Volume 12: Number 2: June 2005

Increased evidence of structural failure of mooring equipment

Earlier this year, during a berthing operation, a Member's ship experienced structural failure of the poop deck plating in way of two panama fairleads.The ship was a two year old Korean built loaded Aframax tanker which, under pilotage at the time,was manoeuvring to berth port side alongside her discharge berth in the USA.The ship had secured a harbour tug with a 45 - 50 tonnes bollard pull on the starboard quarter utilising the tug's 62mm wire tow line led through a 40 tonne SWL panama fairlead with the tow line eye dropped over the mooring bit.

As the ship closed alongside the berth the tug aft was requested to hold off the stern and applied weight to the towline. Evidence from the incident suggests that when the tug applied power there appeared to be no sudden or shock loading and the towline did not part. Two panama fairleads were pulled out as the deck plating to which they were attached failed completely. It was indeed fortunate that in this incident no injuries or fatalities resulted.

From the investigation and photographic evidence it appears that neither the effects of corrosion nor potential weld defects were contributory causes of the failure on what is a relatively new ship. It was the deck plating itself which was torn up together with the panama fairleads and hand railing.

The Association has become aware of mounting concerns within the industry at large regarding the apparent increase in mooring equipment failures. The Nautical Institute, in their March 2003 edition of Seaways, has called for feedback from seafarers to help define the needs and strengths for fittings and for towing and mooring operations in both normal and emergency situations. In addition, some of the oil major vetting organisations have been taking more than a passing interest in this issue and actively considering the safe working loads for mooring arrangements on ships for prospective charter.

During discussions with the Member's classification society - a member of IACS - it emerged that, historically, the mooring arrangements on ships appear not to have fallen under standard classification society rules (anchors and cables excepted).

In the light of recent incidents involving mooring equipment failures, IACS have recently developed new classification society rules, termed UR-A2,which introduce requirements for mooring and towing fittings and the respective hull strengthening for ships greater than 500 gt applicable to new ships contracted after 1 January 2005.

Following approaches from some Korean and Japanese ship builders the IMO are also currently developing a new set of requirements.This IMO initiative is presently being considered by the Design and Equipment sub committee as 'Proposal DE 48' and appears identical to the IACS rule requirements, but with the design loads reduced by 37.5%. DE 48 is likely to be approved during the next IMO MSC session in May 2005 and it is the classification societies' understanding that the new requirement will be incorporated in the IMO SOLAS Regulations.

With both UR-A2 and DE 48 there appears to be neither retroactive application of the rules nor any plans to address the design, construction, strength and suitability of existing arrangements on vessels which have already been built.

Given the increasing concerns regarding existing mooring arrangements on recently built tonnage and examples of failures such as this one it is suggested that owners should give serious thought to the mooring arrangements on their ships, focusing on the deck/underdeck strength. In consultation with their classification societies it is suggested that owners should consider whether it is necessary to downgrade the existing SWL's/expected capabilities of existing mooring systems or voluntarily incorporate the new measures to upgrade to the new classification rules or IMO requirements.

Reliable mooring and towing arrangements form a key component for the safe operation of a ship, most often utilised and relied upon when the ship is manoeuvring in possibly confined waters, often surrounded by potential hazards and risks. It would take little imagination to envisage a range of potential scenarios in which a mooring component failure could give rise to a major incident with the potential for any combination of ship damage, berth damage, grounding, pollution and injuries or loss of life.

Masters will be required to comply with a specific sampling process and will need to obtain a bunker receipt containing certain details and a specific declaration from the supplier.

While fuel oil quality is now mainly a commercial matter between ship operators and suppliers, it will also become a statutory matter when Annex VI of Marpol 73/78 - Regulations for the Prevention of Air Pollution from Ships - enters into force on 19 May 2005. Marpol Annex VI, Regulation 18, specifically requires that fuel oil supplied to ships must be free from inorganic acids or chemical wastes that could; jeopardise the safety of the ship, harm ships' personnel, or contribute to additional air pollution. It is also a requirement that any fuel oil for combustion purposes delivered to and used onboard shall be recorded by means of a Bunker Delivery Note (BDN). This implies that a BDN shall be presented for every delivery and every grade. BDNs are required to contain all the following information:

• Name and IMO number of receiving ship;
• Bunkering port;
• Date of commencement of bunkering;
• Name, address and telephone number of marine fuel oil supplier;
• Product name;
• Quantity (metric tonnes);
• Density at 15°C (kg/m3);
• Sulphur content (% m/m);
• A declaration signed by the fuel oil supplier's representative certifying that the fuel oil supplied complies with Regulation 14 (the fuel supplied has a sulphur level below 4.5%) and Regulation 18.

