The Port of Inverness is a thriving commercial enterprise, situated at the mouth of the River Ness. The Port handles close to three quarters of a million tonnes of cargo per annum. The number of commercial vessels using the Port remains steady at approximately 220 per annum, but the general size of vessel has increased significantly over the last few years, and cargo tonnages have therefore shown a steady increase. The Port is tidal, and can handle vessels up to 5000 DWT.
The major import is of various grades of fuel oils, virtually all from UK based refineries. Other significant imports are processed timber, salt, grains, carbon blocks, animal feed and general cargo, from around the European area. Exports include sterling board, grains, wood chips, wood pellets and general, to European ports. Exports have on occasion gone to the USA, and cargo continues to be exported to Turkey.
Inverness Harbour Trust has had an operational Port Waste Management Plan, authorised by the MCA, since October 1998. The requirement to do so was initially stipulated under the Merchant Shipping (Port Waste Reception Facilities Regulations) 1997. Subsequent legislation has modified the requirements on the Port, and the customers who use it. Amendments to the original plan were made by way of addendums by the MCA, and the plan itself periodically locally reviewed to ensure its relevance and effectiveness.
During 2007/2008 a ten hectare extension was constructed at the mouth of the river. This has created additional lay-down areas, a new 150 metre quay called “North Longman”, and a new 150 berth Marina.
During 2010 a new road access for the Port was built.
This was constructed with a bellmouth opening, specifically for the movement of turbine blades up to 50m in length from the Port.
The Marina operation is a joint venture between Inverness Harbour Trust and Caley Marina, and the company formed to run it is called Inverness Marina Ltd. Their waste streams are totally separate to that of the Harbour, and they hold their own Waste Plan. Contact details for Inverness Marina Ltd are on page 11.
Responsibility for implementation of the Waste Management Plan rests with the Harbourmaster, as directed by Inverness Harbour Trust. Contact the Harbour Master
MARPOL Regulations 1973/78 - The International Convention for the Prevention of Pollution from Ships (Known as MARPOL 73/78) provides an international framework on how pollution from shipping should be regulated. MARPOL applies to all UK ships and all ships in UK
Territorial waters, including fishing vessels, passenger ferries, small craft and yachts, harbour authorities and terminal operators. It simply requires states to ensure that the provision of waste reception facilities are ‘adequate’ and do not cause ‘undue delay’ to the ships using them.
‘Adequate means capable of receiving the types and quantities of prescribed wastes from ships normally using that harbour or terminal taking into account the operational needs of the users of the harbour or terminal, its size and geographical location, the types of ships calling there and any exemption provided’.
MARPOL covers five specific areas. These are enumerated as follows:
ANNEX 1 - Regulations for the Prevention of Pollution by Oil.
ANNEX 2 - Regulations for the Prevention of Pollution by Noxious Liquid Substances.
ANNEX 3 - Regulations for the Prevention of Pollution by Harmful Substances in Packaged Forms. ANNEX 4 - Regulations for the Prevention of Pollution by Sewage.
ANNEX 5 - Regulations for the Prevention of Pollution by Garbage.
The United Kingdom is a signatory to Annexes 1, 2, 3, 4 & 5
This plan will be amended when the Annex 4 of MARPOL has been incorporated into UK legislation.
MARPOL 73/78 is implemented in the UK through the following regulations.
