Volume 15: Number 4: November 2008

Containers and cargoes

1 DRI Fines, a dangerous gap in the BC code shortly to be rectified
1 Warning – hot coal at Maputo
2 Engineers are ignoring cargo sensitivity
2 Draft survey – a commercial imperative as well as a safety requirement
3 California block stow – still causing problems

Crewmatters

7 Stowaways and deviation – two thorny issues combined
7 Beware malaria 

Navigation and Seamanship

4 Wind farms – a hazard to navigation?
5 ‘Air booms’ a new complication to berthing manoeuvres
6 Fouled propellers,whose fault?

Miscellaneous

8 US to regulate operational discharges
8 Ukraine – how to prepare for arrival in a Ukrainian port

Containers and cargoes

DRI Fines, a dangerous gap in the BC code shortly to be rectified

Direct Reduced Iron (DRI) comes in several forms and the Bulk Cargo Code (BC Code) recognises the dangers attributed to most, but not all, of these forms.DRI in the form of pellets or cold moulded briquettes is required, amongst other things, to be carried under an inert gas blanket containing less than 5% oxygen. The highly dangerous hydrogen emissions from the cargo are required to be monitored and kept to a level of less than 1% by volume. (The carriage requirements are less onerous for DRI in the form of Hot Moulded Iron). Masters and Members will appreciate that such onerous requirements result in considerable expenditure on the part of shippers, either directly or indirectly, through the level of freight owners would demand. Unfortunately, one particular form of DRI, namely DRI Fines, is not expressly mentioned in the Bulk Cargo Code.

Britannia has had an unfortunate incident involving the carriage of DRI Fines (called Hot Briquetted Iron (HBI) Fines by the shipper in this particular case), when a serious hydrogen explosion caused death and injury. Fines are a residual product which nevertheless have value and are therefore collected over a period of time until there is sufficient quantity to justify shipment. DRI Fines are particularly prone to production of hydrogen especially when in contact with water or damp atmosphere. Shippers, in an effort to avoid the onerous costs of providing an inert blanket, have previously advised carriers that hold spaces containing DRI Fines should be continuously ventilated. Such action would not only fail to prevent the build up of hydrogen but could possibly enhance its production and increase the risk of explosion.

The IMO Safety Committee has recently considered the failure of the present edition of the BC Code to address DRI Fines. Subject to amendments to the BC Code being approved in a final administrative phase, it appears that DRI Fines will be required to be carried under an inert blanket. In advance of the publication of the amended Bulk Cargo Code, we would strongly recommend that DRI Fines (in any form, including HBI Fines) be carried in accordance with the requirements of the present BC Code for Direct Reduced Iron in the form of lump pellets and cold moulded briquettes, that is under an inert gas blanket. Masters should be directed accordingly. Alternatively, the Member/Master should contact the Association for assistance.

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Warning - hot coal at Maputo

The Association has recently received a warning from the Correspondent in Durban about the dangers of loading hot coal in Maputo.

Bulk coal was loaded onto a vessel at the Matola Coal Terminal in Maputo, Mozambique. During the course of loading, coal loaded into one hold spontaneously combusted. Luckily, the smouldering coal was noticed by the crew and all the cargo from the hold was able to be discharged without further, potentially serious, problems. During the discharge it was noted that the temperature of the coal was above the IMO criteria of 55 degrees Centigrade.

Following investigations, it was noticed that at least one shore dump site was burning and there were reports of other shore sites smouldering prior to this incident. This is the first such reported incident from this terminal in the past 5 years and it seems that very strong winds, combined with lengthy storage times, may have contributed to the combustion. Members are advised to be careful when loading bulk coal at Maputo and to make sure that the requirements of the Bulk Cargo Code are followed.

