use of incinerators and to encourage the
proper disposai of contaminated garbage, e-g., oily filters, oily rags, plastic and glass
bottles, and metal cans.
Sanitary waste is discharged to the ship's sewage treatment system, where it is
treated before being discharged overboard. The raw sewage is treated in a Canadian
Coast Guard approved sewage treatment system which consists of an anaerobic digester
and an ultra-violet sterilizer.
Resihal cmgo
It is common practice after the loading and unloading of the ship's cargo holds, to
wash down the decks. This practice discharges the cargo spillage over the side and into
the surrounding waters. Usually this includes coal, iron ore, grain, phosphates, corn, salt
and gravel. Recently there has been controversy regarding the effects of deck wash on the
marine environment. MeIlville Shipping of Ottawa, Ontario was contracted by the CCG in
1992 to undertake a study which would "investigate the discharge of non-regulated cargo
residues from ships operating in the Great Lakes in order to determine if control measures
are required" (Melville Shipping, 1993, pg. 1 ) The USCG has implemented a regulation
that prohibits deck washing within twelve miles of land. It is expected that Canada will
soon implernent sirnilar regulations.
M e r the cargo has been removed it is common practice to hose down the holds if
a different cargo is to be loaded at the next port of cdl. The waste wash water is
discharged through the cargo hold pumps to the lake water. Although not of particular
concem when cleaning out after a load of grain, it can be detrimental to environmental
quality of the receiving waters when cleaning out after a load of coal or phosphates.
Pumping out of the residual material fiom the cargo holds is restncted to open waters and
outside of boundaries established by the USCG. Potential environmental impairment to
the marine environment is probably very small when diluted by the wash water and by the
fact that the ship is usudly underway when discharging the cargo hold wash water.
Designaied Subsicuices
There was Little designated substance (PCBs, asbestos, lead, etc.) awareness
amongst members of the deck department (Master, Mates, Deckhands, Wheelsmen).
Lighting inside the ship is provided by fluorescent lighting. Fluorescent light fixture
ballasts manufactured prior to 1978 could possibly contain PCBs. This is not usudly a
problem until several ballasts are taken out of seMce due to remodelling, repairs, or
replacement. Generally a lirnited number of PCB containing ballasts can be disposed of
with the regular garbage stream.
The deck department was not able to comment on whether any of the electricai
transformers on board contained PCB oil or not. Generally, it was reported that any
electricai equipment was the ship's electrician's property, if the ship's complement included
one - if not it was the engine room's responsibility. According to two ship board
electricians, it is unlikely that any of the electrical transformers contain oil, as they are
normally air cooled transfonners. In the event that an oil filled transformer was found to
be leaking, it is unknown how the spi11 would be handledcleaned-up and how the
contaminated clean-up material would be disposed of Additionally, it is also unknown if
any of the crew's complement would be aware that the transformer oil could possibly
contain PCBs.
Given the age of the ships in the w e y , it is likely that asbestos contaùiing
material is found in some of the floor tiles, acoustic ceiling tiles, and in the air conditioning
system ventilation pipes. Again the deck department was not knowledgable about the
possible extent and locations of asbestos containing materids. The use of asbestos in floor
and ceiling tiles, and as a insulating matenai in pipe wrap was banned in 1980.
As previously mentioned, the interior walls and most of the other outer surfaces of
the ships were painted AIthough latex paint is now used for al1 intenor painting, it is likely
that the old oil based paints previously used contained lead. The use of oil based paints
for interior surfaces is no longer used in accommodation areas due to its potential to burn
and emit harmfil gases and vapours during a fire.
5.5 Gaiïey Department
The galley department is responsibie for the preparation of meals, the changing of
linens and the cleanliness of the gaiiey. The galley is equipped with several refngeration
units, deep f?yers, cooking ovens/griIls and a food storage pantry.
H-rdous Chemicds and Sîotage
No hazardous chernicals are used by the galley department. The only type of
chemicals used are floor cleaning supplies, oven cleaner, and bleach. These chemicals are
usually stored in a separate store room or in the pantry.
W a e Management
Food wastes and food related wastes (packaging, wrap, etc.) are disposed of in the
ship board incinerator. As with the deck department and glass jars and cans are separated
and disposed of when proper shore side garbage receptacles are available. The paper
waste has been reduced in the galley through the use of cloth rags, cloth aprons and ~10th
pillow sheets as opposed to paper. Styrofoam cups, for take out drinks, have been
replaced by personal plastic mugs.
The oniy liquid waste generated from the galley is spent deep b e r oil. This is
usudly picked up by the engine room department and deposited into the used oil tank. On
one ship, the used deep Q e r oil was put into the walk-in refngerator for solidification and
then sent ashore for disposal. Wash water from the gailey goes to the on board sewage
treatment systern. The deep @ers are equipped with a fire extinguishing system,
activated fiom a remote location.
@ne Depfefrmng Substances
The refrigeration systems on al1 the ships contained Freon 12, a known ozone
depleting substance. On one ship was it reporteci that there had been one refngerant leak
in the past five years. Al1 galley staindicated that the maintenance of the refigerant
systems was the responsibility of the engine room department. With the introduction of
the 1990 Montreal Protocol, generally accepted as the ozone depleting substance
guideline, the refngerant systems on board the ships are to be changed to an
environrnentally fnendly refiigerant .
It was unknown whether the ship board personnel s e ~ c i n g the refngerant systems
are qualifiedAicensed by the Ontario MUiistry of the Environment and have obtained their
Ozone Depletion Prevention card. According to shore based regulations, any person
servicing equipment that contains an ozone depleting substance must be trained
accordingly and be licensed to do so.
Designated Substances
Similar to the deck department crew, the galley staff were not aware of any
designated substances on board the ship. They were however aware of the effects of a
refiigerant leak and its ozone depleting properties.
5.6 Engine Room
Hdzzurdous Chernicals a d Sturage
Hazardous engine room stores were generally kept in designated areas on storage
racks and were identified as being such. On one ship, hazardous chemicals were not in an
isolated room but in a section of the engine room while on another ship the hazardous
chemicals were kept outside the engine room in the entrance to the ships's side tunnels.
On another ship there was no such storage area, and chernicals were stored throughout the
engine room, however these chernicals were usually secured to prevent accidental tipping.
The engine rooms that were equipped with storage racks usually had some form of
secondary containment; shelves equipped with lips. However, the size of the containment
system was observed not to be sufficient in the event of a major spill.
On one ship, several metal pails of a highly toxic electricai cleaning fluid were
observed in the electrician's store room, located in the engine room. Aithough the drums
were marked accordingly, they were not secured and could easily be punctured or tipped.
The label on the pails indicated that the product should only be used when a suitable
breathing apparatus is wom by the worker and that there should be no one else in the
engine room when product being used. This chemical is apparently used only dunng
winter lay-up; however it is recommended that this chemical not be stored on board until it
is required for use.
On two of ships, fire fighting equiprnent was not located in close proximity to
hazardous chemical storage areas.
Paints were kept in a paint locker, similar to the one described in the deck
department. Spill equipment, aithough centraiiy located in the engine room was not
present in the vicinity of the hazardous storage areas. It should be noted that only one
ship did not have any spi11 response equipment located in the engine room.
Material Safety Data Sheets (MSDS) were readily available for inspection and
were noted to be up-to-date. In some cases, chemical products that were no longer used
aboard the ship were included in the MSDS binder. It should be noted that only those
chernical products in use should be entered into the MSDS binder to avoid confusion and
unnecessary idormation that could delay the retneval of information when needed.
Fuel and Oil Storage
Of the four ships surveyed, three were diesel powered and the other was steam
powered. Average fuel tank capacity varied fiom approximately 500 to 800 metric
tonnes of bunker "'C" andor heavy fuel oil. Average fuel consumption varied between 2 1
to 32 metk tonnes per day. Each ship was equipped with two large fûel storage tanks,
one on each side and a day tank. The fùel tanks on the ships had been inspected within the
past four years, some of the tanks within the past year. The tanks are required by the
CCG to be inspected every five years. This usually occurs during winter lay-up when one
or several of the tanks are inspected. On some of the ships, the fuel tanks are located
adjacent to the outside shell of the hull, while in others there is a void space between the
tanks and the hufi. Al1 sbips were equipped with double bottoms that would prevent any
tlooding or fuel tank rupture during a grounding.
None of the ships reported any setious fuel tank leaks or ruptures. Mass balances
(i.e., volume in = volume out) are kept on a daily, trip and rnonthly basis. The tanks are
equipped with gauges. however, tank readings known as ullages are taken to ver@ the
amount in the tank. At the end of every trip and month the Chief engineer fills out a fuel
log indicating the arnount of fuel used during that tirne penod. Although minor
discrepancies in the fuel reports may go unnoticed any abnomal consumption (or loss)
would be noticed in the daily and monthly fuel consumption reports. None of the fuel
tanks were equipped with secondary containment systems, as any fuel storage tanks
ashore are required to equipped with. However, the construction and feasibility of such a
system would not be practical on a ship due to lirnited space. Additionally the ship's bilge
acts as a secondary containment system, unless the hull is ruptured due to a collision or
grounding.
Ail of the ships surveyed had smaller tanks for the storage of hydraulic, lubricating
and machine 02. These tanks were equipped either with spi11 or drip pans. There was no
noticeable floor staining around any of the smaller oil storage tanks observed.
Drums containing hydraulic oil lubricating oil or machine oil are commonly stored
around the engine for practicd and "ease of use" reasons. These drums were usually
secured and identified as to contents. In some instances there were no drip collecter pans
or spill trays observed with sorne of the drums in use.
Drums containing the various types of oil are also stored on the stem deck of the
ship. These drums are secured to prevent my movement, and on one ship were stored on
drum storage racks. The drums on two of the ships surveyed were stored directly on the
stem deck, while on one ship they were stored on a wooden platforrn to prevent the
drum's bottom from deteriorating from vibrations and rut. Secondary containment was
not observed on any ship around the outdoor drum storage. The Iack of secondary
containment is of concern as deck scuppen (drains) are usually in the vicinity of the stored
drums. Should a drum Ieak while in port, the oil would migrate to the scupper and be
discharged to the surrounding waters. As a result, the ship could be charged for
discharging a contaminant to the receiving waters. It is recornmended that either the deck
scuppers in the area be plugged or a form of secondary containrnent be instailed around
the drum storage area.