STATUTORY INSTRUMENTS :-
2003 No. 1809 -MERCHANT SHIPPING
The Merchant Shipping and Fishing Vessels (Port Waste Reception Facilities) Regulations 2003
2009 No. 1176 - MERCHANT SHIPPING
The Merchant Shipping and Fishing Vessels (Port Waste Reception Facilities) (Amendment) Regulations 2009
2008 No. 3257 - MARINE POLLUTION
The Merchant Shipping (Prevention of Pollution by Sewage and Garbage from Ships) Regulations 2008
2010 No. 897 - MARINE POLLUTION
The Merchant Shipping (Prevention of Pollution by Sewage and Garbage from Ships)(Amendment) Regulations 2010
2011 No. 3056 - MERCHANT SHIPPING
The Merchant Shipping (Ship Inspection and Survey Organisations) (Revocation) Regulations 2011
2014 No. 3306 - MARINE POLLUTION
The Merchant Shipping (Prevention of Pollution) (Limits) Regulations 2014
MARINE GUIDANCE NOTES :-
MGN 387 Guidance on the Merchant Shipping & Fishing Vessels (Port Waste Reception Facilities)
MERCHANT SHIPPING NOTICES
MSN 1678 – THE SPECIAL WASTE REGULATIONS 1996
These Regulations aim to ensure that anyone who may consign, carry or receive special waste should be responsible for the proper handling and disposal of that waste.
The Duty of Care Regs - Section 34 establishes the Duty of Care was established on anyone who produces, imports, carries, keeps, treats or disposes of controlled waste. This does not apply to householders. Within The Duty of Care is a system for transferring the waste to a receiver of the waste. A Waste Disposal Transfer Note is used with written descriptions and details of the controlled waste, and records of these transfers are kept for a minimum of 2 years.
The Waste (Scotland) Regulations 2012. SI. 148
These regulations aim to ensure that the minimum level of service on offer to households and businesses across Scotland is better than that of today and signal the end of landfilling biodegradable municipal waste in Scotland. Also known as “Zero Waste Regulations”.
3. Objectives of the Plan
To bring to the attention of Port users their responsibilities as a result of legislation.
To inform Port users of the facilities available to them for the disposal of waste, at the Port.
To ensure facilities provided comply with the regulations and meet the needs of Port users.
4. Waste types and quantities
It is a requirement of the Merchant Shipping and Fishing Vessels (Port Waste Reception Facilities) Regulations 2003, that the responsible Port Authority carries out an assessment of the types and quantities of waste expected. This assessment will then be compared with the quantities actually received. This is done annually in January and statutory reports forwarded to the MCA.
Coastal tankers importing various grades of fuel oils make up a quarter of the vessels calling at the Port.
These short sea vessels discharge their cargoes to a facility in the upper part of the Port, with the vessels taking river water for ballast prior to sailing. There is therefore no requirement for them to dispose of dirty ballast water, this being dealt with at Immingham and occasionally Grangemouth, where the majority of the tankers are loaded.
Short sea bulk and general cargo vessels make up the other three quarters of vessel types using the Port. These cargoes are both imported and exported, and the Longman quay, at the lower part of the Port is the area where the vast majority of these vessels are handled. Along with the normal ship generated waste, a significant amount of operational cargo waste is generated. This comprises dunnage, slings, battens, steel banding and polythene sheeting. The vessels’ agents are responsible for arranging for the disposal of all cargo-related waste in an appropriate manner.
Other producers of waste
A 150 berth yacht facility was constructed during 2008 as part of the Longman Quay extension project.
The Harbour Office is used by the Port Authority on the upper floor, and offices downstairs are leased out to the Maritime & Coastguard Agency. Normal Harbour Office rubbish is gathered nightly and disposed of in the same covered skips as are provided for commercial ship use. Plain paper is collected in dedicated office bins for recycling. Plastic bottles and cans are also collected in a dedicated bin for recycling.
The MCA Coastguard staff, who occupy offices within the Harbour Office building, dispose of their own rubbish off-site and independent of this Waste plan.
There is one small company who leases operational space at the upper harbour, from the Port Authority. This company makes their own arrangements for the collection and disposal of their own generated daily office waste, and such waste is disposed of outwith the Port facilities.
The Port Authority provides one covered skip, three x 1,100 litre eurocarts and two wheelie bins, for the reception of ship garbage within the Port. These are currently provided through a local contractor, Northern Recycling.
The skips, eurocarts and wheelie bins are situated at three points:-
1. The downriver end of Longman quay
2. On Citadel quay close to the tanker berth.
3. North Longman Quay
A daily check is kept on how quickly the skips are filling, and they are emptied appropriately. The cost of these skips is borne by the Port Authority. (See appendix 1 for a schematic plan of the locations.)
