The Association has been informed by local correspondent that Turkey has revised sea pollution fines on December 21. The tariff has increased at the rate of 36.2% in terms of both the minimum and additional amount, applicable for the year 2022 as of January 1. We would like to draw Members’ attention again to pollution prevention when calling at or operating in Turkish waters.

I. Categories

Tariff against different types of offending vessels and pollutants can be divided into four categories, a scheme consistent with those of previous years.

A: Petrol and petroleum products discharged to sea by tankers (raw petroleum, fuel oil, bilge, oil mud, refined product oil waste etc.);

B: dirty ballast discharged to sea by tankers;

C: petrol and petroleum products discharged to sea by vessels or any other sea vehicles (bilge, oil mud, freight mud, fuel oil, oil waste or dirty ballast);

D: garbage and sewage discharged to sea by tankers, vessels and any other sea vehicles.

II. Fine rates

In the event of pollution fines issued, the owners are entitled to lodge an appeal before the Administrative Court within 30 days from the fine notification date, though the prospects of successful appeal proceedings can be generally low. A 25% discount will still be applicable if payment of the fine is done within the appeal period.

III. Advice to Members

Referring precautions recommended by the correspondent and in addition to the Association’s previous circular LP 02/2019, the vessels entering Turkish waters should pay utmost attention when performing operations such as ballasting, deck and tank cleaning, dusting, painting, and discharging of bilge, garbage, sewage, or any kind of residues. MARPOL regulations and company requirements with regard to pollution prevention should be strictly followed.

In addition, in the event of a pollution caused by the negligence of the shipyard employees or agents, the ship may be held vicariously liable for the pollution fine. Therefore, the crew members should exercise care and they should immediately take photo evidence or protest in writing to the shipyard where they believe pollution took place.

While calling Turkish ports or operating in Turkish waters, ships should carry out self-inspections once any pollution is found in surrounding waters. Inspection records and evidence should be kept if the pollution is not caused by the ship. If pollutants are found in port areas prior to or during berthing, the master should be extra cautious – ask the pilot/agent to be witness and report immediately to the port authority where necessary.

For more information, please contact Managers of the Association.