Fuel Tramfer Operations
Second to collisions, fuel transfer operations are the next greatest source of
potential for the discharge of a contaminant to the environment.
During fbel transfer operations, al1 personnel are aware ahead of tirne of their
responsibilities and duties and were knowledgable about the fuelling procedures,
requirements and emergency response actions. Ail the ships were equipped with a fuel
transfer process diagram, usually posted in the vicinity of the on deck fuelling stations and
in the engine roorn. Additionally, a fuel transfer procedures book was readily available.
Prior to re-fuellïng operations on aü ships the following precautions and steps are
taken:
the appropriate deck scuppers are plugged;
the saveaiis around the fuel comection are inspected and drain plugs inserted;
absorbent material is made readily available;
communication with the fùelling facility is established;
purnping rates contirmed;
approximate fiel to be taken on is relayed;
the volume in the tank is monitored as well as the &el hoses and connections; and
the mooring winches are attended to prevent any movement of the ship during fùelling operations.
The fùelling activity is recorded in the Oil Record Book and signed by the Chief Engineer
and the Master.
Ody on one ship had there been an incident were there was a spi11 associated with
the fùelling activities. The spill was the result of an air lock in the iine that caused an
overflow into the saveail when the fùel hose was discomected. Due to the immediate
response by the ship's crew and the availabiiity of absorbent material, only approximately
one gallon of fuel was discharged to the water. The spill incident was recorded in the Oil
Log Book and the ship's Master Log Book and the CCG was notified of the incident.
Warte Management
Waste oil and any oil spillage is collected and transferred to the waste oil /sludge
tank. On a stem ship the used/waste oils are transferred back into the bunker tanks for
consumption. Afl engine mounts pumps, transfer valves and oil purifiers are equipped
with spiludrip pans to collect any spilled fuel/oil. On one ship these pans were directly
connected to the waste oil tank. On the other ships, the drip pans are cleaned on a regular
basis and the coliected oil is transferred to the waste oil tank. In some instances it was
noted that pails with used oil were temporary stored throughout the engine roorn without
being secured and some without lids. Although not of great concem, it reflects poorly on
the housekeeping practices and attentiveness in the engine room. Should any of these
pails spill, the spilled oil would drain into the ship's bilge. In general, bilges of al1 the ships
surveyed contained varying amounts of oil and water. Al1 ships were equipped with bilge
pumps that pass the bilge water through an oiVwater separator (OWS) before the oily
mixture is pumped into the waste oil tank.
The waste oil tank is purnped out at tùelling facilities. Al1 ships are required by the
CCG and USCG to keep and maintain an Oil Record Log. An entry into the log is made
for every fuelling/oil activity, e.g. bilge pumping, waste oil pump out, fuel taken and fuel
transferred .
Oniy one ship was aware of a Muiistry of Environment and Energy (MOEE)
Waste Generator Registration Number (GRN). On shore, ail shore based facilities that
generate more than 25 litredmonth of waste oils, service stations exempted, must apply
for a GRN to be approved to generate certain types/streams of wastes. Generdly ships on
the lakes are given a number that appiies to one of the four Great Lakes and to be used
when completing the waste manifest. It is likely that this one ship had a separate GRN as
its waste oils may not normally be pumped out at a fuelling facility.
Oily rags and used oiVfuel filters were separated from the regular waste strearn on
two of the ships surveyed. Throughout the engine room on these two ships there were
waste receptacles labelled specifically for oily rags. When appropriate shore side facilities
exia or disposal arrangements have been made, this refùse is sent ashore separate from the
ship's regular garbage. On the other two ships the oily rags and used filten are collected
with the regular waste Stream and usually incinerated.
OiWater sepmrim (O KY)
Ail ships surveyed are equipped with CCG and USCG approved OWS's. A
Certificate of Type Test for Oily-Water Separating and Filtering Equipment and a
Certificate of Type Test for Oil Content Meters for the OWS was posted in the vicinity of
the OWSs. The ship's OWSs are equipped with a i m s that sound and shut the system
d o m when bilge water being directed overboard contains more than 5 parts per million
(pprn) of oïl. The OWS is dso connecteci to the used oil receiving tank. The contents of
the receiving tank pass through the OWS to separate the water from the oil, prior to the
oil being pumped to the waste oil tank or the sludge tank. There bas been no confirmatory
testing of the discharged water to ensure its cornpliance with the regulations.
Air Emissions
Air emissions include the exhaua from the engines, generators and bow thnister (if
diesel powered). The concentration of pollutants discharged fiorn a ship's exhaust system
cm be related to the fine tuning of the engine's injectors, air fuel mixture and exhaust
ports and the engine's overall efficiency. Accordingly adjustments are continuousIy being
made to improve the engines' efficiency. Exhaust emissions fiom ships have been under
study by the Marine Environmental Protection Cornmittee (MEPC) and other international
marine organizations/companies (Manne Pollution Bulletin, 1990). It is estimated that
international trade ships contribute 7% of the total world emissions of nitrogen oxides
(NOx) and 4 % of the sulphur compounds (Marine Pollution Bulletin, 1990). No air
emission standards have been set as of yet, however the CCG is researching the
applicability of such air guidelines, given the vast number of different engines in seMce
and operating environments. No air quality monitoring tests have ever been completed for
any of the ships surveyed in this study.
Sewage Treatment Systems
Al1 ships were prov-ided with a sewage treatment system that has been approved by
the CCG, Environment Canada and the USCG. All of the systems were equipped with an
ultra-violet sterilizer, however this systern on one ship was inoperable, and on another
ship several UV sterilizer lights were bumt out. On the ship with the non-operational
system, a new sterilizer had reportedly been on order for seven months. The sewage
treatment systems on aii the ships were reportedly in good working order, with the
exception of the above noted sterilizer unit. The systems are reguiarly maintained.
However, no testing of the water quality discharged from these sewage treatment units has
been conducted on the ships involved in this survey. It should be noted that on the ship
with the non-operational W sterilization system, during the open ended interviews the
syaem was reported to be in good working order. During the walk about it was
discovered to be non-fùnctional.
Ody on one ship does the grey water from the showers and sinks discharge
directly to the open waters. On the other ships the grey water is discharged to the sewage
t reatment system.
Designated Su b a c e s
The engineers and electncians were familiar with possible areas of asbestos
containing materials and the presence or lack of PCBs on board. Traditionally, the
insulating wrap on the exhaust stacks, hot water and stearn pipe lines have contained
asbestos matenals. On two of the ships surveyed the asbestos has been removed by
qualified contractors dunng the winter lay-up period.
On the remaining two ships the engine roorn department was aware of the asbestos
containing materials and had been notified by the shore based management that the
asbestos would soon be removed, if required. Asbestos that is in good condition poses no
harrn to the environment if it is containeci.
The engineers and electricians al1 indicated that any transformers located inside the
ship were probably air cooled, however they were not able to verify this. At the time of
the inspection, the researcher was not able to identi& several of the transformers
observeci. However of the few that were identifiable, they were air cooled. Fluorescent
Iight fixture ballasts were not exarnined, however spare ballasts located in the electncal
supply room were PCB fke. The ballasts for the hi& intensity discharge lights in the
cargo holds and on deck could possibly contain PCBs. Verfication was not possible at
the time of the inspection.
Additional Sources of Oil Pdution
An additional source of oil entering the surroundhg waters is from the stem tube.
This is where the propeller sh& passes through the hull of the ship. The stem tube is
oflen oil lubn'cated and if the oil pressure head is not properly balanced, oil will leak out of
the seal and into the water. Depending on the condition of the seal and the pressure
difference this can arnount to a substantial amount of oil being erroneously discharged.
On none of the ships inspected was this reported to be a senous problem.
The propellers on three of the ships were equipped with variable pitch propeller
blades, rneaning that the sh& spins at a constant RPM while the pitch of the blade
changes to produce a greater "bite" in the water which in tum advances the ship. With
variable pitch propeuers there exists the possibility that the pitch seals could be worn and
hydraulic oil could leak into the water. This was not the case on the three ships equipped
with a variable pitch propeiier as the hydraulic seals were reportedly in good condition,
and there had been no abnomial loss of hydraulic fluids noted. The other ship had a fixed
propeller, in that the direction of rotation and RPMs of the sh& were equated to the ship's
sea speed.
All four ships surveyed were equipped with a bow thruster. The bow thmster
operates in a sirnilar manner to the variable pitched propeller with the same pollution
potentials. No problems with the operation of the bow thmster or oil leakage problems
were reported. However it was mentioned by one Chief Engineer that there is aiways a
minor amount of oil that leaks from the bow thruster during its operation.
5.7 LoadinglUnloading Operations
During the loading of the ship's cargo holds, the ship's crew have little control over
dust ernissions and cargo spillage. The onus for this is the responsibility of the loading
facility and operator. However, after the ship has been loaded and departs the loading
berth the decks are usually hosed down to remove any residual cargo spilled or dust
accumulations. This is nomally done when the ship is underway and out on the lake. The
effects of this practice are somewhat controversial and some studies have indicated that:
ûverall, the cumulative effect of discharges by ships has probably been neghgible to rninor in harbours and neghgible in the Mes.
Melville Shipping Ltd. ( 1993, pg. 7 1)
Udoading operations Vary in two distinctive ways: 1) the unloading of a fieighter
without self-unloading capabilities thus relying on shore based facilities; and 2) the
unloading operations on a ship equipped with its own unloading capabilities. Of the ships
involved in this research project, three were self-udoaders and the other is commonly
known as a straight back (relies on shore based unloading equipment ). Bulk cargo is
removed from the ship's cargo hoids via overhead cranes equipped with buckets (clams).