These skips and Eurocarts are for commercial vessel use only, visiting yachts must use the facilities provided for them within the Marina.
Disposal of very large amounts of garbage, requiring more than one skip, must be arranged through the Agent, and paid for accordingly.
“Segregated Waste”. There are limited segregated facilities for the reception of different types of ships garbage for recycling. These are located at the three locations as detailed above.
Two separate appropriately signed euro-carts have been provided for paper, cardboard, glass and plastic.
Two separate appropriately signed wheelie bins have been provided for glass. The euro-carts and wheelie bins are emptied every four weeks for recycling.
The Port Authority also has a small 1,200 litre oil reception tank/pump, mounted on a trailer. This tank is for receiving small quantities of waste oil and bilges, from Coastguard vessels, operational craft, and from servicing port vehicles.
This service is provided free of charge and the cost is borne by the Port Authority.
A very small amount of waste oil in 25 litre drums is disposed of by the Port, on behalf of Port users. The Port maintains a separate Waste Oil Register for recording such quantities received.
Commercial vessels wishing to land 205 litre drums, either empty or part filled, must arrange their disposal directly through the ships Agent. Under no circumstance are they to be left beside garbage skips, or on the quayside.
The Port does not provide skips for reception of cargo wastes. The main company operating on the dry goods side at the port is Scotlog Sales. This company makes their own arrangements, through Finnies, for the adequate provision of open skips for the reception of dunnage, slings, battens, steel banding and polythene sheeting. The costs of these are borne by Scotline directly.
There are no dedicated facilities at the Port for the reception of tank washings, oily mixtures containing oils in bulk, sludge, scale, or sewage. Should a vessel of any type require to land this material, then it can be facilitated by the use of a road tanker, from an approved waste disposal contractor, arranged directly through the ships agent. Twenty-four hours notice is usually required for this facility.
Approved contractors will normally invoice ships Agents for payments for disposals, but Masters should obtain receipts for quantities. (Details should be entered in ships record book for future inspection by Port State Inspectors).
Each year, the Port Authority will check with the inpidual shipping Agents as to how many such road tankers have been employed. It is usually three, or less. This info forms part of the annual return to the MCA.
Yachts wishing to pump out sewage holding tanks or the emptying of chemical toilets, have dedicated facilities provided for them within the Marina, operated by Inverness Marina Ltd, IML.
“Special waste”, and waste from “Harmful Substances in Packaged Form”, from a vessel must be disposed of via an approved waste disposal contractor, arranged directly through the ships Agent. Special waste includes; lead acid batteries, fluorescent light tubes, tyres, television/computer monitors, aerosols, asbestos, solvents, and any other item listed in MSN 1678.
Redundant fridges/freezers or washing machines must not be left adjacent to skips. Arrange disposal through your ships Agent.
The above items must never be added to a normal harbour quayside skip, which would then have to be classed as Special waste in its entirety, causing greatly increased costs. Should this occur, then the Harbour reserves the right to charge the ships Agent acting on behalf of the vessel for the recovery of all costs incurred in disposing of any such contaminated skip.
“International Catering Waste” may on occasion be received at the Port. Given that this is only for food waste from non-EU countries that qualifies, and that the type of short sea shipping operating in and out of the Port is generally only trading with other EU countries, a dedicated facility has not been put in place. However the Port has had numerous contacts with the approved waste contractors as to the likely costs involved of receiving and disposing of such waste, along with the costs of subsequent disinfection of containment used.
It is the responsibility of the Master of a vessel arriving from a non-EU country, to liaise with his ships Agent for the collection of any ICW held aboard. Given that the quantity is likely to be small and that ICW has to be transported out of the Highlands for disposal at licensed landfill, the most cost effective option for the vessel may be to retain it aboard for disposal at a larger, southern port. If however it must be landed, then it must be received it into an appropriate sized closed skip arranged through the ships Agent.
