Volume: 16 Number: 3 November 2009
Containers and cargoes
1 DRI fines to be addressed in revised BC Code
2 Loading Iron Ore Fines at New Mangalore in the monsoon season
Crew matters
3 Master's attempts to placate stowaways backfires
3 Fishing from the dock proves to be expensive
Navigation and seamanship
4 Six miles of unlit danger
6 Apparent increase in damage to shore cranes
7 Engine room flooded
Regulatory update
8 Mis-reporting of lube oil leaves vessel at the mercy of local customs
Miscellaneous
8 Publications
Containers and cargoes
DRI fines to be addressed in revised BC Code
The inherently dangerous nature of the carriage of DRI (Direct Reduced Iron) fines, is soon to be addressed by an amendment to the BC Code.
In the recent past, cargoes of DRI fines have been known to cause serious explosions along with death and injury to seafarers; the case of the MV YTHAN with the loss of six crewmembers in 2004 is probably the most notorious case. Shipments of DRI fines are well known for improper or insufficient declaration of the dangerous nature of the cargo. Foremost amongst the difficulties regarding accurate declarations is the failure to properly identify the cargo.
DRI itself comes in several forms which can be confusing, the fines are a by-product and are not easily categorised, furthermore the Bulk Cargo Code (BC Code) had failed to properly address their existence and their properties. However this is about to change.
At the moment, the BC Code distinguishes between Type A and Type B DRI. Type A DRI includes hot moulded briquettes or hot briquetted iron and are considered the less dangerous form. The carriage of these cargoes requires certain precautions, such as the regular measuring of cargo temperature and hydrogen and oxygen levels; cargo holds must be sealed. Type B DRI,which includes lumps, pellets and cold moulded briquettes, is considered more dangerous and must be carried under a blanket of inert gas.
Both Type A and Type B products are required to contain less than 5% fines (Fines are pieces with an average size of less than 6.35 mm). To date, the difficulty has been that there is no categorisation for cargoes of fines themselves. This will change with the introduction of new schedules in the BC Code during 2009, where DRI by-products and fines are defined and categorised within the BC Code schedule as ‘Type C’.
Carriage of Type C DRI will be governed by the same stringent safety requirements that apply to Type B DRI which mandates carriage under inert gas.
It should also be noted that there remains a limit of 5% fines for both Type A and B DRI. If this is exceeded or if there is doubt, the carriage requirements for Type B DRI should be followed. These new requirements for the carriage of DRI fines will be only recommendations until January 2011; thereafter they will become mandatory.
Although currently not mandatory, it is of vital importance that Members asked to carry DRI fines (also variously described as:HBI fines, Metallic HBI fines, Iron Remet fines, etc) implement the recommendations in full, in view of the record of catastrophes associated with the carriage of these cargoes.
Loading Iron Ore Fines at New Mangalore in the monsoon season
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1 Iron ore exposed to rain prior to loading. |
Much has been previously printed in Risk Watch about the risk of liquefaction in cargoes of mineral ore with high moisture content. A Britannia Member was recently in heated dispute for refusing to load iron ore fines at New Mangalore port. Concerned about the danger from high moisture levels, the Member asked for the assistance of the Managers and local surveyors were instructed to assist. Heavy rain at that time of year meant that the cargo, which was stock-piled outdoors,was surrounded by flood waters to a depth of 40cm. Surveyors appointed by Britannia's correspondent commenced a very thorough sampling in accordance with the IMO BC Code 2004. The dispute arose when the shippers insisted that as only cargo from more than 1 metre above ground level would be loaded, sampling should only be from 1 metre above ground level. Sampling recommenced in accordance with the BC Code and the samples, each representing no more than 250MT of the stockpile, were sent to a laboratory in Chennai for testing. This established that much of the cargo had dangerously high moisture and would almost certainly liquefy in the ship's holds resulting in loss of stability. Considerable pressure was put on the Master to load this cargo, despite the evidence of ‘can tests’ and the laboratory results from Chennai. With the support of cargo experts and legal advisers based in London, the Master, surveyor, and Owners continued to resist the pressure to put commercial considerations ahead of the safety of the ship. The refusal to load from the wet stockpiles was completely vindicated by the misfortune of another ship, the MV ASIAN FOREST, which departed with a full load of the same cargo from the same port whilst Members were in the process of refusing to load the cargo. The ASIAN FOREST sank, it is thought, having suffered a catastrophic loss of stability. The MV BLACK FOREST sank under similar circumstances a few weeks later. It is vitally important that Masters receive the full details of bulk mineral ore cargoes in advance of the commencement of loading. Can tests should also be undertaken whenever the suitability of the cargo for carriage is in doubt. The services of the local correspondent and surveyor should be engaged so that the relevant specifications of the cargo to be loaded can be compared with the BC Code. The ‘can test’ should be conducted at every relevant opportunity. Stop press |
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2 Area of wet cargo in the ship's hold, water having drained out of the cargo. |
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3 Sampling in ship's hold. Note the splatter marks on the bulkhead. |
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4 Area of cargo at the top of the stow in hold no.1. Note where the grab has smoothed the wet cargo, this phenomenon can only occur with wet iron ore. |
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5 Sample shown after being banged on a hard surface. Free water is visible in the flattened surface indicating a flow state has been achieved. |
The Bulletin can be viewed on the Association’s website at;
| http://www.britanniapandi.com/download.cfm/docid/B403D240-2D61-48D6-840701C92B77DAF1 |
Crew matters
Master’s attempts to placate stowaways backfires
Stowaways are extremely disruptive to the operation of a ship. When discovered it is necessary for the crew to ensure that they are kept in secure accommodation, so as to prevent their escape.