Dunng this process there is often spillage from the buckets from overtilling of the bucket
and improperly sealed buckets. Some of the spillage fdls to the ships deck which is later
hosed off, as described above and some cargo enters the water behveen the ship's side and
the dock. However, the amount entering the water was observeci to be negligible and not
directly the responsibility of the ship.
On the three ships equipped with self-unloading equipment, d u t emissions frorn
the unloading boom are the biggest concern. NI three ships were fined with water
sprayers to control the dust. However, this is sometimes not feasible, e.g., unloading grain.
The unloading boom on two of the ships was equipped with a tarp undemeath the boom's
conveyor belt to help prevent dust and collect any spillage or residual material on the
boom belt. Al1 three ships were fitted with boom hoods and skirts at the end of the boom
to reduce dust emissions. The amount of dust generated from the unloading operations
can also be wntrolled by the cargo discharge rate. These ships have the capability of
discharging 6,000 metric tonnes per hour.
According to one of the ship's officers, the ship's unloading process has been
stopped on a couple of occasions due to high winds carrying the dust into a residential
neighbourhood. This apparently is rare and not directly related to the unloading
operations, as spraying and a reduced unloading rate were in effect.
Recent studies (Melville Shipping Ltd., 1993) indicated that due to curent
technology and procedures the amount of cargo spilled into the environment has been
greatly reduced and the actual amount is so small that fùrther modifications or controls on
the unloading equipment may be impractical. The shidy fbrther goes on to state that "it
will never be possible to completely eliminate windblown dust nor occasionai loss due to
overfilled clam shell grabs or conveyor belts."
5.8 Overall Findings
The overd findings of the application of the audit questiomaire and protocol was
that the degree of enwonmental compliance and environmental awareness on board a
Great Lakes' ship is not directly related to its style, age or type. The degree of
environmental compliance is related to the effectiveness and efficiency of the crew
employed on each ship and the company's degree of environmental awareness.
Generdy al1 the ships complied with the regulations and guidelines regarding
pollution. Differences in waste management practices can be attributed to the type of run
that the ship is employed on and whether garbage receptacles are available at the
load/unload port.
The variances in hazardous chernical storage facilities are rnainly the result of
available space, the management of the engine room and the lack of governing
regulations. Given the increase of environmental regulations on the Lakes and the
financial constraints of the shipping companies, proper storage facilities are not of primary
concem. Since there are no regulations regarding the storage of these chemicais, a vesse1
equipped with a hazardous storage containment area is usually the result of the diligence
of the engine room complement and the assistance, or lack of, from the shore based
management operations. The stowage of drums ofoil on the stem deck has always been
common practice. However, as noted, some ships have gone to different lengths to ensure
proper stowage, although secondary containment was non-existent on ali of the four ships
surveyed.
Sirnilar fuel transfer operations were undertaken by al1 ships surveyed. As noted
there were no major spills reported during any fuel transfer operations. Ail fuel transfer
procedures and regulations are complied with. The chance of the release of an
environmental contaminant is more directly related to lack of attention during transfer
operations and the mdfunctioning of transfer equipment, in particular the shore based
equipment.
In summary, the degree of environmental cornpliance on a Great Lakes' fieighter is
determined or regulated by the existing regulations and guidelines. That is, ail ships
surveyed in this study complied with the regulations and guidelines as far as applicable.
However, the degree of environmental awareness amongst the ship's crew and assistance
fiom the shore based management operations influences the amount of environmental
diligence taken by the crew above and beyond what is regulated.
6.0 EVALUATION OF AUDIT INSTRUMENT AND PROTOCOL
The audit evaluation criteria and their rating systems, formulated in Chapter 4,
were used to evaiuate the marine audit questionnaire and protocol. For each evaiuation
criterion, specific questions were addressed. The answers were rated according to the
categories established for each criteria. The results fkom the rating were then synthesized
and a general evaluation, based on each criterion, was detemùned. Finally, an overall
evaluative judgement of the audit process was offered based on the synthesized results of
each criterion. The strengths and weaknesses of the audit process will becorne evident
from the conclusions derived through this evduation process.
6.1 Evaluation Findings
To evaluate the comprehensiveness of the audit questionnaire and the audit
protocol, three questions were used. The overall coverage of the environmental issues
that the vessels are subject to is the first cnterion to be rated. Whether or not the
environmentai issues were addressed sufficiently by the environmentai auditing instrument
was a second question. And third, the audit instrument was evaiuated with reference to its
ability to provide means of assessing other activities that may be can-ied out on the ship in
order to further prevent any environmentai mishap and whether additional measures were
taken to ensure cornpliance.
First, in order for the audit questionnaire to be successful, it must include a vanety
of subjects that could pertain to the environmental intelligence of the shipping industry and
its related day to day activities. During the development of the audit questionnaire,
meetings were held with respective shi p owners and other marine related representatives.
to examine the questionnaire and note any deficiencies or areas that were not addressed
that would be pertinent to the environmental audit.
The questionnaire was used as a guide and as a means of collecting information.
The response to the questions and the information gathered indicated that issues of
environmental compliance on board a ship were covered.
During the waik about and the open ended i n t e ~ e w s with the ship's officers and
crew, no additional environmental issues were brought forth. Furthemore, the issues
identified in the fiterature review were comprehensively covered.
The second comprehensive criterion examined whether the issues addressed were
covered in sufficient detail to provide the researcher with unambiguous results. The issues
identified in the questionnaire were covered in sufficient detail that the researcher was able
to detennine the ship's degree of environmentai compliance with the existing regdations
and guidelines. In each section of the questionnaire several questions regarding a certain
environmental issue were asked. The purpose was to identifL if there was any arnbiguity
in the answers from the ship's personnel and the answers obtained through the walk
about/questiomaire. The i n t e ~ e w s with the ship's personnel also presented the
researcher with a good sense about the ship's degree of environmental compliance and
soundness. In some cases, where there was minimal knowledge of a certain environmentai
issue in one of the ship's departments, it would be reflected in the arnount of due diligence
that was taken to either prevent an environmentai rnishap or the extent to which a
protective measure was taken to either ensure or increase the degree of environmental
compliance.
The review of on board documentation also reduced any ambiguity as to the extent
to which the ship practiced and adhered to the environmentai regulations. Aithough there
was no extemai review of documentation held by the ship's owners and the Canadian
Coast Guard or other regdatory bodies, it is the authof s expetience that a review of such
documentation helps to reduce any ambiguity with respect to the ship's degree of
environmental compliance. The record review is beneficial in that most of the documents
reviewed are officiai documents and there is limited bias incorporated into any
circumstances that might have prevailed or led to an environmentai mishap. Additionally
the auditor is imrnediately able to ascertain whether the ship is in or out of compliance and
to what degree.
The review of the on board ship's documentation, the application of the audit
questionnaire and the interviews, and the walk about provided the researcher with
sufficient detail to determine the ship's degree of environmental cornpliance with minimal
ambiguity. As a result, the rating for the audit instrument is "cornprehensive" with
respect to sufficient detail to reduce the degree of ambiguity, if any.
The third part of the comprehensive rating was set up to detennine whether there
was a means of assessing whether further actions had been taken to ensure compliance
with the prescribed regulations or to prevent an environmental mishap. Through the use
of open ended questions and the walk about, the researcher was able to determine whether
any additional activities were taken which wouid enhance the ship's degree of
environmental compliance, thus a rating of comprehensive was given.
In summary, there was a comprehensive rating given to each segment of the
comprehensive criterion (Table 6.1 ). The audit instrument was complete in that it covered
al1 the subjects that were researched in the literature review that are regulated because of
their environmental concern. There were no issues found that needed to be addressed that
were not covered by the questionnaire or the audit protocol. The open ended interviews
and the informa1 discussions held during the wdk about did not reveal any new issues of
environmental concern. The envkonmental issues were sufficiently addressed allowing the
researcher to determine whether each issue was in cornpliance or not. The audit
instrument provided the researcher with a means of assessing whether fùrther activities
had been taken and to what extent to ensure environmental cornpliance or the ship's
practice of due diligence. A synthesis of these three aspects of comprehensiveness
resulted in a detexmination that the audit instrument and protocol were comprehensive.
o. lkk!mxx
The evaluation of relevance examined whether or not the issues addressed in the
audit instrument related to the overall objective - is the ship in compliance with
environmental regulations and environmentally sound?
In order for the audit instrument to be rated as relevant, the percentage of the audit
instrument that was required to determine the degree of environmental compliance on
board a ship had to be determined. It was found that al1 aspects of its operation had to be
taken into account. Therefore a rating of relevant with respect to the number of topics
Table 6.1: Comprehensive Questions and Findings for the Audit Instrument and Protocol
Comprehensive Questions and Rsting System
1) Were al1 the issues identified in the Iiterature review covered during the audit?
-comprehensive: >95% of issues identified, no additional issues need be included - moderately comprehensive: ~ 9 5 % to 75% of issues were identified in the audit - not comprehensive: <75% of issues identified were covered by the audit
2) Were the issues addressed in suficient detail?
- comprehensive: ~ 5 % ambiguity in the issues identified - moderately comprehensive: >5% to <25% arnbiguity in the issues addressed, more detaii needed - not comprehensive: >25% ambiguity in the issues identified, other information was required to determine compliance status
3) Does the audit instrument provided any means of assessing other activities?
- cornprehensive: audit instrument allowed for recognition - not comprehensive: no means of assessing other activities taken to ensure compliance
Audit Inst~menüProtocol - Rating and Reason
- the audit questionnaire did not reveal any issues that had not been addressed - the walk about did not reveal any unaddressed issues - the interview with the ship's personnel and officia1 document review did not reveal and issues that had not been addressed
- the audit instrument was not ambiguous in the issues it addressed and the degree of compliance could be determined h m the results
- the audit instnirnent allowed for the assessment of other activities taken to ensure compliance
and issues covered to achieve the outcome of the program, was determined as al1 issues
were part of an integrated assessment.