ICW must never be added to a normal harbour quayside skip, which would then have to be classed as ICW in its entirety and disposed of accordingly, causing greatly increased costs. Should this occur, then the Harbour reserves the right to charge the ships Agent acting on behalf of the vessel for the recovery of all costs incurred in disposing of any such contaminated skip.
As with the previous Port Waste Plan, Inverness Harbour Trust is required to consult with all Port Users and other organisations having a reasonable interest in the proper disposal of waste arising from shipping and Port activities. The simplest way of ensuring that reception facilities meet the needs of Port users and complying with the requirements of the regulations, is to talk to those who need to make use of them. This Plan is intended to be a “live” document and as such users are encouraged to notify the Port Authority of amendments and/or improvements as they occur, rather than waiting for planned review meetings, which will be held at intervals not exceeding three years. The effectiveness of the Plan will be subject to constant monitoring with any subsequent proposed changes being subject to full consultation with the users.
The consultation exercise for this Plan has included representation from Port Users, Ships' Agents, waste management contractors, the local Maritime & Coastguard Agency, Port Health Authority, members of the yachting community, and operational staff.
The following are some of those consulted:
Mr Murdo Grant - Self Storage 4U
Mr S Catto - Scotlog Sales
Mr H Fraser - Caledonian Oils Ltd/Certas Energy
Mr A McLarty - Costain
Mr H Young - Maritime & Coastguard Agency
Mr L Seaton - Sureclean Ltd
Mrs A Booth - Northern Recycling Ltd
Mr S Finnie - Finnies Ltd
Ms V Taylor - Veterinary Officer, Scottish Government
Mr A Yates - Highland Council Environmental Health
Mr A Galloway - Scottish Environmental Protection Agency
Vessel Masters in both James Fishers Tankers and Scotline fleets.
7. Charging Structure
Under the “polluter pays” principle, ships should bear the cost of providing reception, treatment and disposal of waste, but the cost of using port waste reception facilities should not be so high that it encourages disposal of waste at sea.
All ships must pay the Port a mandatory charge, which makes a significant contribution to the cost of port waste reception facilities, irrespective of the actual use of the facilities.
The policy of Inverness Harbour Trust is to consolidate the mandatory charge within the port dues. This is done by incorporating an additional charge of 1.5 pence per gross tonne, within the overall charge for berthing dues, applicable to all commercial vessels calling at the port.
The cost of the Waste facility provision, against that received from the vessels, is checked on an annual basis. At present there is a 100% recovery of costs.
8. Prior notification
At least twenty-four hours prior to arrival in port, the Master of a vessel is required to inform the Port authority, by e-mail or fax, of the type and quantity of waste to be delivered to the waste reception facility. This does not apply to fishing vessels or to pleasure craft authorised to carry no more than twelve passengers.
It is the responsibility of the Master of a vessel arriving from a non-EU country, to liaise with his ships Agent for the collection of any ICW held aboard.
Virtually all commercial craft now have their own version of the pre-notification form required, but should a vessel not have one, then on contacting their Agent, or the Port Authority, a pro-forma can be either faxed or e-mailed to the vessel, for their use.
An example of this pro-forma is attached within the annex to this plan.
E-mail address: firstname.lastname@example.org
Fax: 01463 715705.
The notification forms are retained on file for the current year, plus twelve months. Data from the notification forms are retained on monthly summary sheets, and used for compiling the annual notifications to the MCA.
9. Delivery of Waste
The Master of a vessel calling at the Port of Inverness shall ensure that before the vessel leaves the port, all vessel-generated waste is delivered to a waste reception facility, unless sufficient dedicated storage capacity is available to store the waste until the next port of call, and the correct notification procedure has been followed.
The responsibility for ensuring that the quantity and type of waste landed, is as stated on the pre- notification to the port, lies solely with the ships Master. Port staff may make random spot checks on the waste being landed.
Non-Compliance will be reported to the MCA via the Central European Reporting System (CERS) website. (Ref MGN 387). Such vessels may then be made a target by the MCA for inspection, who may inform other ports/terminals of their non-compliance. Vessels that fail to comply with the requirements shall be guilty of an offence and liable on summary conviction to a fine.