This can be a problem when there is one stowaway, but when there are eight, who are intent on being uncooperative, the problem can be immense.
In one particular case eight Sierra Leoneans were found hiding in the void space above the ship’s rudder. They had boarded the ship in Freetown and the next port of call was in Nigeria. Many stowaways are repeat offenders and therefore know what to expect when on the ship and are aware when efforts are being made to disembark them. It is quite common for stowaways to demand ‘pocket money’ in exchange for their cooperation. In this case, the ringleader demanded a substantial sum of cash for each of the stowaways to guarantee they would not be difficult when it came to their repatriation. Regrettably, the Master told the stowaways that they would be given some money and would be flown home.
It is the case that stowaways are often given small amounts of cash for incidental travelling expenses but the amounts promised by the Master were much greater than normal. When it came to arranging the repatriation of the stowaways, they were insistent that they should receive what had been promised to them.
Unfortunately the situation became more stressful when the stowaways learned that they were not to be flown home but were to be subject to an uncomfortable three day drive back to Sierra Leone. Eventually, they were persuaded to reduce their expectations and the repatriation of the stowaways was arranged.
The moral of this story is that no matter how difficult stowaways prove to be while on board, promises should never be made. We rely very heavily on our network of correspondents to arrange the prompt disembarkation and repatriation of stowaways and this can be unnecessarily complicated when undertakings are given,without first checking with the Managers, or our local correspondents. In this case, the stowaways were repatriated, but the costs incurred were far greater than they would have been had promises not been made.
Fishing from the dock proves to be expensive
The Association recently received advice from our Corpus Christi, Texas, correspondent that US Customs and Border Protection (CBP) had imposed a fine of US $9,900 on a ship, ‘for failure to detain an alien if ordered to do so by a CBP Officer.’
The ship had arrived at the port and the CBP had refused the crew permission to go ashore, because they were considered to be aliens pursuant to the US Immigration and Nationality Act. Three crew members subsequently were found fishing from the dock beside the ship and the CBP considered this to constitute a breach of the Act.
In another case reported to the Association, a ship was fined when the Chief Officer left his ship to use a nearby telephone to call home.
It should be noted that the CBP take contraventions of the legislation very seriously , no matter how apparently trivial they may appear. Therefore, appropriate precautions should be taken if shore leave is restricted by the local authorities, whether in the United States or other jurisdiction.
Navigation and seamanship
Six miles of unlit danger
Navigators may rarely encounter survey vessels towing arrays of seismic equipment but the Association has in recent years had experience of three incidents which gave rise to considerable damages.
This experience, together with the recent publication of a law report concerning a claim in excess of US$20m against a ship that made contact with a seismic tow array, perhaps evidences a pattern of deficiencies in the manner in which survey vessels operate. These deficiencies may come as a surprise to many mariners but navigators would be wise to make allowances for these deficiencies when sailing in the region of survey vessels.
In the first example, our vessel was navigating at night in conditions of good visibility and fair weather. The third mate was on navigation watch when he received a call on channel 16 from a vessel informing him that she was engaged in survey operations and requesting a CPA of 6.5 miles.The third mate had acquired the vessel on ARPA and had properly identified it using AIS. He was assisted on the bridge by an AB and a good visual lookout was being maintained. Our vessel was on an approximately south-easterly course and observed the towing vessel fine on the starboard bow at 16 miles range, on an approximately northerly course, passing ahead of our vessel. Our vessel did not alter course immediately but after another short VHF conversation with the survey vessel – when 12 miles apart – altered course slightly to starboard to ensure a CPA of 6.5 miles. Shortly afterwards a flashing light was observed 4 points off the starboard bow, 4 miles distant. The third officer thought this might be a small fishing vessel. Another vessel was also observed by radar immediately astern of the survey vessel. The survey vessel eventually passed clear to port at a distance of 6.5 miles and the flashing white light was observed thereafter to pass astern. Subsequently an allegation was made that our vessel had cut across the seismic towing line and that significant damage had been suffered by that equipment.
