Turkey – pollution fines and guidance

London P&I notes that pollution fines in Turkey were amended with effect from December 2018, with some penalties increased to between three and 14 times previous levels.

Significant fines can be imposed for any discharge into Turkish waters of dirty ballast, petroleum, petroleum derivatives, including sludge, slop fuel products and oily waste, as well as garbage and sewage. The fines are calculated by reference to the type of pollution and the type and tonnage of the vessel involved, rather than the quantity discharged, and the amount can be substantial.

To help avoid a significant pollution fine when calling at ports in Turkey or transiting Turkish waters, London P&I strongly recommends that members follow the recommendations and guidance issued in a circular by Metropole Maritime & Trading Ltd. Co., a correspondent in Turkey:

• Avoid de-ballasting unless the ballast water has been checked and confirmed to be clean.

• Close and secure or seal all overboard discharge valves in the closed position.

• Plug all deck scuppers and close any gaps in the fish plate surrounding the deck.

• Do not carry out hose tests of hatch covers, hydrostatic tests of deck pipes, hoses or other equipment.

• Avoid washing decks and superstructure.

• Transfer treated water from the sewage system and grey water to a holding tank and do not discharge it until the vessel is outside Turkish waters.

• Do not dispose of cargo residues, cargo space cleaning residues, garbage or other substances in Turkish waters.

• Do not scrape, chip or paint the vessel’s hull while alongside the pier or at anchor.

• While the vessel is in a shipyard or dry dock, crew should exercise care because the ship may be held vicariously liable for pollution caused by the negligence of the shipyard, its employees or agents. If a pollution incident is believed to have occurred, crew members should immediately protest in writing to the shipyard.

The circular provides further details of the pollution fines, the appeals process, security requirements for releasing an offending vessel and discounts for prompt payment. It can be accessed here.