The second relevance cnterion question asked: "Was the walk about a relevant
exercise in determinhg the status of compliance on the ship?". The audit protocol
includes a wdk about, as a third party often notices issues of non-conformance that ship's
personnel have become desensitised to. Additionally the walk about helps to verify the
information provided by the ship's personnel. Although the ship's personnel could be un-
easy about the audit process and not willing to volunteer a lot of information, the auditor
is able to ver-@ whether issues that according to the ship's personnel were reporteci to be
in compliance actually are. On one of the ships the septic system was indicated to have
been in good workhg order. Upon inspection of such it was noted that the üV
sterilization lights were not functioning and further conversations with the engine room
crew revealed that they had not been for a while.
In other circumstances the auditor is able to see the degree of environmental
cornpliance and assess it. What was thought to be in compliance with the regulations by
the ship's personnel might ody be marginally in compliance due to lack of maintenance
and normal Wear and tear (deterioration). Drums stored on the deck, although common
practice, are usually lashed down to prevent movement and spillage, but upon closer
examination it was found that some of the dmm bottoms were deteriorating to the point
that spillage could result unless preventative maintenance was undertaken.
Additionally the walk gives an auditor a good sense of the environmentai practices
aboard a ship by the state of the housekeeping. Tell tale signs of spilled oil, the day to day
activities and generally accepted practices often give the auditor a better insight to the ship
and its crew's attitude towards environmental compliance and proactive measures, if any.
Based on the above, the walk about plays an important role in
deterrnininglassessing the overall degree of environmental compliance on board the ship
and therefore is considered to be relevant to the audit protocol.
The third part of the relevance criterion was to determine whether the record
search was a valid part of the audit protocol. Information shared by the ship's officers
could be verified or refuted in the various logs. In some cases the logs contained
additional information regarding the ship's due diligence and other practices to ensure
environmentai cornpliance. The ship's logs are officiai documents and the entries represent
the actual details of precautions taken, and the cause and effect of any mishap.
Previous experience with marine vesse1 auditing and regdatory searches at
govenunentai offices pnor to a ship audit, revealed information reported that was not
shared during the audit questionnaire and interview. Upon presentation of this
information during a ship audit, the ship personnel realized that the information they were
sharing with you could be and usually is verified. When this situation occun, the
intewiew segment of the audit protocol changes such that the information being relayed
becomes more accurate and additional details are not withheld. The information collected
from the record search was rated as relevant.
As noted in Table 6.2, the issues addressed and the means of addressing these
issues were found to be very relevant in deteminhg the ship's compliance with
environmental regulations and whether the daily routines are conducted in an
environmentally friendly rnanner. The i n t e ~ e w process does contain some inherent
problems, such as, in te~ewee willingness to talk the fear of job security - if any mishap is
a result of their practices, could it affect the intenieweefs employment - and the omission
Table 6.2: Relevance Questions and Findings for the Audit Instrument and
Relevance Questions and Rating System
- -
1) Were the overdl results of the audit supportive of the degree of environmentai corn pliance?
- relevant: >95% of the answers~observations were required to properly assess the degree of compliance - moderately relevant: >75% to <95% of the overall results were required to ascertain the degree of compliance - not relevant: ~ 7 5 % of the results obtained were required to detemine compliance
2) Was the walk about a relevant exercise in determining the status of cornpliance on the ship?
- relevant: observation were relevant to verify degree of compliance - moderately relevant: observations were of some importance in verifjmg degree of compliance - not relevant: observations had Iittle or no importance in verifjmg degree of compliance
3) Was the record search necessary for the final conclusion of the ship's environmental status?
- relevant: al1 issues applicable - moderatel y relevant: some issues applicable not relevant: of no value
-
Audit lnstrumentlProtocol - Rating and Reason
- with several environmental issues in each department, al1 answerdo bservat ions were required to determine the degree of compliance through a sound bais
- the walk about provided verification of collected data and additionai information used for determining the degree of compliance
- -
- Reievan t
- ail issues were applicable in determining the environmental status and dl information pertained to the matter being investigated
or changing of some detaiis. The record/document search will provide enough
background that the auditor cari challenge false statements and demonstrate a greater
knowledge of the situation. Additiondly the auditor is able obtain further idormation
from the ship's personnel that is applicable to determining the ship's compliance with
environmental regdations and whether it is environrnentally sound.
6.1 -3 Workability
The workability of the audit instrument and protocol examined whether they were
practical mechanisrns for deterrnining a ship's state of environmental compliance. Three
questions were formulated to evaluate workability. First, was the questionnaire a
workable instrument within the given time the ship was in port? This generally was a 5 to
10 h o u time period. The pilot studies of the audit process provided the evidence to
answer this question. The first audit was conducted during a 10 hour interval. As it was
the first audit, not al1 the information was covered in as much detail as what was intended.
However, the information collected did provide the researcher with enough insight to
clearly determine the outcorne of the audit. In addition, the timing of the process needed
to be refined to allow sufficient tirne for each section.
The next series of audits were conducted on ships which were docked for
approximately 5 -7 hours. It was found that this tirne span was a bit on the short side for
one person as the audit was designed to adrninistered during a 8 to 10 hour time period.
Although the audit process was never tied with two auditors, it was felt that the process
would mn more efficiently with two. However, pnor to using two auditors, the audit
team would have to ascertain each other's roles and responsibilities to avoid missing any
details that are pertinent to the audit outcome. The audits conducted on these ships, with
one auditor, were compieted with a satisfactory arnount of information being collected and
in a cost effective rnanner.
In some instances during the interviews, the in te~ewee had to be interrupted to
maintain the tight schedule. This occurred whenever the information the researcher was
seeking had been obtained and further discussion on a topic was not required. The
in te~ewee was politely made aware that sufficient materialhiormation had been gained.
This had a double effect - first, the personnel felt they were being ignored and second, as a
result of the short time span many issues couid not be discussed to theu fullest. The
information collecteci, however, provided sufficient insight into the issues such that the
degree of environmental compliance on board the ship could be determinecl. As a result of
the short time span and the time required to conducted a complete audit of a ship, the
workability of the audit instrument cm be considered to only be moderate.
The second question used to evaluate the workability criterion was designed to
determine if the record search was a workable search. The record search aboard the ship,
however, due to t h e constraints as noted above for the administration of the
questionnaire, was not sac ient to complete a thorough search of the records. However,
enough valuable information was gathered to allow the researcher to determine the degree
of environmental compliance aboard the ship. A complete record search would have
added more detail to the report regarding day to day practices, additional environmental
rneasures and past environmental occurrences. The review of the ship's records were a
valuable source of ùiformation, but due to the time constraint it was rated as only
moderately workable.
The walk about was the third part of the audit protocol that was evaluated for its
workability. The problems inherent in the previous two questions were also encountered
in the walk about. hiring the audit of the ship a separate, unaccompanied, walk about
could not be conducted due to the time frame. The walk about was conducted using the
questionnaire as the guideline and "tour book". The waik about in most cases was
conducted in the company of a shipboard personnel familiar with that area. Although al1
areas of environmental issues were observeci during the walk about, a more detailed
observation could not be conducted. The information collecteci during the walk about was
minhally sufficient to evduate the degree of cornpliance. An unaccompanied waik about
would have led to a more detailed report, however, it is felt that there would have been no
new environmental issues discovered, thus a rating of moderate has been assigned. Again
because of the short time h n e , detailed explmations and reasoning could not be given to
dl issues. In sorne instances, e.g., the oil water separator, the researcher was able to
ver@ that the separator was working, however, the discharge was not tested to determine
if it was in good working order.
In summary, the overall workability of the audit instrument was detemined to be
only moderate. A summary of the findings is outlined in Table 6.3. The moderate rating
was assigned due to the short time span in which the audit could be completed. Three of
the four ships audited were self-unloaders which on average remain in port for only 5-7
hours.
Table 6.3: Workability Questions and Findings for the Audit Instrument and Protocol
Workability Questions and Rnting System
1 ) Was the questionnaire a workable instrument within the given ship's port tirne?
- workable: >95% questions flowd smoothiy, were accurate and answers were appropriate; completed within tirne fiame - moderately workable: >75 to <95% questions and answers completed within the time fiame - not workable: ~ 7 5 % of questions completed and not within the time fiame
2) Was the record search a workable segment of the audit process?
- workable >95% of the records were accessible and search completed in allotted tirne - moderately workable: >75% to <95% of the records were accessible and a satisfactoq search completed in the allotted tirne - not workable: <75% of records were accessible and was not completed in the allotted time
3) Was the walk about a workable part of the process?
-Workable: observations recorded greatly influenceci final outcome and completed in allotted time - moderately workable: observations had influence on the final outcome and it was lifficult to complete in allotted time - not workable: observations had no significance and was not cornpleted in time
Audit InstmmentlProtocol - Rating and Reason
- Moderately workable
- approximately 90% of the questions were complet ed - time fiame short but do-able
- Moderately workable
- 85% of the ships records searched completely - satisfactory search completed in the allotted time
- Moderately workable
-observations were influentid in the assessment of the ship's degree of environmental cornpliance but were difficult to complete in the given ship's port time
6.1.4 Receotiveness
Three questions forrned the basis on which to evaiuate receptiveness of shipowners
and personnel to the audit instrument and protocol. The receptiveness of the owners/crew
members affects the amount of information offered to the auditor. In turn, this affects the
comprehensiveness and validity of the audit.
The first question pertained to receptiveness of the shipping company's executives
contacted. As the author had worked for the two sailing companies contacted, the initial
contact was quite receptive. Upon a sending a letter with a detailed outline of the
intended work and its purpose, meetings were quickly set up with the executives. During
the meetings, the dr& questionnaire was discussed and revised accordindy. Strong
interest was shown and the two sailing companies were very willing to cooperate,
resulting in a receptive rating .
