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Sewage Water Fines - Georgian Ports

Our company has observed a recent rise in sewage water pollution cases involving vessels in Georgia. We'd like to share some crucial information to help club managers and members avoid potential losses and hefty fines.

The procedure:

As per the standard procedure, inspectors from the Black Sea Conventional Pollution Inspection board vessels to conduct routine inspections in accordance with various MARPOL regulations. These inspections involve verifying Garbage Management, Ballast Management, and Oil Management record books, as well as inspecting machinery spaces. During such inspections, instances of alleged sewage pollution are frequently identified. It is our practice to attribute all such deficiencies and resulting fines to inadequate maintenance or improper use of sewage treatment plants.

In case such deficiencies will be ascertained by Pollution Inspectors the sample of sewage water will be taken for analysis in order to prove the fact that the vessel discharged untreated or insufficiently treated sewage waters into the territorial waters of Georgia.

The official’s procedure in case of ascertained deficiency will include:

  • Sampling of sewage water from treatment plant and analysis

  • Detention of vessel

  • Extraction of all ship documents and related log books According to the Georgian Code of Administrative Infringements articles 39,239,240, 241 and article 582 will be imposed the fine in the amount of 65000.00 GEL (Georgian Lari) which is currently approximately 23000 USD. The first part of fine (65000GEL) does not relate to the quantity of spillage or its significance and will be imposed as a lump sum fine only for the fact of the pollution. Additionally, the pollution inspectors will calculate the cost for the environmental loss and cleaning which can conclude another several thousand US dollars.

The case will be brought to the City Court for lessening within 1-2 days (Saturday, Sunday and Holidays excluded). Release of vessel will be possible only after remittance of fine to state treasury account. The CLUB LOU or Bank guaranty letters are not accepted by the Court and the only way to release the vessel will be direct remittance of fine via agent or club Correspondent to indicated by the Court state treasure account number.


According to our statistics, the most common problems are:

  1. Malfunctioning overboard discharging valve or blocked valve

  2. Not proper or not scheduled use of disinfection tablets (chlorine)

  3. Tablets or chlorine solution not in place, not charged into the plant

  4. No records in log books about the use of disinfection tablets (chlorine)

  5. Dismantled sewage treatment plant

  6. Planned maintenance of plant at the time of staying in port and at the same time discharging untreated sewage waters into the sea

To prevent vessel detention, and huge fines and minimize the risks, the following minimum actions are recommended for club members:

  1. To collect all sewage waters on board of vessel to the sewage holding tank.

  2. In case of the absence of a sewage holding tank in the required volume collect the sewage in AFT peak tank by sealing it off from the overboard discharge system.

  3. Follow the manual for sewage treatment plant maintenance

  4. Include in engine department maintenance plans (software) the indicated in manuals items for periodic checking

  5. Before entry to Georgian ports ensure that all above-mentioned steps of plant maintenance are followed in accordance with the manual, especially the use of proper quantity and at recommended intervals of chlorine tablets (or concentration of chlorine solution on some types)

  6. Keep in log books the records about the use and maintenance

  7. Check the water at least visually at plant plant-treated water outlet


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