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Engineers are ignoring cargo sensitivity

Engineering officers are continuing to cause damage to grain cargoes by their failure to monitor the temperature of fuel oil in double bottoms. Notwithstanding that Risk Watch has previously highlighted the tendency of engineers to excessively heat oil which is to be transferred from double bottoms to settling tanks, the Association continues to receive claims for heatdamaged grain. Other cargoes such as steel may be affected by high condensation arising from heat generated in the double bottoms. It appears that engineers on board are not being given adequate guidelines on how to avoid cargo damage.

The limits widely accepted to ensure free and efficient pumping of fuel oil lie between 870 cSt and 1040 cSt. The type of pumping equipment, the location of the tank to be pumped and its distance from the engine room will all have an effect on the ability to pump oil. For a typical IFO 380 fuel a viscosity of 870 cSt should be achieved at 38°C, for a typical IFO 180 fuel a temperature of only 26.1°C will be required. In some fuel oils, however, the production processes can lower the viscosity index so that a higher temperature will be needed to achieve the required cST level. In practice this could mean an increase in storage / transfer temperature of around 5–10°C.

In the absence of specific advice from a fuel analysis service company, a storage temperature – for oil in tanks in immediate use – of between 40–45°C for IFO380, and 30–35°C for IFO180, should cover most typical bunkers. Temperatures in these ranges should not adversely affect cargoes.

Superintendents and chief officers might want to put guidelines in place accordingly to avoid excessively heating bunkers and risking damage to cargo.

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Draft surveys - a commercial imperative as well as a safety requirement

All Masters and Chief Officers should, as a matter of course, undertake draft surveys prior to cargo operations commencing, during those operations and again on the completion of cargo operations. Draft Surveys provide the Master and Chief Officer with a method of calculating the amount of cargo, ballast and fuel onboard as well as checking the vessel’s trim and stability. The Association has noted however recent incidents of Masters not undertaking regular draft surveys or, once having undertaken a series of properly conducted draft surveys, not entering on a Mate’s Receipt the cargo quantities calculated.

Whilst it is not clear why Masters and Chief Officers should feel that regular draft surveys are not necessary, it may be the case that the – almost – universal practice in the bulk trades of using shore figures in bills of lading has, in the minds of Masters and Chief Officers, made the draft survey a redundant exercise. Putting aside the needs of safety, the accurate calculation of cargoes onboard by the ship still provides essential evidence in the event of a shortage claim irrespective of shore figures being utilised for bill of lading purposes.

It is generally accepted that when shore-side and ship calculations of cargo loaded differ only slightly, the Master and the owners are entitled to use the shore figures for the loaded quantity in the bill of lading. Where the difference is greater, and the Master has reasonable grounds for suspecting that shore figures are inaccurate, it would be hoped that the shippers and charterers could be persuaded to show both ship and shore figures on the face of the bill of lading in equal prominence. Obviously for the Master to be confident that shore figures are approximately correct and allow shore figures to be utilised he has to have his own check on the loaded quantity i.e. a draft survey. Similarly a draft survey will highlight any large, inexplicable inaccuracy in the shore-figures.

The results of ship’s draft survey calculations are enshrined in the Mate’s Receipts, a critical document for many purposes.

Depending upon the legal regime applicable to any claim for cargo shortages, the possibility exists – even though the bill of lading quantity is the figure upon which the claim would be based – of using the Mate’s Receipts to evidence or dispute the amount actually loaded. Similarly, in circumstances where the owners have been obliged to pay a claim for shortage under a bill of lading showing shore figures, the Mate’s Receipts may be utilised in supporting a claim for indemnity against Charterers.

Where different bulk cargoes are being loaded (discharged), especially where the different cargoes are not loaded (discharged) concurrently, draft surveys should be taken intermittently and especially upon the conclusion of loading (discharging) of one cargo prior to the loading (discharging) of other cargoes.

The failure to undertake regular draft surveys appears more prevalent amongst the Masters of general cargo ships who, because of the wide variety of cargo types loaded, sometimes fail to appreciate that in the absence of a tally the ship’s draft survey is the only way to protect the owner’s interest when loading semi-bulk cargoes.

