Volume 14: Number 4: October 2007

CONTAINERS AND CARGOES

Stow collapse raises the possibility of a new industry code of best practice

The collapse of a relatively small stack of containers onboard the MV ANNABELLA lead investigating officials to identify serious deficiencies in both the shoreside and ship stowage planning procedures.

When combined with concerns about previous incidents of stow collapse, this resulted in the UK authorities suggesting that the time is right for the construction of a new code of best practice for stowage planning of container vessels.

The detailed report drawn up by the UK Marine Accident Investigation Branch (MAIB) into the ANNABELLA incident identifies faults with stowage planning procedures that are familiar to the Association. The MAIB has hinted that their on-going investigation into the MSC NAPOLI incident is also likely to reveal deficiencies in this area which may need to be addressed by the industry. The MAIB report also provides ships’ officers and stowage planners with a useful reminder of the many factors which can give rise to the collapse of a stow.

The ANNABELLA was transiting the Baltic Sea when, on the morning of 26 February, the crew discovered a collapse of 7 x 30’ containers in bay 12 of #3 hold. During the previous night the Master had altered course and reduced speed in order to reduce the effect of heavy weather (Beaufort force 7/8). The stack had collapsed into the forward part of the hold; the lower containers being partially crushed, the upper containers not suffering significant damage. Rather worryingly these upper containers were tank containers fully loaded with butylene gas (IMDG Class 2.1). Later that day, on arrival at Helsinki, the Harbour Master decided that because of the proximity of populated areas to the port, it would be unsafe for the vessel to berth and attempt to discharge the damaged hazardous cargo containers at Helsinki. The vessel was ordered to Kotka. At Kotka a 400 metre restriction zone was established around the vessel when it berthed at the container terminal and salvage experts were engaged to advise on a discharge plan. After ascertaining that there was no hazardous gas leaking into #3 cargo hold, the containers were successfully discharged. Apart from the inconvenience and costs of being diverted to Kotka, the consequences of the collapse of stow were relatively minimal compared to many of the incidents of collapsed stows with which the Association has dealt. Indeed, the potentially disastrous consequences had the cargo of butylene leaked and then ignited can be imagined. Despite the minimal consequences, the MAIB investigated the circumstances of the collapse in a comprehensive and detailed manner.

The stack of 7 x 30’ containers in the centre of bay 12, hold #3 were loaded at the ‘ECT’ terminal in Rotterdam, below deck. As 30’ containers are considered ‘irregular’, the lashing and securing manual provided that lashing bars should be applied to their forward end. Unfortunately, no such lashing bars were applied. Further, the total weight of the seven containers was found to be 225 tonnes, whereas the cargo securing manual indicated the maximum permissible stack weight for 30’ containers loaded in this location was 150 tonnes. Furthermore the lower four containers in the stack only had a maximum allowable stack weight of 100 tonnes i.e. were not built to ISO Standards.

As is often the case, stowage planning was undertaken ashore; on this occasion by charterers’ stowage planners. Importantly, although the planners were aware of ANNABELLA’s stowage capabilities and also held some details of her stability, they ultimately relied on the ship’s staff to alert them to any errors in the stowage plan and expected the Chief Officer to check every aspect of the stowage plan before the vessel began loading. The shoreside planners were aware of previous incidents involving ships of the same class, where their plans to load 30’ containers exceeded the allowable stack weights. In these cases the planners had been alerted to the problem by the ship’s staff, and suitably amended plans agreed. Despite this, the planners failed to review their planning procedures for this type of vessel when loading these 30’ containers and continued to rely on the ship’s Chief Officer to check the stowage plan. In any event the shoreside stowage planners’ software seems to have had difficulty dealing with the in-put of 30’ containers and defaulted to 40’ containers when analysing the maximum permissible stack weight. This resulted in an incorrect maximum allowable stack weight of 240 tonnes in hold #3. Accordingly the subject stack, at 225 tonnes, triggered no alarms. The MAIB noted that the software used by the charterers for planning purposes was not the same as that onboard the vessel and that there is no requirement for the planners’ programme to be checked or approved by an external authority.

The vessel received the proposed stowage plan by email at 1200 hrs on 22 February, some 6 hours before berthing and commencement of loading operations. The Chief Officer checked that the stow plan was acceptable in terms of bending and sheer stresses, hazardous cargo distribution and the requirements of the vessel’s cargo securing manual. However the software onboard the ship only checked cargo securing arrangements for containers stowed above deck. Further, although the software had an alarm function designed to operate if individual stack weights were exceeded, the software had not been correctly programmed to recognise 30’ containers and did not alarm when the weight of the stack of 7 x 30’ containers was in-put.

The ship’s software (lashing and securing module) had not been approved by a Classification Society. The ship’s cargo securing manual had been approved and did contain lashing arrangements and specific stack weights for 30’ containers. Details of these lashing arrangements for 30’ containers were located in an annex to the manual but the annex was not referred to in a list of reference documents in the introduction of the cargo securing manual. The implication being that it was not easy to locate. The general lashing plan shown in the manual was also permanently displayed on the cargo office wall and clearly indicated that the maximum stack weight on the tank top was 150 tonnes and not 240 tonnes. (Based on a maximum GM of 0.8m).This plan was not referred to by the Chief Officer. Unfortunately, the lowest 4 of the 30’ containers in the collapsed stack were themselves not capable of supporting a stack weight of 150 tonnes. According to their CSC rating they were limited to a stack weight of 100.5 tonnes.

