MARPOL enforcement cases in the US historically have involved violations of Annex I, such as oily water separator bypasses and falsified oil record books (ORBs), coupled with post-incident misconduct by crew members, such as destroying/altering records or lying to the US Coast Guard (USCG). While these cases are likely to continue (as they have for three decades), we also expect enforcement authorities to target Annex VI violations.

Originally published in the March/April 2020 edition of Ship Management International.