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Risk Watch Vol 15 No 4 November 2008 CBS Hold plan view of ideal five block stow
California block stow - still causing problems

The ‘California block stow’ method of stowing steel slabs has always been controversial and has caused much difficulty to owners under pressure to conform to a request to stow in that manner knowing that the method is considered less than desirable. The method has changed somewhat from the original form where slabs were loaded with one block beneath the hatch square. The new methodology as described by the California Steel Industries (CSI) manual is not as controversial but problems arise because the manual itself is quite often not followed by the shippers and their representatives.

The modern California block stow (CBS) now includes stowage of slabs in the wings and in the forward and after ends of the hold. However the slabs are not ‘winged out’ in the traditional fashion of the stow butting up against the side of the sloping wing tanks. Rather, the stow is still vertically sided i.e. in a block with considerable ‘broken stowage’ between the slabs and the sloping wing tanks. The ‘new’ CBS therefore remains less than ideal. In effect the modern California block stow consists of five stows; the central block stow immediately under the hatch square, the wing stows and the forward after stows. The separate stows are then bound to each other by ‘Olympic lashings’. Experts are reluctant to call the method unsafe but CBS does require that any Master agreeing to load in this fashion should be particularly careful in making allowances in the navigation of the vessel so as to avoid areas of heavy weather and during periods of heavy weather, or possibly even moderate weather, employ navigational precautions such as adjusting heading and speed to avoid undue rolling. The possibility of ‘heaving to’ should always be considered.

Unfortunately, despite the clarity of the instructions in the California Steel Industries manual for CBS, many shippers, in an effort to reduce costs and improve loading and discharge rates, compromise even the requirements of their own preferred methodology. The Association has had recent experience of such stowage compromises.

The CSI manual quite properly provides that the wing stows should be the full length of the hold. This provides a buttress for the stows in the forward and after ends of hold. Quite often, because of the inadequate length of the hold, only one slab stow can be made in the wings and this usually leads to there being no buttress for the thwart ship stow in the forward and after ends of the hold. Should Members be persuaded that this is unavoidable then their Masters should be made aware of the increased importance of the aforementioned comments on heavy weather.

Shippers also appear to be ignoring the requirement for proper dunnaging between slabs. Dunnage should interlock; it should extend between stows. The California Steel Industries manual stresses that the stow is heavily reliant upon friction for its safety. Clearly, therefore, the greater contact area of dunnage to steel, the more stable and safe the stow. It appears however that shippers are increasingly reducing the amount of dunnage and replacing it with round spacing pieces (cross-sections of logs) which, whilst facilitating the use of fork lift trucks, does not provide the requisite contact area and frictional restraint. A further note of caution: the ‘expert’ community is becoming increasingly aware of how the wood – steel friction co-efficient reduces significantly in circumstances where the surfaces are wet. Deck Officers should therefore be quick to respond appropriately during periods of rain.

This article was produced with the kind assistance of Nic Paines of Newman Giles Co. Ltd. http://www.newmangiles.com

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Navigation and Seamanship

Wind farms - a hazard to navigation?

‘The UK Government wants 33 gigawatts of electricity-generating capacity to be built in the seas around Britain by 2020, together with an additional 14 gigawatts from onshore wind farms. Ministers have set a target of having wind generate at least one-third of all of the UK’s electricity within 12 years.

The Department for Transport has told the wind energy industry that shipping operators have serious concerns about plans to build thousands of huge wind turbines out at sea in a bid to meet the Government’s ambitious renewable energy targets’. click here

The suggestion that marine wind farms present a real hazard to passing vessels has been made many times, but is this fear based on evidence? Given that more and more of these farms are now being constructed, an effort was made in 2006 to try to determine what threat, if any, they actually pose.

Sea trials were recently undertaken, under observance of the UK Department for Transport and the MCA, at the Kentish Flats – the entry point for the Thames Estuary and home to a wind farm comprising some 30 turbines.