The exact content of the VHF exchanges with the survey vessel was the subject of dispute but it was argued by the opponents that they had clearly identified the vessel slightly astern of them as being the actual towing vessel (their vessel in fact being a leading, guard vessel) and that their request to remain 6.5 miles clear was in respect of this vessel astern of them and not their own vessel. It was asserted that the actual towing vessel had a working AIS which clearly identified it as the towing vessel. Our Third officer consistently denied that he had received any AIS data from the actual towing vessel.
In cases where VHF exchanges between the vessels form a significant part of the circumstances giving rise to the collision, there can be a tendency to concentrate on the exact content of the exchanges and not to give due weight to other factors of the collision. Indeed a return to the basic principles of collision avoidance as dictated by the Collision Regulations is necessary. In that regard a useful starting point will be consideration of the lights being displayed by the respective vessels. Our vessel was a large tanker displaying standard side lights and two mast heads. Opponents asserted that they were displaying, in addition to towing lights, the `vessel restricted in manoeuvrability’ lights i.e. three ‘all-round’ lights, the highest and lowest being red, the middle white. Despite the tow itself being in excess of 5.5 nautical miles in length, only a buoy immediately astern of the towing vessel, and the buoy placed at the end of the tow,were lit. It might be expected by navigators that such a tow would be subject to Rule 24(g)(iii) of the Collision Regulations as the tow was inconspicuous, partly submerged and in excess of 100 metres in length. As such it should be lit by ‘all round’ lights not more than 100 metres apart. However and unfortunately, the ColRegs, Rule 24(h) provides that such lights do not have to be carried where it would be ‘impracticable’ to exhibit those lights. No such lights were shown in this instance. The UK Maritime and Coastguard Agency (UKMCA) has issued a Marine Guidance Note (MGN 168) on the marking of seismic tow arrays. This recommends that the tail buoy should display an ‘all round’ high intensity white light flashing the Morse signal U – ‘you are running into danger’. In this case the towing vessel admitted that the flashing white tail buoy was not flashing Morse Code ‘U’.
Navigators would normally expect to receive a series of warnings concerning the activities of survey vessels. Normal procedure is for the survey vessel or the guard boat to issue regular navigational warnings on VHF. In this case this was not done. The surveying vessel should also have ensured that navigational warnings were issued detailing their activities. Although the survey vessel did make submissions to the coastal states for such notices to be issued they failed to ensure that the notices were being promulgated. No Navtex warnings were issued.
Whilst the deficiencies in the operation of the survey vessel were many and varied, it is useful to scrutinise the conduct of our own watch keeping; reliance upon one source of information is not sufficient. There may have been a lack of clarity in the instructions given by the `survey’ vessel (subsequently clarified to be the guard vessel) and there may have been understandable confusion if the actual towing vessel failed to transmit her AIS, but the watch officer could nevertheless have attempted to verify the position of the towed seismic array visually. He could also have enquired of the guard vessel the actual length of the towed seismic array and made his own decision whether a 6.5 mile CPA was sufficient for a tow of 5.6 miles. A question remains whether the third officer was keeping a sufficiently careful radar watch – should he not have been concerned about the existence of what turned out to be the guard vessel and the towing vessel in close proximity to each other? In defence of the Third Officer, it should be noted that the survey vessel had recently turned on to a new survey run, so the possibility exists that the tail buoy was, at the relevant time, still moving in a direction of the survey vessels’ original course and not on the new course. In such circumstances even careful radar observation of the tail buoy by the third officer may not have provided any clue that it was in fact the tail buoy and not a fishing vessel as originally thought.
The second incident occurred off the Nile Delta in daylight in good conditions of visibility. Again several VHF discussions had taken place between the survey vessel and our watch keeper. The need to pass at least 1nm astern had been communicated but the watch keeper had failed to appreciate the reasons why and decided to use his own discretion - believing that a lesser CPA would suffice.