The BDNs are to be retained on board for a period of three years after the fuel oil has been delivered, readily available for inspection at all times.

Regulation 18 requires every BDN to be accompanied by a representative sample of the fuel oil delivered, taking into account the guidelines in Resolution MEPC.96(47).The sample is to be sealed and signed by the supplier's representative and the master or officer in charge of the bunker operation on completion of bunkering. Samples should be retained under the ship's control until the fuel oil is substantially consumed, but in any case for a period of not less than 12 months from the time of delivery.The ship's Master should develop and maintain a system to keep track of the retained samples. Further, Resolution MEPC.96(47) recommends that the seal number of the associated Marpol Annex VI fuel representative sample is included in the BDN for cross-reference purposes.

Resolution MEPC.96(47) further specifies that the Marpol fuel sample is to be obtained at the receiving ship's inlet bunker manifold and drawn continuously throughout the bunker delivery period. Sampling methods are clarified as manual valve-setting continuous-drip sampler, time-proportional automatic sampler, or as flow-proportional automatic sampler. The guidelines also specify that sample bottle labels are to contain the following information:

• Location at which, and the method by which, the sample was drawn;
• Date of commencement of delivery;
• Name of bunker tanker/bunker installation;
• Name and IMO number of the receiving ship;
• Signatures and names of the supplier's representative and the ship's representative;
• Details of the seal identification;
• Bunker grade.

The retained samples are to be kept in a safe storage location, outside the ship's accommodation and where personnel would not be exposed to vapours which may be released from the samples. Further, the sample should be stored in a sheltered location where it will not be subject to elevated temperatures.

On tankers, the cargo sample locker would be considered an adequate storage space. Alternatively, a suitable locker (with opening ensuring adequate air flow) in an adequately ventilated area of the engine room located at a safe distance from ignition sources and hot surfaces may be considered.

Marpol Annex VI also contains instruments to encourage port states to ensure that bunker suppliers fulfil their obligations. Port states must:

• Maintain a register of local suppliers of fuel oil;
• Ensure local suppliers provide the BDN and sample, certified by the fuel oil supplier that the fuel oil meets the requirements of Regulations 14 and 18;
• Require local suppliers to retain a copy of the BDN for at least three years for inspection and verification by the port state as necessary;
• Take action as appropriate against fuel oil suppliers that have been found to deliver fuel oil that does not comply with that stated on the BDN;
• Inform the flag administration of any ship receiving fuel oil found to be non-compliant with the requirements of Regulations 14 or 18;
• Inform IMO for transmission to Parties to the Protocol of 1997 of all cases where fuel oil suppliers have failed to meet the requirements specified in Regulations 14 or 18.

In order to assist ships in ensuring that the operational requirements are met, it is recommended to include clauses regarding compliance with Marpol Annex VI Regulations 14 and 18 in bunker contracts and agreements with suppliers, as well as in charter parties.

Intertanko has produced 'A Guide to Bunkering of Ships for the purposes of Annex VI to Marpol' to assist ship operators in developing onboard procedures to ensure compliance with Marpol Annex VI. Copies can be ordered at www.intertanko.com/publications.

Although it may be impractical to find all stowaways, there are some things that can be done to reduce US Coast Guard criticism and fines.

The Association is aware of several recent incidents where stowaways have been hidden inside containers in China bound for the USA. Before the container is loaded onboard, a section of the container side panel is cut out to allow access for the stowaways.The panel is then welded or bolted back in to position to conceal the fact that it has been tampered with. On arrival at the port of destination, the stowaways are able to kick out the section of panel or remove the retaining bolts.

The US Customs and Border Protection Bureau take all stowaway incidents very seriously and in one recent case where this technique was used, the containership operator involved had their CT-PAT participation suspended by the US authorities as a consequence. Members should be aware that the customs authorities, in the first instance, will hold the shipowner responsible even if the container belongs to a slot charterer.

Where stowaways are found in containers the severity of action taken against the shipowners by the US authorities will be moderated to a certain extent where it can be shown that the shipowner took steps to prevent the stowaways gaining access to the ship. The Association is advised by correspondents in the USA that the following actions/precautions taken by the shipowner might decrease any penalty imposed against the shipowner;

• Are there any checks made when there is a major discrepancy between the weight of the container on the bill of lading and the actual weight when the container enters the terminal in the loadport?
• Are there any procedures in place to check carbon dioxide levels inside the container? (increased carbon dioxide levels would indicate the presence of stowaways)
• Are any efforts being made to check whether containers with patches big enough to allow humans to enter or exit the container actually contain stowaways?
• Has there been any communication between the shipowner and/or the slot charterers with the authorities at the loadport to identify and intercept suspicious containers?