11. Deficiency reporting
Given that the large majority of vessels trading to the Port, are regularly returning throughout the year, and that the type of wastes being landed is fairly mundane, it has not been the policy of the Port Authority to issue a form for reporting deficiencies to each and every vessel attending the port. Feedback is obtained verbally from the port users, and regular vessel Masters, if there is any issue arising.
Masters should in the first instance contact the Harbour Master, to allow the complaint to be investigated, and to rectify the deficiency. (A copy of the MCA form from MGN 387 Annex D is attached to this form.)
For the vessels that have not been to the Port before, a General Information sheet on the Port is given to vessel Masters by the Pilot, on boarding the vessel on arrival. This form has the plan of the harbour, giving the garbage skip locations, printed on the reverse.
At the same time any issues to do with the provision of waste facilities, and their locations may be discussed.
(A copy of the Information sheet is annexed to this plan.)
Vessels can apply for an exemption from some of the requirements of the Port Waste Reception Regulations. Ships so entitled should apply to the MCA in accordance with MGN 387, who will then advise Inverness Harbour Trust, if such a vessel has received an exemption.
Workboats, pilot boats and other similar vessels that operate within the Ports area of jurisdiction, and do not normally leave the area, fall outside of the scope of the requirement to notify, deliver or pay charges.
13. Contractor Lists
Sureclean Ltd - 10 River Drive, Alness - 01349 884480
Northern Recycling Solutions Ltd - Alexander House, River House, Teaninich Ind Est, Alness, IV17 0PG - 0345 8945130
Finnies Skip Hire - 32 Longman Drive, Inverness - 01463 713637
MSIS - Admiralty Base, Shore Rd, Invergordon - 0844 8804182
Northburn Industrial Services - Blackdog Industrial Centre, Aberdeen - 01224 825448
14. Useful contacts list
Inverness Harbour Trust - Harbour Office, Longman Drive, Inverness, IV1 1SU - 01463 715715
MCA (Douglas Temple), Nautical Surveyor - East SCOTNI, Aberdeen Marine Office, Marine House, Blaikies Quay, Aberdeen AB11 5EZ - 01224 597900
Inverness Marina Ltd - Longman Drive, Inverness, IV1 1SU - 01463 220501
SEPA (Mr Alasdair Galloway) - Graesser House, Fodderty Way, Dingwall, IV15 9XB - 01349 862021
AHVLA (Animal Health Vet Lab Agency) (Scottish Executive) (Ms V Taylor) - Longman House, 28 Longman Road, Inverness, IV1 1SF - 01463 728800
Highland Council Environmental, Environmental Health Manager (Mr Alan Yates) - Glenurquhart Rd, Inverness - 01349 886606
Highland Council Waste Services (Mr Andy Hume) - Community Services, Ross House, High Street, Dingwall, IV15 9RY - 01349 868614
Review of the Port Waste Management Plan will be carried out at least every three years, and will involve consultation with representatives of the Port users, regulatory authorities, and other concerned bodies.
16. MCA Annual Reporting Forms
There are two sets of information that must be submitted on an annual basis to the local Marine Office by the plan holder. In both cases the information should be submitted by the end of April each year, and should take the form of a written or electronic return.
There is a continuing requirement under MARPOL 73/78 for the UK to provide information to the international Maritime Organisation (IMO), as to the type, capacity, and notice required to use reception facilities for oily wastes, noxious liquid substances, tank washings and slops. A copy of this form is annexed to the Plan.
The UK Regulations and EC Directive require information on amounts of waste landed, and totals for the amounts retained onboard vessels, to be collated by the Plan holder, and returned to the MCA. This return should break down the amounts of waste into the format found in the notification form (Schedule 2 of the Regulations), and should additionally provide an update on the Ports mandatory charge for the provision of port waste reception facilities, if there have been changes made that year. A copy of this second form is also annexed to this plan.