The survey vessel relied upon the fact that the details of the one-mile tow were broadcast by AIS but appeared to be ignorant of the possibility that our vessels’ AIS might not be integrated with the radar, and that even if it was, the data relating to the tow would not be shown unless the target was ‘interrogated’. The AIS text itself was deficient in that it did not refer to the tow being on the surface. Indeed Marine Guidance Note 277 states that collision avoidance must be undertaken in accordance with the Collision Regulations and warns mariners against taking action based on information broadcast over AIS. MGN 277 notes that ARPA information is more accurate so there should be no need to interrogate the AIS data. There were no buoys in place along the length of the tow, only a small tail buoy,which the watch keeper failed to observe.
Again it appears that the NavigationWarnings were deficient in that they made no reference to a towed array,merely to survey operations and the area in which the survey would be carried out. The incident occurred outside this area as the survey vessel was turning and lining up her run into the survey `box’.
The third incident reveals considerable concerns about the competence and experience of the navigators on board seismic survey vessels. In this incident the `con’of the bridge had been passed down to the survey team who were operating from a different part of the vessel. The vessel was being steered by an unlicensed technician. A split in function therefore existed between the bridge watch keepers and the survey team. It is assumed that the bridge team remained responsible for safe navigation.
In all three incidents the watch keeper of the survey vessels took little or no action, preferring to rely on their survey departments and their guard vessels. Other common factors include; no intermediate lights/buoys at 100m intervals; small and ineffectual tail buoys/lights which were not flashing `u’; inadequate and unclear navigational warnings and an unjustified reliance on VHF conversations. The level of English of both survey and colliding vessels was not conducive to the successful communication of the full nature and description of the tows.
The use of guard vessels appears to be of limited benefit in collision avoidance; usually stationed forward of the towing survey vessel, their priority seems to be to warn-off vessels, allowing the survey vessel to maintain her course. Rarely, it seems, are guard vessels stationed astern to address the obvious risk from an overtaking vessel (survey vessels commonly steam at about 4 knots) crossing the towed arrays.
Whilst the operation of survey vessels towing seismic arrays is open to criticism it should be emphasised that where such vessels properly show `towing’ and `restricted manoeuvring’ lights or shapes, they will receive the priority mandated in the Collision Regulations (Rule 18).
The recent Court decision in WESTERN NEPTUNE v PHILADELPHIA EXPRESS excuses the failure to use intermediate (100m) buoys/lights along the length of the tows. This is most unfortunate given the apparent lack of effective action on the part of some towing survey vessels to draw attention to the danger presented by unlit, towed arrays, some of which can be up to 7nm in length.
Apparent increase in damage to shore cranes
The Managers are concerned at the apparent increase in damage to shore gantry cranes at container terminals caused by contact by ships.
It is the norm that when large container vessels are berthing, they are ‘pushed’on to the berth only when lying parallel, or near parallel, to the berth so that no opportunity for the bow flare to overhang the quay-side arises. Pilots however are not always fully aware of the peculiarities of ship bow design , and, if complacent about the angle of the ship to the berth, the bow can cause considerable damage to shore gantries, despite only minor contact.
Comprehensive exchange of information between the Master and the pilot, especially the completion of the pilot card, is important. The Master should draw the pilot’s particular attention to the specific characteristics of the ship, for example, the flare of the bow. This is important as it will alert the pilot to the inherent dangers of approaching the berth at an acute angle. On his part, the Master should ask the pilot whether the gantry cranes are parked in the correct – safe - position, and whether loading arms are fully luffed. The pilot should be able to tell the Master where cranes are actually positioned, if not in‘safe’position, before the berthing operation commences.
Beware! It is not unknown for cranes to be in the wrong place. Masters need to check visually for themselves that cranes are where the pilot has reported them to be.
Engine room flooded
The Australian Transport Safety Bureau (ATSB) has issued a report into an incident where the engine room of the geared bulk carrier MV GREAT MAJESTY, was flooded whilst alongside in Port Kembla, New SouthWales.
Whilst alongside with the No. 2 Water Ballast Pump under repair, the Chief Officer remotely opened two ballast valves to fill No. 1 Water Ballast Tank. About 390 m³ of seawater entered the engine room activating the engine room bilge alarm. The inflow of water was stopped immediately after the alarm was sounded, but a total of 22 electric motors located on the lower levels of the engine room were damaged by the ingress of sea water.
The vessel has ten double-bottom, one afterpeak and one fore-peak water ballast tanks. All are connected to a ‘ring main’ ballast piping system. The ship has two centrifugal main water ballast pumps, each driven by an electric motor. The bore of the suction and discharge pipes of theWBP’s is 350 mm. These water ballast pumps are connected to the engine room main seawater line through valves BA-15 and BA-18 (see diagram). Ballast operations can be conducted from the ballast control room located in the ship’s office on the main deck.