On the ships, the receptiveness to the audit varied. On one ship the Captain said
"he would have nothing to do with me and that the First Mate would answer al1 questions
and provide al1 the documentation". In addition, the First Mate was instructed to
accompany me at al1 times and carry a tape recorder to record our conversations. This
resulted in some bnef answers Eom the mate. Eventualiy the tape recorder was shut off
and the First Mate became more receptive. In general, on the other ships 1 was greeted
with some reservation at first, then found that the crew started to warm up. 1 was usually
escorted around the ship both for security/liability reasons and to have an officer answer
any questions that 1 might have. I was escorted by one of the mates when my
investigation pertained to the deck department and by an engineer when in their
department. HaWig spent a couple of hours with each they eventudy were fùlly
cooperative and willing to assist with the audit. With respect to the above, a rating of
"moderately receptive" was given.
The third aspect of receptiveness involved the willingness of the ships' personnel
to locate and to provide requested information. During the course of completing the audit
questionnaire, i n t e ~ e w s and a review of the ship's documents, information was often
requested to ver@ pertinent issues. The required documents were ofien easily located,
and if not, every atternpt was made to produce the information before the end of the audit
process. In one case the information was not located by the end of the audit, however the
requested information was later faxed to the researcher. Additional ùiformation was fieely
offered in rnany circumstances to further ver@ environmental management systems or
practices. A synthesized rating for this criterion was not detemiined due to the nature of
the disaggregated assessrnent results. As indicated above, the shipping companies'
representatives were very receptive to the undertaking; the ship's crew were hesitant at
first, but eventuaily co-operated; and personnel were helpful in locating and providing
requested information. A summary of the findings is presented in Table 6.4.
Table 6.4: Receptiveness Questions and Finding for the Audit Instrument and Protocol
Receptiveness Questions and Rating System
--
1) Were the shipping company's executives contacted receptive to the audit?
- receptive: willing to CO-operate - Moderately receptive: unwilling at first, then receptive - not receptive: not willing to participate
2) Were the shipboard personnel receptive to the undertaking?
- receptive: willing to CO-operate - moderately receptive: hesitant & cautious at first, then receptive - not receptive: wanted nothing to do with it
3) Were the personnel helpful in locating & providing information?
- very helphl: "ask and you shall receive" - moderately helpful: will indicate where the information c m be found with some hesitancy - not helpful: information was difficult to obtain
-
Audit InstrumentlProtocol - Ratings and Reasons
Receptive
- interested in undertaking - assisted with draft version of questionnaire
Moderately Receptive
- Officers and crew were hesitant at first, then warmed up and did their best to assist with the undertaking
Very Helpful
- provide information when requested and produced additional information which was not requested - were keen to provide information and details
6.2 Conclusions - Overaii Evaluation of the Audit Instrument and Protocol
A surnrnary of the overall evaluation follows in Table 6.5. Each criterion was
given equal weight, as there was no evidence to suggest that one critenon is more or less
important than the other. The first criteion to be rated was the comprehensiveness of the
audit. Al1 three rating questions were given a cornprehensive rating. This indicated that
Table 6.5: Summary of Evaluation Criteria Ratings for the Audit Instrument and Protocol
1 Comprehensiveness 1 Cornprehensive 1 1 Relevance 1 Relevant 1
- - - - - - . . -
1 Workability 1 idi ira tel y W o rkable 1 1 Receptiveness 1 M i d Rating* 1
*company representatives were receptive; shipboard personnel were moderately receptive; and dl personnel were very helpfùl in locating and providing requested information
the questionnaire and protocol were of sufficient detail to provide the researcher with a
detded insight into the problems and issues that are of environmental concem on a ship.
The second criterion was relevance of the three main segments of the audit -
questionnaire, waik about and document review. Each segment was rated as being
relevant thus providing the researcher with a sound basis for deciding whether or not the
results led to determihg the environmental compliance and soundness of the ship. The
workability of audit was evduated through the workability criterion. Although the rating
for this criterion was moderate, it still provided the researcher with information to assess
the ship's compliance with environmentally related regulations. To increase this rating the
audit could have been conducted over a couple of days, however, research time
constraints did not ailow an extended penod on board the ships. The last criterion rated
was receptiveness. The receptiveness of the personnel is a key factor in detemiining the
arnount and accuracy of information the auditor receives regarding past history and
practices. Daily activities can also be slanted providing an biased viewpoint. An overali
rating for this criterion was not detennined due to the nature of the disaggregated results,
however, the results indicated that the responses to the undertaking were favourable.
Some hesitancy and cautiousness were first encountered when arriving on board. Once
the crew warmed up and realized that the researcher was not out to "convict" personnel,
but assist in the overall environmental compliance, any information requested was k l y
provided.
Overall the rating of the audit instrument and protscol was very favourable. The
cnteria used to evduate the instrument utilized the systematic collection of information
about how an investigative program, like an audit, operates and its effect. The audit
instrument was rated as being cornprehensive enough to cover al1 environmentally related
issues and provided the researcher with enough information to make an accurate
assessrnent regarding the ship's degree of environmental compliance and soundness.
Further discussion regarding the interactive effects of each criterion and the overdl
effectiveness of the audit instrument will be discussed in greater detail in the next chapter.
7.0 CONCLUSIONS AND RECOMMENDATIONS
This chapter draws study conclusions and offers recommendations with regard to
the application of the merchant marine environmental compliance questionnaire and
protocol. Highlighted are thesis contributions to evaluation research, as weli as
contributions to our understanding of merchant marine pollution and the value of an
environmental compliance instrument in assessing the degree of environmental compliance
and awareness on board a Great Lakes' freighter.
7.1 Summary of Objectives and Findings
The first objective of this research was to develop a merchant marine
environmental compliance audit questionnaire and protocol that pertained specifically to
the merchant marine shipping industry on the Great Lakes. The audit questionnaire and
protocol were derived from a series of land based environmental compliance audits. A
cornparison between the land based pollution regulations and the marine pollution
regulations was conducted. M e r a draft questionnaire was established. the questionnaire
was then subjected to trial mns on board three Great Lakes' fieigbters and modified
accordingly. Following the on board trials, a review of the questionnaire by the shipping
companies' representatives was undertaken and modifications were made to include
concerns/issues voiced by the representatives. Although this was a lengthy process, the
resulting questionnaire was then an instrument accepted and supponed by the shipping
companies. This receptiveness is vital, especially when it cornes f?om the top down as
employees are now aware that this is a prograrn that has management support.
The second objective was to apply the environmental compliance audit on selected
Great Lakes' freighters to determine their state of environmental compliance and to
provide a bais for evaluating the audit instrument. During the earlier consultation process
with the shipping companies' representatives, four freighters were chosen that represented
a cross section of the ships plying the Great Lakes. The audit questionnaire and protocol
were then applied on these ships and each ship was individually evaluated in terms of its
degree of environmental cornpliance. Overall, the ships that were audited were generally
in compliance with the applicable pollution guidelines and regulations. The results from
these evaluations provided a basis for the evaluation of the audit instrument.
An evaluation of the marine environmental compliance audit instrument and
protocol was undertaken as the third objective. To address the evaluation of the audit
process, the following criteria were used: comprehensiveness; relevance; workability; and
receptiveness. The criteria chosen were good indicators of the success of the audit
instrument and protocol. Each critenon enabled the researcher to criticaily examine each
process of the audit instrument and protocol and subjectively analyze it. The resulting
information was useful in determining how the audit instrument and protocol operated and
how they could be irnproved. The overall conclusions drawn from the evaluation process
indicated that the audit questionnaire and protocol were thorough enough to cover a11
issues of environmental concem aboard a Great Lakes' fieighter. This in turn, ailowed the
researcher to determine the degree of environmental compliance and awareness on board
the ship based on sufficient data. The comprehensiveness of the instrument aiso
eliminated any arnbiguity that might have arisen during the audit process. The only
problem that was identified was the workability of the audit. It was found that there was
insufficient time to conduct an in-depth assessment.
7.2 Research Contributions
Theoretically, this research explored the role and value of a marine
environrnental audit in determining the degree of pollution entering the Great Lakes fiom
shipping activities. This thesis demonstrated the effectiveness of an environmental
compliance audit as a mechanisrn for measuring the degree of environmental compliance
on board a Great Lakes' fieighter. The environrnental compliance audit developed for this
research represents a normative benchmark, or description of an ideal state of
environmental compliance for the merchant marine shipping industry on the Great Lakes.
An environmental audit, according to Buckley ( 199 1 ) is a valuable management
tool for any corporation that uses any publicly owned resource and whose activities and
practices could create some form of public concem. With respect to this, the marine
environmental compliance audit was designed to be used as a management tool for the
Great Lakes' shipping companies. Not only does it indicate areas of concem, but used
effectively it becomes a valuable water resource management tool. With the growing
trend in today's society being greater private sector involvement in environrnental
management, the marine environrnental cornpliance audit, developed in this thesis, is a
timely and useful addition to water resource management practices..
This thesis contributes to the development of evaluation criteria rating systems
applicable to assessing environmental audits. The criteria developed for the assessment of
the marine environmental compliance audit questionnaire and protocol also can be applied
to ot her types of environmentai assessment mechanisms. Land based environmental audits
are a relatively new field of environmentai management and have become an accepted and
hcreasingly wide spread practice. The cnteria developed in this thesis now provide a
means of evaluating the efFectiveness of these audits.
On the practical side, the marine environmental audit questionnaire and protocol
were designed in such a manner that the results are easily reproducible. This allows
auditors to maintain consistency when auditing the same ship different times. It also
allows for some form of standardization of environrnental assessment arnong the Great
Lakes' freighters.
Another advantage to this type of evduation is that the results are easily
obtainable. An environmental audit can be conducted in a relatively short time frame and
is not dependent upon accumulative data. The information collected from the audit is
readily available and quickly surnmarized. This is advantageous when assessing the degree
of environmental compliance of several ships and for conducting periodic spot checks or
updates. Additionally the results obtained form the application are not related upon the
age, style or type of ship.
A practical limitation of the environrnental audit is that it oniy reflects the
environrnental conditions at the time of the audit. However, due to the reproducibility of
the audit questionnaire and the protocol, the audit can be repeated anytime. In addition
the audit questionnaire is divided into segments, thus ailowing the auditor to do a partial
audit using only the necessary sections when doing a follow-up or evaluating newly
implemented procedures.