During the study 56 transits were made using sea-going and coastal vessels, and their radar displays recorded. Small craft were also placed in the area in order to assess whether the signal from the wind farm made it harder to distinguish these craft as targets.

The results of the sea trials were interesting in that they did not reflect the degree of anxiety that has been associated with these wind farms since their inception. Indeed 30% of the transits produced no radar effects whatsoever, other than the usual return signal from the turbines.

Three effects were observed however; the ‘ghost effect’; ‘linear reflections’; ’the chandelier effect’.

The ghost effect produced a mirror image of the wind farm on the radar. This duplicate (mirror) image was caused by the wind farm’s radar signal being received both directly and, at the same time, via a reflective surface, either a passing ship or some part of the transmitting ship, for example the flat face of a signal mast.

Interestingly container ships with high-sided container stows on deck seem not to act as reflecting surfaces. The observers on the trial concluded this was probably due to the corrugations on the containers breaking up the signal. This ghost image was in general only transient however and often went unnoticed.

The linear reflections were caused by small intervening obstructions in the radar return, these normally occurred when the vessel was passing within 0.5nm of the wind farm and was dependant upon the type of radar antenna being utilised. The reflections were easily identifiable as false targets due to their ‘spoked’ shape and constant rotation around the reflecting target that created movements that could not be mistaken for legitimate targets. They did not interfere with other legitimate signals/targets.

The chandelier effect was identified as potentially the most dangerous. The effect results in a significantly stronger return signal from each of the wind turbines. This is due to the secondary reflections of the turbines on each other’s vertical cylindrical surfaces. This enhanced signal could become problematic for vessels using radar equipped with automatic gain controls (AGC).The AGC may react to a strong return by suppressing it, and therefore potentially also suppressing smaller targets in the vicinity. However this effect was never observed during trials, and could be mitigated by disabling the AGC when approaching the source of a strong signal.

The Chandelier Effect: reflected beams follow reverse direction of arrows.

Overall it would seem that the fears regarding the effect of marine wind farms on shipping are somewhat overblown. Certainly with the constant quest for more sources of energy, and the fact that this type of energy is both ‘green’ and renewable, we will see many more wind farms springing up around coasts the world over. However, by factoring into training courses for mariners the possible disabling of systems likely to be adversely affected by these wind farms, and making everyone aware that increased vigilance is necessary, any serious problems should be avoided. There may also be an increased reliance on local pilots, who know the area and will be well aware of the farms and the need for increased care in navigating around them.

This item is based on an article which appeared in the October Edition of Nautical institute magazine ’Seaways’ written by Capt. Dennis Barber MRIN, FNI (Marico Marine). http://www.marico.co.uk

Risk Watch Vol 15 No 4 November 2008 Wind Farms Ghost Effect Linear reflection

Risk Watch Vol 15 No 4 November 2008 Wind Farms The Chandelier Effect

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'Air booms' - a new complication to berthing manoeuvres?

A Britannia Member recently reported an unusual incident whereby the operation of the ship’s engine during berthing allegedly damaged an air boom. The term air boom is new to the Association but it appears to be a system of underwater pipes laid around a berth which can supply a curtain of air bubbles to contain oil in the event of a spillage from the terminal or ship alongside.

The incident in question occurred in Gdansk. Following what appeared to be a routine berthing operation, the Master received notice that his ship had damaged the air boom because he had failed to ensure that the engines were stopped whilst passing over the air boom. This came as a complete surprise to the Master as he had received no notice of any requirement that engines be stopped whilst passing the boom nor indeed any notification of the existence of an air boom. The vessel had a pilot on board during the berthing operation who did not mention the existence of the air boom.

In this particular incident the lack of notice to the Master of the requirement to stop engines would have been academic as the ship in question operated with a variable pitch propeller which required, as is usually the case, that the equivalent of ‘engine stop’ is that the propeller pitch is put to zero but the propeller and engine remain turning (at approximately 105 rpm).

