I HAVE often thought that it was not beyond the wit of maritime man to design a ship that never, ever, discharged any effluents or wastes into the sea. I would put money to back up my belief that within the next 20 years there will be a design of ship that makes the carriage of ballast redundant, and machinery that will see all liquids recirculated or disposed of on board.

There must be slightly longer odds against ports and terminals having the reception facilities they have been required to make available for visiting ships for the past 30 years, but that is progress for you.

But in an age of environmental activism, when there will be a storm of outrage if a widgeon brought down by a hunter is found to have oil on its feathers, nobody is sufficiently patient to wait for the passage of technological progress.

What is legislation, if it is not to prevent pollution, and the discharges of ships are always a popular target for the politician seeking a just cause. This, then, is the background to the US’ Environmental Protection Agency and its new requirements for the Vessel General Permit, which at least has the potential to make the lives of seafarers and ship operators trading into US waters more difficult than they already are.

The legislation came into effect on September 19 and, although there seems to be a period of adjustment as the implementers decide who is going to do the implementation, it is not something that can be taken lightly by anyone who has a voyage to the US in prospect.

The legislation, designed to eliminate all forms of pollution from ships in US waters, is complex, weighty and covers no fewer than 26 standard discharges that might emanate from a merchant vessel.

So it goes far beyond the concerns of how to properly operate the oily water separator, and ensuring that no overside valve is left open by some dim wiper in the depths of the engine room. It covers everything from ensuring that there is no minute seepage from the stern gland, to the purity of the huge volumes of engine cooling water that are displaced into the sea. If the rain raineth on the decks of the ship, it is thought there must be procedures and records in place to ensure that what poureth out of the scuppers does not carry contaminants and pollutants of any kind.

There is a great deal within the legislation that is specific to different vessel types, whether it is a conventional dry cargoship, a tanker, or passengership with its huge variety of different discharges. And there is much to be concerned about, when a ship operator considers whether the vessel is properly compliant, and the fearsome penalties that might descend upon his head in the case of an infraction.

The legislation firmly places responsibilities upon not just masters and chief engineers, and their supervisors and managers ashore, but all on board ship. As with all US legislation, the punishments prescribed for hapless seafarers and their responsible employers are, to say the least, robust.

It is both the complexity of the legislation, its catchall nature and its applicability to everyone on board ship and in shore-side management that has concerned V.Ships’ Alastair Ireland. After all, some 70% of the huge V.Ships fleet is liable to find itself in US waters with the heavy tread of US regulators on the gangway.

There are 30,000 seafarers employed from all over the world, some 10,000 of whom could, in the next few months, find themselves on a US-bound ship. How on earth does a management company of this size ensure that the risk of transgression is minimised by awareness, diligence and training?

It is not as if they had to start out from square one, Mr Ireland explains. There is, of course, a very detailed Safety Management System, much of which is devoted to protection of the environment and which, in many respects, goes beyond the requirements of the Marine Pollution Convention.

It was not a matter of requiring a change in behaviour to satisfy the US legislators, and it was happily discovered, upon studying the small print that it was most unlikely that there would be any technical issues or new technical requirements. The biggest issue was around record keeping, where the legislation requires that while certain things are done, records to this effect must be diligently and truthfully provided in an acceptable format.

When you introduce the subject of record keeping in the US, alarm bells start to ring. There is no shortage of publicity, in this newspaper and elsewhere, about the terrible things that happen when serious faults are discovered by boarding officials in places like the oily water record statements, and the frightful consequences of lying in record books. Colossal fines, custodial sentences, careers ruined — and that is just the start of it.

The real issue, Mr Ireland says, has been to distil the enormous amount of information within the US legislation — much of which is in complex legal language — into practical and seamanlike advice and instructions, which everyone can understand.

How can large numbers of people be trained in a system that will be applicable to the individual, and to the specific ship type? And in a reasonably short time too, as there is no guarantee that the US will not be coming down hard on transgressors now the legislation is in place.

It was decided that computer-based training offered the best possibility of fulfilling the requirements and V.Ships has turned to its own training organisation, Marlins, to come up with the goods.

Only CBT, it was judged, could provide the right level of training that was applicable to the needs of the individual, and the specific type of ship he or she was serving in. It provides, in an interactive fashion, with a good deal of visual imagery, what the individual seafarer needs to know about waste stream management and the procedures that need to be followed.

Marlins’ Catherine Logie has been conscious of the needs of the multinational workforce, and of the need to provide clear instruction and a means of assessment and verification to ensure that the training has actually registered with the user.

There is a large leisure division in V.Ships and the needs of hotel staff, who also have responsibilities, must be taken into consideration. Think about all that chlorinated swimming pool water, the used contents of jacuzzis and the vast quantities of what we describe as “grey water”. They are as much discharges that require, in the eyes of the US legislators, the same amount of oversight as that underwater seal, or the ballast lines.

Ms Logie says that Marlins’ CBT will work across the V.Ships fleets to ensure that nobody arrives on the US coast unaware of the new requirements. The group also has a number of training centres around the world and these will also be busy.

The training aid will also be made available to external users. It is comprehensive and tailored, she says, with the user getting what he or she needs. However, it is not a “silver bullet” to sort out the Vessel General Permit once and for all, warns Mr Ireland.

V.Ships has been conscious that the US legislation is itself a compromise between states and federal regulators, that elements of it go beyond the prescriptions of Marpol and that there is still a lack of clarity about how it is going to be implemented. Common sense and experience suggests the weight that boarding officers place upon scrupulous record keeping, which tends to affect their whole thinking about the general level of a ship’s compliance.

There must, of course, be some concern at the fact that the US — and not for the first time — is going unilateral on matters that affect all ships and confusing the seafarers on board visiting ships.

Of course, they are entitled to be concerned about what goes into their waters, but should not this have been taken to the International Maritime Organization if there were inadequacies in international legislation?

What happens when the European Commission puts its own slant on the treatment of those 26 standard discharges? When Australia, Norway or Japan decide that they need their own version to protect their waters?

We are then moving inexorably towards the patchwork of different regulations that will plague everyone operating internationally trading ships, and eventually a chaotic system that will drive seafarers, and their employers, insane. It is the IMO where sanity lies, if we did but know it.