Turkey – Pollution Fines 7 July 2015 No.15-007 Download PDF (191KB) Members’ attention is drawn to the Turkey’s strict policy on environmental protection, in particular, pollution including land, sea and air.   This Club Circular draws Members’ attention to the regulatory constraints and outlines how Members may ensure compliance in respect of the law governing the discharge of pollution material into Turkish waters.   1. Turkish Environment Code 2872   1.1. The Turkish Environment Code 2872 (hereafter referred to as “Code”) was first implemented in 1983 and amended in 2006.  This Code establishes a framework for Turkey’s environmental legislation including protection from pollution of land, sea and air, and introduces the “polluter pays” principle.   1.2. Under Article 8 of the Code it is prohibited to diffuse, directly and indirectly, all kinds of waste and garbage into relevant environmental areas, store in, transport to or from, and conduct similar activities by violating the standards and methods determined by the relevant applicable regulations, and causing damage to the environment.     1.3. The Code does not clearly provide what kinds of materials should be deemed waste and garbage causing damage to the environment.  According to Vitsan Mumessillik ve Musavirlik A.S., the Club’s correspondents in Turkey, the local authority interprets the extent of waste and garbage broadly. There have even been cases where the discharge of sea water used for washing accommodation decks and windows or even discharge of clean ballast water were considered as pollution and fines were imposed against the ships involved.   1.4. Grey water such as water used in the galley, laundry and lavatory is not specifically mentioned in the Code.  The Master, therefore, may wrongly believe that discharge of grey water is not prohibited.  It should always be borne in mind that discharge of any kind of water except cooling water is p