Subsequent investigation revealed that neither the British Admiralty charts nor British Admiralty Sailing Directions refer to any requirement not to use engines whilst coming alongside the berth. The Port regulations only require vessels to moor or un-moor with restricted use of their own propulsion. A similar requirement appears in the Terminal regulations. Neither document refers to an absolute ban on engines being used nor indicated why these restrictions were necessary. None of the regulations mentioned referred to the existence of the air boom.

Notwithstanding the lack of advice to the Master, it seems impractical to impose a complete prohibition on the use of engines during berthing manoeuvres as implied in the notice of damage served on the Master in this case. Further, given that the vessel in question had under keel clearance of 4m it would appear that the construction of these air booms is arguably somewhat flimsy.

Any mariners becoming aware of the existence of an air boom should immediately enquire of the pilot and/or their agents whether operational restrictions apply.

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Fouled propellers, whose fault?

Many Deck Officers, whilst at mooring stations, have suffered that moment of dread when a mooring rope or buoy disappears under the stern and then can only wait to see if the propeller becomes fouled. If it does then a dangerous situation could arise whereby the berthing or un-berthing manoeuvre becomes uncontrollable. At the very least, a potentially expensive day or two is lost whilst commercial divers are contracted to clear the fouled propeller. Often, such situations involve the ship’s own lines, but who would be responsible if the lines belonged to another vessel, say a vessel which was double-banking, or perhaps the line was from a poorly maintained fender? Could the Master and the Owners rely upon that other party being held responsible? If they could, would some residual liability nevertheless remain with the ship whose propeller was fouled?

The recently reported case of the KRYSIA may be of interest in this respect. The KRYSIA was a twin-propeller supply vessel manoeuvring portside alongside an accommodation barge 60 miles off the Nigerian coast. The accommodation barge had Yokohama fenders in place. Having discharged some cargo the KRYSIA was obliged to back load a container of waste materials which was to be loaded by the crane of the FPSO alongside which the accommodation barge was itself moored. The KRYSIA was maintaining position alongside the accommodation barge by the use of her engines. Unfortunately the crane driver on the FPSO placed the container on her deck in such a way that a turning moment was imposed on the KRYSIA which then moved slightly out of parallel to the accommodation barge. In order to return the vessel to ‘parallel’, the Master put the port engine to dead slow astern and starboard engine to dead slow ahead. Unfortunately, immediately after he had engaged the two engines in this manner, there was an unusual noise from the engines and the disconcerting sight of the Yokohama fender being pulled towards and under the stern of the vessel. The port engine shut itself down and the Master stopped all manoeuvres. It was clear that the aft securing wire of the fender had become fouled round the KRYSIA’s port propellers. The resulting damage was, allegedly, in excess of US $500,000.

The Yokohama fender had both a securing wire and a pick-up rope attached to its aft end. Two alternative explanations for the incident were argued by respective sides to the dispute. The KRYSIA argued that the pick-up rope, which was 10–12 metres long, must have been loose in the water and became fouled thus dragging the securing wire into the KRYSIA’s propeller. The opponents argued that the KRYSIA’s stern had come too close to the aft mooring arrangements of the Yokohama fender and made direct contact with the securing wire. The court found that the KRYSIA’s version of events was most likely. The fact that a few days prior to the incident the Yokohama fender had been lifted out of the water for maintenance may have swayed the court in favour of the KRYSIA’s version of events. However, the court did not find the KRYSIA’s Master completely without blame but rather found him negligent in allowing the vessel to drift aft of the fenders into the vicinity of the securing wire.

Although it was decided that the accident would never have happened if the pick-up rope had not been loose in the water, the blame and the liabilities were apportioned 70/30 in favour of the KRYSIA. Accordingly, KRYSIA’s owners could recover only 70% of their losses.

