Recently there has been some confusion in the market over new guidelines indicating that it is possible to upgrade an existing IMO MEPC.60(33) compliant oily water separator to meet the latest IMO MEPC.107(49) regulations. This confusion has arisen due to a small number of our competitors claiming that by adding a pre-filter or post-filter (polishing unit) to any system, it will allow the original oily water separator to be upgraded to MEPC.107(49).

On the 15th July 2011 IMO adopted new guidelines (MEPC.205(62)) referring to add-on equipment for upgrading resolution MEPC.60(33) compliant oil filtering equipment. Under these guidelines there are a few points that must be noted:-

1. By using add-on equipment, the existing system does not comply with MEPC.107(49):
2. The add-on equipment will be issued with a separate certificate, MEPC.205(62), which will have to be produced in conjunction with the current certification:
3. Two types of certificates are available. One allows equipment to be upgraded with “specific make” of oily water separator. The other one allows equipment to be upgraded with “any make” of oily water separator:
4. MEPC.205(62) only tests the add-on unit with Test Fluid ‘C’ (emulsions) and does not test system with Test Fluid ‘A’ (heavy fuel oil) or ‘B’ (light fuel oil) as stated in MEPC.107(49):
5. The add-on equipment if fitted, is to be installed between the existing oily water separator and the inspection sample point:
6. Where fitted, the 15ppm oil content monitor should be approved to resolution MEPC.107(49).
Victor Marine recommends if customers wish to upgrade their oily water separator, they replace the existing unit completely which ensures full compliance with MEPC.107(49) regulations.

Installing an add-on unit will involve a similar amount of pipework modification and cost but with the added risk that the add-on unit may not be compatible with a current MEPC.60(33) system.

It is essential to stress that a MEPC.60(33) separator which has had add-on equipment fitted and issued with MEPC.205(62) certification, does not, in any way, imply that the vessel can be considered to meet conditions set out in MEPC.107(49). Therefore an MEPC.107(49) compliant certificate will not be issued to the vessel.

We hope this clarifies the situation but please do not hesitate to contact us should you require further information on this issue.

Yours faithfully
Duncan Marshall
Sales & Marketing Manager
Victor Marine Ltd

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