Another limitation to the application of the audit instrument is the amount of
information that needs to be collected in a short time span. The audits were conducted
while the ships were in port, usually 6 -7 hours. Although generdly this was enough time
to conduct the audit and obtain sufficient evaiuative data, a more in-depth assessrnent and
review of the ship's practices and activities could be conducted.
7.3 Recommendations
Based on the research results it is recommended:
1 ) That the application of audit questionnaire and protocol should be
conducted over a longer tirne period, Le., 10 - 12 hours. This would ailow
the auditor to wnduct a thorough search of the ship's records, spend more
time on the i n t e ~ e w s and provide time for an in-depth walk about.
2) That in lieu of additional time to complete the audit, a second person be
added to the auditing tearn. The tasks and assignments c m be split, which
if coordinated properly could provide greater detail about the ship. Each
auditor has to know exactly what their responsibilities and duties are for
this to be effective.
3) That the Canadian Coast Records and the shipping companies' records be
reviewed to provide as better background/history of the vesse1 being
audited. It is possible that those being interviewed are not familiar with the
history of the ship.
7.4 Future Research Opportunities
There is a need for future application and testing of the marine environmentai
cornpliance audit across a broader range of ships. Additional research may result in
changes to the marine environmental cornpliance audit developed in this thesis resulting in
a more generalized monitoring type of tool. This could lead to the development of a
standardized system for cornparison values with more repetitive applications of the marine
audit. The revised marine environmental cornpliance audit may be less comprehensive but
more applicable to a wider range of ships.
Another research opportunity could include an in-depth review of the marine
pollution regulations. This research would address whether the regulations are adequate
enough to prevent or reduce the discharge of pollutants fiom marine shipping activities
into the surrounding environment. This research should also explore whether a marine
environmental cornpliance audit should be incorporated into the regulations to enhance
water resource management.
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- . *
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MARINE ENWRONMENTAL ASSESSMENT QUESTIONNAIRE
MARINE ENVIRONMENTAL ASSESSMENT QUESTIONNAIRE
MERCHANT MARINE VESSELS
GREAT LAKES EDITION
DATE: VESSEL:
PRWILECED AND CONFIDENTIAL
TABLE OF CONTENTS
1.0 GENERAL INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
1.1 Vesse1 Particulars . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
. . . . . . . . . . . . . . . . . . 1.2 Environmental and Health and Safety Particulars 3
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3.0 DECK D E P A R W N T 7
3.1 Navigation Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
3.2 Communication Systems Signalling Devices . . . . . . . . . . . . . . . . . . . . . . 9
3.3 Fire Fighting Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
3 -4 Spi1 Response Procedures and Equipment . . . . . . . . . . . . . . . . . . . . . . 13
3.5 Deck Stores and Supplies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
3.6 Solid and Hazardous Wastes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
3 -7 Waste Reduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
3 -8 Designated Substance Awareness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
3 -9 Cargo System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
4.0 GALLEY DEPARTMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
4.1 Stores and Supplies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
4.2 Solid. Liquid and Hazardous Wastes . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
4.3 Waste Reduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
4.4 Designated Substance Awareness . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5.0 ENGiNEROOM 23
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5.1 General Information 23
5.2 Air Ernissions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
5.3 Heating/Air Conditioning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
5.4 Engine Room Stores and Supplies . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
5.5 Solid and Hazardous Wastes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5.6 Designated Substances 34
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5.7 Spi11 Response 35
5.8 Transfer Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
MARINE ENVIRONMENTAL ASSESSMENT QUESTIONNAIRE
GENERAL LNFORMATION
Vessel Particulam Vessel Narne:
Cali Sign: Official Number: Lloyds Registry Number: Port of Regiary:
Company's Mailing Address:
1 .1.7 Contact Name and Phone Number:
1 . 1 -8 Mortgagee (Finance Company) Mailing Address:
1.1.9 SizeofVesseI:
length, bearn, depth:
gross tonnage:
net tonnage:
Y
speed: 1 .1.10 Vessel's Classification:
PRIVILEGED AND CONNDENTIAL, 114
MARINE ENVIRONMENTAL ASSESSMENT QUESTIONNALRE
Vesse1 Configuration: (describe vessel's appearance, ie., number of cargo holds and
hatches; location of super nruaure(s); engine room; type of unloading equipment:
Types of cargo carried and amount:
Have there been any dangerous cargoes carried (type and amount)?
Number of Crew:
Licenced: U nlicenced:
1.1.1 5 Describe Work Shifts:
1.1.16 Names of Unions Represented:
PRlMLEGED AND CONFIDENTIAL 2 115
MARME ENVIRONMENTAL ASSESSMENT QUESTIONNAIRE
Environmentai and Heaith and Safety Parîicuhrs 1s there a Canadian Oil Pollution Prevention Certificate or an International Oil Pollution Prevention Certificate or a Certificate of Cornpliance on board? If yes
give particulars:
1s there an Environmental Cornmittee in the organization? If so, is there a written
policy/handbook on environrnental issues? Give details of handbook (topics
covered, date of pub tication).
Names and position of people on the environmental cornmittee.
1s there an Environmental Cornmittee on board? I f so, how often do they meet? If
not, how are environrnental issues handled and who is responsible?
Detail the environrnental reporting structure on the vessel:
Reports to
Reports to
Reports to
PRIVUEGED AND C O ~ E N T T A L 3 II6
MARINE ENVIRONMENTAL ASSESSMENT QUESTIONNAW
1.2.6 1s there a Health and Safety committee in the organization? If so, is there a written
policylhandbook on health and d e t y issues? Give details of handbook (topics
covered, date of publication).
1.2.7 Names and position of people on the health and safety cornmittee:
1s there a Health and Safety cornmittee on board? If so, how often do they meet?
If not, how are health and safety issues handled and who is responsible?
Detail Health and Safety reporting structure on the vessel:
Reports to
Reports to
Reports to
Is there a fire and Iifeboat drill program on board? If so, how often are they
conducted and is it documented? Where?
MARINE ENVIRONMENTAL ASSESSMENT QUESTIONNAIRE
1.2.1 1 Does the vessel take part in the Voluntary Guidelines for the Control of Ballast
Water Discharges from Ships (ie., St. Lawrence River, Lake Superior ports)? If
yes, is there supporting documentation?
1.2.12 Are sarnples of the exchanged water taken?
1.2.13 When were the ballast tanks last inspected and by who? Results:
1.2.14 What type of coating is used to protect the interior walls of the ballast tanks?
- - - - - -- .
1.2.15 What type of coating is used on the hull (for anti-fouling and corrosion)?
1.2.16 What type, and number of mooring winches is the vessel equipped with? If
hydraulic, have there been any hydraulic oil spiiis? If yes, how spili was contained
and how containment material was disposed of
PRIVILEGED AND CONFIDENTIAL 5 1 I8
MARINE ENVIRONMENTAL ASSESSMENT QUESTtONNAiRE - -
2.0 VESSEL EtISTORY
2.1 Where was the vessel built? 2.2 Date on which the keel laid:
2.3 Have there been any modifications made to the structure of the vessel, if so,
describe nature of modification, date and name of facility where modification was made?
2.4 Has the vessel been in the same type of trade since construction? If no, detail pnor
trade(s) of vessel and shipping routes.
2.5 Has the vessel been involved in any collisions, strandings or groundings? If so,
detail the occurrences (where, when, damage, spills, etc.):
2.6 Does the vessel have any inherent problems or characteristics that could affect the
safety andor navigation of the vessel?
PRIVILEGED AND CONFIDENTML 6 119
MARCNE ENVIRONMENTAL ASSESSMENT QUESTIONNA=
2.7 Have there been any labour actions at any time during the history of this vessel
with this Company that effected the operation of the vessel? Detail such and
actions taken to remedy the situation(s):
2.8 Have there been any previous environmental and or health and safety studies/reports conducted regarding the vessel? By whom? If so, are they available
to review on board? Summarize any incidents or areas of concem.
2.9 Have there been any environmental infractions associated with the operation of this
vessel either by the CCG or USCG? If so, when, where, what type of infractions
and action(s) taken to remedy the situation(s):
3.0 DECK DEPARTMENT
3.1 Navigation Equipment
Gyro Compass:
Number of Gyros:
Locations:
Magnetic Compass:
Number of Magnetic Cornpasses:
PRMLEGED AND CONFiDENTIAL 7 120
MARINE ENVIRONMENTAL ASSESSMENT QUESTIONNAIRE
Calibration Curve: S t eering :
Number of Steering Consoles: Makflype:
Locations: Backup System:
Navigation Lights:
Backup System:
Search Lights:
Number of Searchlights:
Type:
Anchors: Nurnber of Anchors (including spares):
Wheelhouse control: Have there been any problerns associated with the anchors or windlasses
(premature release, fluid leaks, loss of anchor, etc.)?
Type of Windlasses: Radar:
Number of Radars:
Make/Type: Loran:
Nurnber of Lorans: Makeîïype:
PRMLECED AND CONFIDENTIAL 8 121
MARINE ENVIRONMENTAL ASSESSMENT QUESTIONNAIRE
G.P.S.:
Number of G.P.S.: Make:
Type: Depth Sounder:
Number of Depth Sounders: MakdType:
Decca: Number of Deccas:
Make:
R.D.F.:
Number of R.D.F.'s: Make/T ype:
Wind Anemotor:
Number of Anemotors:
Other Navigation Equipment:
3.2 Communication Systems Signaiiing Devices Number of WhistlesWoms: Type:
Locations: Backup System:
Number of Ships Bells:
Type:
Locations:
PRNILEGED AND CONFIDENTIAL 122
MARINE ENVIRONMENTAL ASSESSMENT QUESTIONNALRE
Other Signalhg Devices: (ie., gong, hand held air homs, etc. )
Engine Room: Number of Telegraphs: Telegraph:
Type:
Backup System:
V.H.F. Radio:
Number of V.H.F.: Type:
S.S.B. Radio: Number of S.S.B.:
Type: Cellular telephone:
Number of Cellular Phones: Type:
Facsimile: Nurnber of Facsirniles:
Type:
Weat her Facsimile:
Number of Weather Facsimile:
Type: Inter-ship Communication:
Number of Systems:
Type:
PRIVILEGED AND CONFIDENTIAL 1 O 123
MARINE ENVIRONMENTAL ASSESSMENT QUESTI0NNAiR.E
Backup System:
EPrRBS: Number of EPIRBS: Type: Locations:
3.3 Fire Fightiog Equipment
Fire Detection Panels: Nurnber of Fue Detection Panels:
Locations:
Backup System:
Last Inspected: Breathing Apparatus:
Number of Breathing Apparatus:
Locations:
Last Inspected:
PRiVILEGED AM) CONF'TDENTIAL 11 IS4
MARINE ENVIRONMENTAL ASSESSMENT QUESTIONNAiRE
Sprinkler System:
1s vesse1 equipped with a tire sprinkler system?
