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pump had not been dismantled in that time. Ship did not have any alternative plan in the absence of O.F.E system proper operation. Based on above, concerned with convention and professional judgments, we have made reassessment and still considered that the detention is reasonable and suitable. Generally, the bilge pump is the key part of the O.F.E system required by MARPOL and IOPP certificate. The detention for the reason of malfunction of bilge pump for the O.F.E has not any disputations according to Appendix 2 to IMO A.1052 (27). First, the view that the incident of the lock nut loosened and the piston rod disconnected mostly had been caused by the ship’s vibration cannot be accepted by PSCO. The reasons for the physical and mechanical malfunctions mostly result from lack of satisfactory maintenance, proper operation and regular checking. The vibration may not be the major factor. Second, you mentioned, Failure of this pump was not the root cause of an accident discharge of bilge water directly overboard, residues can be retained in the holding tanks. The capacity of holding tanks, the oily water ROB, the periods of intended voyage, and the production of oily water per-day etc, we cannot deny that the possibility violation of MARPOL, such as bilge water been discharged into sea by pass the O.F.E with another pump and pipes for some unexpected factors. Last, we fully agree and highly appreciate with company safety culture. In this case, to some extent, the Captain or chief engineer may have not strong vision for risk assessments. If the O.F.E cannot be used in the intended voyage, alternative means shall been conducted or considered, such as, how many oily water ROB, what capacity of the tanks, arrangement of oily water discharging into port facility etc.【缺少答案,请补充】