This case threw up an interesting legal point on costs. Normally the legal costs in a collision follow the apportionment of blame so that, in this case, the KRYSIA would have expected to pay 30% of the opponents’ legal costs. However, the court distinguished this accident from a collision and, noting that the KRYSIA had initiated proceedings in order to recover its damages from the opponents and were effectively the winning side, allowed KRYSIA to recover her full costs from the opponents and required their opponents to pay their own costs without contribution from KRYSIA.

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Crew matters

Stowaways and deviation - two thorny issues combined

Dealing with stowaways is difficult; often they cannot speak English, or other ‘international language’; they usually lack papers; they can be un-cooperative; they can be dangerous.

Trying to match a stowaway’s nationality or his originating port with a suitable port or jurisdiction where he can be landed for repatriation is a complex matter. Utilising the Association’s experience in these matters, and with the considerable assistance of correspondents, it can usually be quickly established at which ports within the region repatriation would not be allowed (or be impractical) and those from which repatriation may be feasible and economic. If a Member is lucky, that port would be one at which the vessel is already scheduled to call. If it is not, and the vessel needs to divert from the original intended voyage, then the stowaway issue becomes one which is complicated by the owners’ obligations under the bills of lading and charter party.

Irrespective of whether a vessel is operating under a charter party or for its own account, bills of lading are likely to be issued for and on behalf of the Master and he therefore has an obligation to proceed with due despatch i.e. directly from load port to the discharge port by the shortest or the customary route. Diversion from the customary route can have severe consequences in terms of cargo liability.

Generally speaking, an owner will have defences and limitations on liability under a bill of lading that will protect him in the event of cargo damage. If the vessel does not undertake the contracted voyage from A to B directly or by the customary route, as required by the contract, then the courts may consider that the owner, as contractual carrier has deviated (deviation being a particular type of breach of contract) from the agreed contract. Should there be any cargo claim as a result of the deviation, the vessel may lose these defences and limitations. That is not to say that the vessel cannot divert to land stowaways. The courts will not find the owners in breach of their obligations if the diversion is reasonable. ‘Reasonable’ usually means for the benefit of both ship and cargo.

If the stowaways are violent or present in such numbers that they pose a threat to the safety of the ship, to divert and land them could be considered reasonable and would not give rise to the difficulties mentioned. However, if the diversion was found to be undertaken for the convenience of the ship only, for example to reduce the expense and difficulty of the owner in dealing with the stowaways, it might be deemed unreasonable and therefore a deviation from the contract. In that circumstance, special insurance – Ship Owners Liability Insurance (SOL) – can be purchased to provide financial cover for the vessel to divert to a convenient port to land stowaways. The insurance will cover any additional liabilities to cargo interests which would not have arisen but for the deviation.

It is important for Masters and Operations Departments to take the possible need for SOL into account when deciding to divert to land stowaways. Firstly, it has to be understood exactly why the vessel is deviating to a port to land stowaways, either because the stowaways are thought to be a threat to the vessel or because that port is the most convenient both in practical terms and economic terms. Secondly, to be aware that such additional insurance may take time to put in place and the cost of that insurance has to be taken into account when determining whether deviation to land stowaways is indeed economic at all.

For vessels under time charter a decision to deviate to land stowaways also has to take account of the likelihood that the vessel will be put off-hire. Some charters may have a clause which provides that where stowaways get on board through charterers fault (hiding in cargo) then charterers are liable for all consequences, but that owners are liable if they board because of poor ship security. If the charter has no such clause then, under the NYPE charter party, deviation to land them may constitute a breach of the Master’s obligation under clause 8 to prosecute the voyage with utmost despatch. Owners may be liable in damages for losses suffered by charterers. This will include cost of bunkers consumed in the deviation and port costs where the stowaways are landed. In addition the vessel will usually be off-hire for the deviation time lost pursuant to Clause 15 of the charter which provides for hire to cease due to listed causes and ‘any other cause preventing the full working of the vessel’. Deviation would be considered to be such a cause.

Members are urged to consult with the Managers when considering whether to deviate to land stowaways.