Which area's are covered b y sprinkler sy stem?
Backup System:
Last inspected:
Fire Fighting Stations:
Number of Fire Fighting Stations:
1s there a routine fire fighting equipment inspection program? What equipment is
inspected? Are the inspections recorded? Where?
Last Inspected:
Were there any deficiencies? Describe. What actions were taken to remedy the
matter?
Other Safety Equipment: (ie., fire axes, spotlights HTD lights, cargo hold lights - number,
type):
MARINE ENVIRONMENTAL ASSESSMENT QUESTIONNAIRE - - -- -- - - - -- - - - - - --
3.4 Spill Response Procedures and Equipment 3.4.1 Is there a "shipboard oil pollution emergency plan" for the vessel? 1s it approved
by the applicable goveming body (ie. CCG, USCG, Lloyds, etc.)?
3.4.2 Are the spills reported and documented? If yes, to ~ h o , by whom and where are
the records kept?
3.4.3 1s there spill response equipment on board? If so, where is it located. what kind of
spill response equipment is there, who is trained in its use and is the location
marked?
Does the vessel have the ability to deploy oil booms by boat? If yes, what type of
boat is used? Is it motorized? Has it recently been inspected?
Does the vessel conduct any oil spi11 response drills? If so, are they documented
and where?
PRIVEEGED AND CONFIDENTML 13 126
MARINE ENVLRONMENTAL ASSESSMENT QUESTIONNAIRE
3.4.6 What deck procedures are taking during times of fiel transfer and waste oiVsludge
removal? Are there standing orders posted?
3.5 Deck Stores and Supplies 3 .S. 1 Types of chemicais/oils used and stored on board (other than paints):
Name Est. Arnt. Location
3.5.2 MSDS sheets available and where located:
3 5 3 Types of paint used and stored on board (sprays, cans): Name Est. Amt. Location
3 -5.4 MSDS sheets available and where:
PRNIL,EGED AND CONFIDENTIAL 14 127
MARINE ENVIRONMENTAL ASSESSMENT QUESTI0NNAiR.E
3.5.5 Describe the paint locker (Le., explosion proof lights, ventilation, fire extinguishing
system, etc.):
3.5 -6 How are the paint brushes, rollers cleaned and where? How is the spent cleaning
solution disposed OF
3.5.7 Does the vesse1 use sandblasting equipment? If so, how is the paint/sand residue
disposed of!
3.5.8 Are there any other type of materials stored on board (deck department) that might
be considered hazardous, toxic, reactive, corrosive or ignitable?
3.6 Sotid and Hazardous Wastes 3.6.1 Waste material storage and handling (including solvents, paints, etc.) Describe
quantity, form of materiai and storage facilities?
PRNILEGED AND CONFIDENTML 15 128
MARLNE ENVLRONMENTAL ASSESSMENT QUESTIONNAIRE
3.6.2 1s waste disposa1 on board, sent &ore or a combination of both?
3.6.3 If wastes are sent ashore, who is the waste hauler?
3 -6.4 Certificate of Approval of Wastehauler:
3.6.5 Certificate of Approval Number for on-shore waste facility:
3.6.6 What are the associated waste streams (Give ~Iassification and identification number)?
3.7 Waste Reduction
3.7.1 What reuse/reduction/recycling programs exist on-board?
3.7.2 1s the vesse1 equipped with any garbage incinerators? Make, number of, size, uses
and where are they located? What is their fiequency of use?
PRIVILEGED AND CONFIDENTIAL 16 129
MARINE ENVtRONMENTAL ASSESSMENT QUESTIONNAiRE
3.7.3 Have the incinerators been inspected? When, by whom and what were the result?
3.7.4 Has there been any aack emission testing completed on the incinerators? If so, by
who and what were the results?
3.8 Designated Substance Awareness 3.8.1 Are there any transformers, capacitors or other equipment on board containing
dielectric fluids? Have they been certified as being PCB free, or tested to determine their PCB content?
3.8.2 Are there any PCB containing items (50 pprn or more PCB fluid) in service or on-
board? 1s there PCB containing equipment being stored on-board?
3.8.3 Are there any ASBESTOS containing matenals (ACM) on-board? If yes, is there
an asbestos management program in-place?
PRIVILEGED AND CONFIDENTIAL 17 130
MARINE ENVIRONMENTAL ASSESSMENT QUESTIONNAW
3.8.4 Are there floor tiles, industriai curtains, caulking, comgated wails, insulation or
acoustic tiles which are pre- 1980 on board?
3.8.5 Are there any other Designated Substances present on-board (eg. Pb, Cd, Hg)?
Are there any documents indicating their location and quantity?
3.9 Cargo System 3 -9.1 How is the cargo removed fiom the vessel's cargo holds? Describe:
If the vessel is equipped with a self unloading system, what measures are taken to
control dust and residue w g o (dust shrouds, collectors, scrapper, water spray,
etc.)?
Has the vessel ever received any infractions, violation notices or cornplaints with
respect to dust ernissions? If yes, describe:
PRIVILEGED AND CONFIDENTIAL 18 13 1
MARINE ENVIRONMENTAL ASSESSMENT QUESTIONNAIRE
3.9.4 How is the collected dust removed From the vessel?
3.9.5 How are the cargo residues disposed of (ie., residue cargo on deck and in the
hold)?
3 -9.6 Are they ever discharged overboard?
3.9.7 How are the cargo holds cleaned?
3.9.8 During clean-up of the cargo holds, how are the associated wastes disposed of?
3.9.9 Have there been any violations or infraction notices served regarding cargo
residue? tf yes, describe:
PRIVILEGED AND CONFIDElYTIAL 19 132
MARINE ENVIRONMENTAL ASSESSMENT Q WSTIONNAIRE
GALLEY DEPARTMENT
Stores and Supplies
Type of chemicals/oils used and stored on board (other than paints):
Name Est. Amt. Location
MSDS sheets available and where located?
What type of refiigeration system is used (ie. waik-in, refiigerator, freezer)?
Have there been any refigeration leaks associated with the cooling systems?
Is there a record of change out with respect to the type of refkigerant used?
Solid, Liquid and Hazardous Wastes
Waste material storage and handling (including solvents, deep fiyer oils, food wastes, etc.). Describe quantity form of materid and storage facilities.
1s waste disposal on-board, sent ashore or a combination of both?
4.2.3 lf wastes are sent ashore, who is the waste hauler?
PRlMLEGED AND CONFIDENTIAL 20 133
MANNE ENVIRONMENTAL ASSESSMENT QUESTIONNAIRE
4.2.4 Certificate of Approval of Wastehauler:
4.2.5 Cenificate of Approvd Number for on-shore waste facility:
4.2.6 What are the associated waste streams (Give ctassification and identification number)?
4.2.7 Are there any floor drains in the galley area? Where do the flow?
4.2.8 How many sink and appiiance drains are there? Where do they flow?
4.3 Waste Reduction 4.3.1 What reuse/reductionlrecycling prograrns exist in the gailey?
4.3.2 Is the galley equipped with any garbage compactors? Make, number, type, size, uses and where are they located? What is their fiequency of use?
PRNILEGED AM) CONFIDENTIAL 2 1 134
MARINE ENVIRONMENTAL ASSESSMENT QUESTIONNAIRE
Is the gailey equipped with any garbage incinerators? Make, number, type, size,
uses and where are they located? What is their frequency of use?
When were they last inspected? By who and what were the results?
Has there been any stack emission testing cornpleted on the incinerators? If so, by
who and what were the results?
Designated Substance Awareness
Are there any transfomiers, capacitors or other equipment in the galley containing
dielectric fluids? Have they been certified as being PCB free, or tested to
determine their PCB content? Are they documented?
4.4.2 Are there any ASBESTOS containing materials (ACM) in the galley? If yes, is
there an asbestos management program in place?
4.4.3 Are there floor tiles, industrial curtains, caulking, cormgated walls, insulation or
acoustic tiles which are pre- 1980 on board?
MARINE ENVIRONMXNTAL ASSESSMENT QUESTIONNAiRE
Are there any other Designated Substances present on-board (eg. Pb, Cd, Hg)?
Are there any documents indicating their location and quantity?
ENGINE ROOM
GeneraI Information Certificates
List any certificates associated with the operation of the vessel's engine room (ie., OWS, Sewage Treatment System, Boilers, Machinery Inspection, etc.)
Date of Issuing Certificate Number Issue E ~ P ~ v Authority
Engines: Type:
Make: Horsepower: Type of fuel: Fuel Consumption:
Fuel tan&) location and capacity:
PRIVILEGED AND CONFIDENTLAL 23 136
MARINE ENVIRONMENTAL ASSESSMENT QUESTIONNALRE
Have there been any inspections of the tanks, if so are documents available:
Are records kept of mass balance (volume in = volume out) for the tanks?
5.1.6 Propeller type:
5.1.7 Has there been any oil leakage f h m the stem tube or propeller seals, estimate
arnount?
5.1.8 Is a spare blade, propeller on-board?
5.1.9 1s the vesse1 equipped with boilers? State make, type, size of boilers and when last
inspected, certificates.
