Turkey – Pollution Fines and Guidelines

Members should note that the level of pollution fines in Turkey has been amended with effect from December 2018 with increases in the fines from between 3 to 14 times previous levels. Significant fines can be incurred for any discharge of dirty ballast, petroleum, petroleum derivatives (including sludge, slop fuel products, oily waste), garbage and sewage into Turkish waters. The fines are calculated based on the type of pollution, and the type and tonnage of the vessel from which the pollutant emanates, rather than quantity of pollution discharged; the fine imposed can be a substantial amount.

In order to avoid a significant pollution fine when calling ports in Turkey or transiting Turkish waters, it is strongly recommended that Members follow the Recommendations and Guidance contained in the circular issued recently by Metropole Maritime & Trading Ltd. Co., a correspondent in Turkey. The Recommendations and Guidance are as follows:-

• De-ballasting operations should be avoided unless the ballast water has been checked and confirmed to be clean.
• All overboard discharge valves should be closed and secured/sealed in the closed position.
• All deck scuppers should be plugged and any gaps in the fish plate surrounding the deck should be closed.
• Hose test of hatch covers, hydrostatic test of deck pipes/hoses or other equipment should not be performed.
• Washing of decks and superstructure should be avoided.
• Treated water from the sewage system and grey water should be transferred to a holding tank and should not be discharged until the vessel is outside Turkish waters.
• Cargo residues, cargo space cleaning residues, all garbage and other substances should not be disposed in Turkish waters.
• The vessel’s hull should not be scraped, chipped or painted while alongside the pier or at anchor.
• While the vessel is at a shipyard or in dry dock, even if the pollution is caused by the negligence of the shipyard, its employees or agents, the ship may be held vicariously liable for the pollution fine. Therefore crew members should exercise care and should immediately protest in writing to the shipyard where they believe a pollution incident has taken place.

The circular, which includes further details of the pollution fines, as well as information on the appeals process, security requirements to release an offending vessel, and discounts for prompt payment, can be accessed by clicking here.