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Beware of Malaria

The Association is aware of a possible increase in the number of malaria cases being reported. Malaria is one of the world’s most common tropical diseases and all seafarers travelling to malaria affected areas, such as Africa, south and central America, Asia and Middle East, should be aware of the risks and precautions that should be taken.

Mosquitoes and prevention against being bitten
Malaria is transmitted by the female Anopheles mosquito and causes acute fever. There are several different strains of malaria but some types can be fatal unless the infection is diagnosed and treated promptly.

Within two miles of a malarial shore it is important that;

  • External doors and windows are kept closed after dusk;
  • Any mosquitoes entering compartments are killed;
  • Insect spray is used, especially between dusk and dawn;
  • Between dusk and dawn long sleeved shirts and trousers are worn when ashore or on deck;
  • Pools of stagnant rainwater or dew are removed;
  • Refuse bags are properly sealed;
  • Portholes and other openings are protected by fine wire mesh;
  • Lights are screened to avoid attracting mosquitoes.

Mosquitoes are most active after dusk and prior to dawn. Sleeping arrangements should involve using undamaged, impregnated, mosquito nets, hung over the bed with the bottom tucked under the mattress.

Be disciplined about taking anti-malaria drugs
When a ship is bound for a malarial port, in addition to taking all possible preventive measures to prevent mosquito bites, medication will be given to the whole crew. Most medication is taken for a set period before entering a malarial zone, is continued whilst in the zone and for a set period after leaving (as malaria has an incubation period of between seven days and three months). It is important to take the medication for the whole period.

Preventative medication, together with other measures listed above will greatly reduce the chances of catching the disease. See the following website for more detailed guidance.

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Miscellaneous

US to regulate operational discharges

The US Environmental Protection Agency (EPA) has been required by the US Court of Appeals to regulate discharges incidental to normal operation of vessels under the National Pollutant Discharge Elimination System (NPDES) programme. The application of the NPDES programme to commercial vessels calling at US ports will take effect from 20 December 2008. From that date all commercial vessels of 79 feet in length or greater with discharges of pollutants incidental to their normal operation within the 3 mile territorial sea or in inland waters must comply with the EPA final VGP (Vessel General Permit) requirements. It should be noted that this regulation is not limited to ballast water discharges incidental to normal operation. Unfortunately the EPA has not yet finalised the VGP requirements and does not expect to do so until early December; there is limited time therefore for implementation and compliance.

In their Marine Guidance Note 383 the UK Maritime and Coastguard Agency (MCA) strongly recommends to UK ship owners that intend to have any of their vessels call at US ports after 19 December 2008 that they begin development of a compliance programme based on the VGP currently proposed by the EPA. It should be borne in mind however that changes to compliance programmes may need to be made by ship owners after the final VGP is issued by the EPA. Ships are required to have permits. The proposed VGP can be seen at http://cfpub.epa.gov/npdes/home.cfm?program_id=350 under ‘Proposed Permit’. The proposed VGP identifies 28 different vessel discharges that are ‘eligible for coverage’; it is very unlikely that these will change when the final VGP is issued.

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Ukraine - how to prepare for arrival in a Ukrainian port

Our correspondent in Odessa, DIAS Co, Ltd, has added a new section to their website to assist Masters with the preparations for their vessel’s arrival in Ukrainian ports. They have pointed out that there is much information requested by the State Inspection authorities prior to a ship’s arrival and that there are often harsh penalties if the information is not given at the required time and in the correct form.

DIAS realise that Masters are often busy with many things as the ship approaches port and they also may not appreciate the consequences of not complying with the demands of the authorities. DIAS also points out that not all local agents provide sufficient advice and assistance and so the guidelines set out in the website article will act as a useful checklist for Masters.

The relevant page can be found on the DIAS website: http://www.dias-co.com/index.php?page=100

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Editor's message
We are always looking for ways to maintain and increase the usefulness, relevance and general interest of the articles within Risk Watch. Please forward any comments to: rwatched@triley.co.uk

 

 
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