5.1 .10 Generators
Number of Generators: Make:
Type of Fuel: 5 .1 - 1 1 Generator fuel tank capacity and location:
PRNILEGED AND CONFIDENTIAL 24 137
MARINE ENVIRONMENTAL ASSESSMENT QUESTIONNAIRE
5.1.12 Have there been any inspections of the tanks, if so are documents available:
5.1.1 3 Are mass balances of the tank done?
5-1-14 B o w Thruster
Type:
Make: 5-1 -15 Has there been any problems associated with the variable pitch seals? I f so,
detaik:
5.1.16 1s the bow t h s t e r cornpartment fitted with a high level d m ? 1s the alarrn
sounded before the sump pump is activated?
5.1.17 1s there a regular maintenance program with respect to the bow thruster? Detail:
5.1.18 Fuel tank capacity and location: 5.1.19 Are mass balances of the tank done?
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MARINE ENVIRONMENTAL ASSESSMENT QUESTIONNAIRE
Have there been any inspections of the tanks, ifs0 are documents available?
Other tanks (hydraulic oil, kerosene, solvent, capacity, etc., except waste oil tank):
Have there been any inspections of the tanks, if so are inspection documents
available:
5.1 -23 Are mass balances of the tank done?
Miscellaneous 5.1.24 Are al1 the tank sight glasses, decant valves in good condition?
5.1.25 Are there any drip trays around the engine, generators andor oiVfÙel pumps?
5.1.26 Are the drip trays in good condition (ie., no leaks, drain holes, etc.)
M M E ENVlRONMENTAL ASSESSMENT QUESTIONNARIZ
Describe their clean out procedure:
Are the fuel oil and oil tank vents equipped with save-alls and fire screens?
How many pumps @el, lubricating, other oils and chemicals) in the vesse1 fiaed with? Are they in good working order (ie., leaks, seals, etc.)? Have there been spills as a result of pump fdure? If yes, describe and clean-up procedure used.
Is the piping in the engine marked as to the pipe's contents and direction of flow?
Are there MSDS sheets available regarding the niel, lubricating and other oils and where are they located?
Air Emissions
What are the sources of air emissions (engine exhaust stacks, generator exhaust
stack incinerators, outside vents):
MARINE ENVIRONMENTAL ASSESSMENT QUESTIONNAlRE
5.2.2 When were the aacks last inspected? Were there any signs of corrosion of solids
build-up?
5.2.3 Have there been any monitoring of these stacks, if yes, by w ho, when and what
were the results?
5.2.4 Are there any air emission certificates associated with the vessel?
5 -2.5 Does the vessel use any type of technology to reduce the stack emissions?
5.2.6 If engines are steam or stem tiirbine, describe soot blowing and/or boiler blow
down procedure:
5.2.7 Have there been any air emission violations in the past? I f yes, describe circumstances, results and any actions taken:
PRIVlLEGED AND CONFIDENTÏAL~ 28 141
MARINE ENMRONMENTAL ASSESSMENT QUESTIONNAIRE
5.3 Heating/Air Conditioning
5.3.1 How is the vessel heated?
5.3.2 Is the vessel air conditioned? I f yes descnbe A/C system. Is there any asbestos in
the duct work's interna1 systems?
5.3.3 1s there a record of change out with respect to the type of refrigerant used?
***See also Questions 4.1.3 to 4.1.5***
5.4 Engine Room Stores and Supplies (include tunnelmen's stores if applicable) 5.4.1 Types o f chernicals/oils used and stored on board (other than paints):
Name Est. Amt. Location
5.4.2 MSDS sheets available and where located:
PRIVILEGED AND CONFIDENTIAL 29 142
MARINE ENMRONMENTAL ASSESSMENT QüESTIONNAIRE
5.4.3 Types of paint used and stored on board (sprays, cans):
Type Est. Amt. Location
5.4.4 MSDS sheets available and where:
5.4.5 Describe the paint locker (Le., explosion proof lights, ventilation, fire extinguishing
system, etc.):
5.4.6 How are the paint brushes, rollers cleaned and where? How is the spent cleaning solution disposed of?
5.4.7 How is the spent cleaning solution disposed of?
5.4.8 Are there any other type of materials stored on board that might be considered hazardous, toxic, reactive, corrosive or ignitable?
PRMLEGED AND CONFIDENTIAL 30 143
MARINE ENVIRONMENTAL ASSESSMENT QUESTIONNALRE
5.4.9 Are there any void spaces in the engine room and where are they? 1s there access
to the void spaces and if yes, are any stores kept in these spaces?
5.5 Solid and Hazardous Wastes 5.5.1 Waste material storage and handling (Încluding solvents, paints, etc.). Descnbe
quantity, form of material and storage facilities:
5.5 .2 1s waçte disposal on-board, sent ashore or a combination of both?
5.5.3 1s wastes are sent ashore, who is the waste hauler?
5.5.4 Certificate of Approval of Wastehauler:
5.5.5 Certificate of Approval Number for on-shore waste facility:
5.5.6 What are the associated waste strearns (Give classification and identification
number)?
PRIViLEGED AND CONWDENTIAL 31 1 44
MARLNE ENVLRONMENTAL ASSESSMENT QUESTIONNAIRE
1s the Oil Record Book up to-date and available for inspection?
Is there a Canadian 0i1 Pollution Prevention Certificate or an International Oil
Pollution Prevention Certificate or a Certificate of Cornpliance on board? If yes
give particulars:
1s the vesse1 equipped with an oiVwater separator? lfyes give details (make, model, year of installation, aiarms, certificates (type test), inspections, input
sources, etc.):
Is the oil/water separator in good working order? Have there been ary problems
in the past?
5.5.1 1 Does the oiVwater separator mn continuously? Descnbe penods of operation:
5.5.12 Has the oiVwater separator been tested for oil discharge? Lf so when, by who and
the results:
PRNILEGED AND CONFIDENTIAL 32 145
MARINE ENVIRONMENTAL ASSESSMENT QUESTIONNALRE
5 3-13 Have there been any environrnental irûiactions issued with respect to the oiYwater
separator? Give details:
5.5.14 Are the direct bilge discharge valves locked out, chained off?
5.5.1 5 1s the vesse1 equipped with a sewage treatment system? Give details (make, model, type, year of installation, holding tank capacity, input sources, etc.):
5.5.16 Has the sewage treatment system been tested for discharge content? 1s so when,
by who and the results:
5.5.1 7 1s the sewage treatment system in good working order? Have there been any
problems in the past?
5.5.1 8 Have there been any environrnental infractions issued with respect to the sewage
treatment system? Give details:
PWILECED AND CONFTDENTIAL 33 146
MARiNE ENVIRONMENTAL ASSESSMENT QUESTIONNALRE
5.5.1 9 Does the sewage treatrnent system mn continuousIy? Describe periods of
operation:
5.5.20 What are the sources of input for the sewage treatment systern? (ie. toilets, sink and floor drains, etc.)
5.6 Designated Substances 5.6.1 Are there any transformers, capacitors or other equipment on board containing
dielectric fluids? Have they been certified as being PCB free, or tested to deterrnine their PCB content?
5.6.2 Are there any PCB containing items (50 ppm or more PCB fluid) in service or on-
board? 1s there PCB cuntaining equipment being stored on-board?
5.6.3 Are visual inspections of ail PCB equipment made? How frequently? Are such
inspections documented?
PRIVILEGED AND CONFIDENTiAL 3-8 147
MARINE ENVIRONMENTAL ASSESSMENT QUESTIONNAIRE
5.6.4 1s a PCB inventory maintained? How long has it been maintained?
5.6.5 Are there any ASBESTOS containhg materials (ACM) on-board? If yes, is there
an asbestos management program in-place?
5.6.6 Are there floor tiles, industrial curtains, caulking, comgated walls, insulation or
acoustic tiles which are pre- 1980 on-board?
5.7 SpiU Response
5.7.1 1s there a "shipboard emergency spill response plan" for the engine roorn? If so,
give details:
5.7.2 1s there spill response equipment in the engine room? If so, where is it located,
what kind of spill response equipment is there, how much is there and is the
location rnarked?
5.7.3 Have there been any significant spi11 incidents in the past (apart fiorn fuel, sludge
or oily mixture transfer operations)? I f yes, descnbe:
PRIVILEGED AND CONFIDENTLU 35 148
MARINE ENVLRONMENTAL ASSESSMENT QUESTIONNAIRE
Are the spills reported and documented? If yes, to who, by whom and where are
the records kept?
Are specific employees trained in spill response procedures? [fyes, how, by whom
and is their training kept up-to-date?
5.7.6 Does the vesseVengine room condua practice drills? If yes, describe:
5.8 Transfer Operations
FueIling
5.8.1 Descnbe the fùelling process?
5.8.2 What safety/environmentai precautions are taken?
PWILEGED AND CONFIDENTUL 36 149
IMARLNE ENWONMENTAL ASSESSMENT QUESTIONNALRE
5.8.3 Have there been any spills during fuel transfer operations, either on deck or in the
engine room? If yes, were the spills documented and reported? Detail:
Sludge/Oily Mixture Tmnsfer Descnbe the sludgdoily mixture transfer operations:
On the discharge piping system where are the stop valves iocated? Are they
labelled?
Where are the emergency shut offs Iocated? Are they labelied?
5.8.7 Have there been any spills during sludge/oily mixture transfer operations, either on
deck or in the engine roorn? If yes, were the spills documented and reported?
Detail:
PRlVILEGED AND C0NI;IDENTLAL 37 150
MARINE ENVIRONMENTAL ASSESSMENT QUESTTONNALRE
Have the sludge hoses been pressure treated recently?
(Note: Should be done amudy)
Are the results of the test documented?
(Note: Should be certificate of test in oil record book)
PRIVILEGED AND CONFiDENTiAL 38 151
IMAGE EVALUATION TEST TARGET (QA-3)
APPLIED & IMAGE. lnc 1653 East Main Street - -. - - Rochester. NY 14609 USA =-- Phone: 71 6/482-0300
I- -- - - Fax: 716i288-5989