Due to ongoing problems with both the ballast pumps, a maintenance schedule had been agreed for the vessel by which the No. 2 Water Ballast Pump was dismantled, while the status of No. 1 Water Ballast Pump was confirmed as fully operational. The Chief Engineer had informed the Chief Officer that the No. 2 Water Ballast Pump was ‘stripped and blanked off’.
The vessel had a mixed nationality crew at the time of the incident that comprised of; 15 Bangladeshi, six Chinese and two Indian nationals. The Master held a Master’s COC from UK (issued in 2005), the Chief Mate had a Master’s COC issued in Bangladesh and the Chief Engineer held a Hong Kong Licence that was based on a Chinese class-one COC.
As soon as the shore crane started to discharge the cargo from No. 1 cargo hold, the Chief Officer decided to ballast No. 1 WBTK. To this end, he opened valve BA-15 and BA-16 to connect the main sea water line to the ballast ring main. The flooding started immediately thereafter triggering the bilge alarm; the Chief Engineer asked the Chief Officer to stop ballasting immediately.
The Chief Officer could have used valves BA-17 and BA-18 instead of valves BA-15 and BA-16 to fill the ballast tanks by gravity, had he been aware that No. 2 Water Ballast Pump suction side (that is connected to BA-15 valve) was not blanked off. Only the discharge side of No. 2 Water Ballast Pump was blanked off, thus the remotely controlled BA-15 valve was the only separation between the engine room and the sea. Further, the Chief Engineer had not isolated the remotely controlled valves on either side of the pump.
This incident highlights the need for Ship Management System procedures to address the issue of readiness of ballast pumps for ballast operations so that the Chief Officer can establish whether the ballast pump can be used in circumstances where repairs are being carried out. In this case a no work permit form was completed for the maintenance work. Indeed the investigation revealed that it was usual on board the vessel to carry out repairs without completing work permit forms. No notice was placed by the ballast valve remote control panel to warn officers not to operate No. 2 Water Ballast Pump.
This incident also highlighted that in a mixed nationality crew, the problem of effective communication in English still persists. Both the Master and Chief Officer had difficulty understanding the Chief Engineer’s spoken English. It was recommended by the ATSB that ‘closed loop’ communications should be practiced on board the vessel. Closed loop communication can be either verbal or written and involves the initial sending of a message, the receiving, understanding and acknowledging of the meaning of the message; and follow-up confirmation about the accuracy of the information. This style of communication serves to reduce the likelihood of error and to improve safety for any work onboard.
The full ATSB report is available at:
| http://www.atsb.gov.au/publications/investigation_reports/2008/mair/257-mo-2008-009.aspx |
Regulatory update
Mis-reporting of lube oil leaves vessel at themercy of local customs
One of the Association’s Members recently found themselves exposed to the full power of Customs officials in Dakar after the vessel entered port with incorrect lube oil ROB figures.
The error arose in part when the lube oil carried on board in bulk was declared as carried in drums. Additionally, the cylinder lube oil had been omitted from the calculations.
Customs officials boarded the vessel and ordered the Chief Officer to count all the drums in the engine room and provide a calculation of bunkers/lube oil on board. It was then that an excess of bulk lube oil and a shortage of lube oil in drums was discovered. The Customs official imposed a fine of EUR 580,000, confiscated the Master’s passport and refused to allow the vessel to leave port until the matter was resolved.
After a great deal of negotiation, the local correspondent was able to reduce the fine to around EUR 57,000 – still a large sum of money for what was a simple error in reporting.
The local correspondent stressed that the reduction in the fine was highly unusual, as Dakar is in great financial difficulties and that this type of fine is seen as an important source of revenue.
Particular vigilance in reporting to Dakar Customs is clearly necessary.
Miscellaneous
Publications
The Nautical Institute has just published a two-volume guide to mooring and anchoring. According to a recent survey,mooring accidents in the last 20 years have cost around US$34 million,making it the seventh highest cause of injuries and often involving death or serious injury.
The new practical guide which is entitled ‘Mooring and Anchoring Ships’ is the result of an industry-wide investigation and is supported by the International Maritime Organisation and also by the International Chamber of Shipping.
The first volume is written by Ian Clark and outlines the theory and practice of mooring and anchoring. The second volume, by Walter Vervloesum, covers inspection and maintenance procedures for the mooring equipment.
For further information and to order copies of the two volumes, please go to the Nautical Institute website:
| http://www.nautinst.org/en/Publications/index.cfm |
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