It appears therefore that the stack not only failed to comply with the correct 30’ container 150 tonnes limit as per the approved lashing and securing manual but that this limit was in fact not appropriate because the vessel’s GM was actually 1.8m. The stow was additionally flawed because the stack limit was based on ISO standard containers and ISO Standard containers were not loaded.

The failings of the Chief Officer are perhaps obvious in that he failed to refer to the detailed annexes of the cargo securing manual to establish proper stowage of the 30’ containers. He also seemed oblivious to the effect of GM on lashing and securing arrangements, i.e. as a factor affecting the applicability of the cargo securing manual itself. However the MAIB have thoughtfully gone beyond the omissions of the Chief Officer and identified the failings of the operations and processes involved.

Among the prime factors relating to the casualty was the insufficient spare time allowed for the Chief Officer to become fully conversant with the full details of the vessel’s cargo securing manual and its many annexes before he took over as Chief Officer. Further, the integrated container and lashing module of the ship’s software was not Class approved; the approval process would no doubt have identified and eliminated the programming error which ‘converted’ 30’ container to 40’. The fact that the lashing and securing manual was only applicable to a GM of 0.8 meant that the Chief Officer did not have available to him the requisite reductions in allowable stack weights and enhanced securing requirements when sailing with a GM greater than 0.8m. (For operational reasons, this vessel was required regularly to sail with GM in excess of 0.8m).

The MAIB report went on to identify deficiencies in the shoreside procedures. Namely, that the charterers’ loading computer system had not been independently examined and that this contributed to the programming errors not being detected. Further, that the cargo planners had no access to detailed information of the ANNABELLA’s cargo securing manual and accordingly the operational restrictions contained in these documents were not taken into account during the planning process. These deficiencies have to be considered in the context of the speed of operations which meant that the Chief Officer is unlikely to have the necessary influence to stop or slow the operation while he makes a detailed check of all aspects of the stow plan or individual containers. Without such a check it is inevitable that errors made during the planning loading process will be undetected.

It is perhaps this latter issue which needs to be emphasised. If the Chief Officer does not have the time nor influence to affect the stow then the deficiencies of the shoreside stowage planning process become critical.

One causative factor over which neither the Chief Officer nor the shoreside stowage planners could have exercised their influence was the lack of a method of identifying containers which are non-ISO standard.

In addition to the recommendations to the ship managers and charterers of the vessel, the MAIB are so concerned at what appears to be a pattern of incidents involving the loss of containers overboard that they have seen fit to recommend to the International Chamber of Shipping that the industry develops, promotes and adheres to a best practice safety code. This would ensure ships’ staff had the resources and opportunity to safely oversee the loading and securing of cargo and that either cargo securing manuals are in a format which provides ready and easy access to all relevant cargo loading and securing information or, loading computer programmes - both shipboard and shoreside - incorporate the full requirements of a vessel’s cargo securing manual and are properly approved so that officers can place full reliance on the information provided. The MAIB went on to suggest that the availability or otherwise of a reliable, approved, loading computer programme should be a factor in determining appropriate levels of manning for vessels on intensive schedules.

The Association has little experience of the specific difficulties relating to 30’ containers illustrated in the above report but does have considerable experience of the fundamental deficiencies in stowage planning procedures which feature regularly in claims presented to the Association. Such claims tend to manifest themselves, not in the exceeding of stack weights, but rather in the inappropriate distribution of heavy containers within a particular stack, the result however is the same: collapse of stow. The report’s emphasis on the failure or inability to take in account GM’s higher than that provided in lashing and securing manuals is also a familiar factor in the incidents reported to the Association.

Styrene monomer
 

To those that specialise in the trade, it has been known for many years that great care should be taken if a ship that has previously carried a cargo of styrene monomer is offered for the carriage of sensitive cargoes such as edible oils/fats, methanol or other high purity chemical cargoes.

Styrene monomer is a colourless, oily liquid with a strong odour. Used in the manufacture of polystyrene, polyesters and various types of resin, it is one of the most frequently shipped chemical cargoes.

Styrene monomer is difficult to clean from tankers as it is prone to absorption into organically coated cargo tanks, particularly tanks coated with epoxy paint, from which it then desorbs naturally over time. For this reason, FOSFA (Federation of Oils, Seeds and Fats Associations) has banned the carriage of edible oils and fats intended for human and animal consumption in tanks where styrene monomer is amongst the last 3 cargoes carried. Many manufacturers of methanol also insist that their cargoes should not be carried in vessels that have carried styrene monomer previously. However, the growth of the methanol trade in recent years, particularly its rapid expansion in the Chinese market, which looks set to continue, has inevitably meant that a wider range of ship owners and charterers have become involved in the carriage of methanol. Not all such new entrants to the market have experience of the risks involved in carrying methanol or other high purity chemical cargoes where styrene monomer has been carried as a previous cargo. For this reason, we wish to bring to Members’ attention a recent case in which the Club was involved which illustrates the potential problems.

The case involved the carriage of chemical grade methanol from Indonesia to China. The ship’s centre tanks were made from or clad with stainless steel, while the wing tanks were coated with an epoxy-type paint. Amongst its previous two cargoes the ship had carried styrene monomer in both the stainless steel and epoxy coated tanks.

Prior to loading the methanol, the tanks were cleaned to the standard customarily required after carrying a cargo of styrene monomer. The cleaning method used was capable of removing all significant residues of the styrene monomer from the tank surfaces, pumps and lines. The ship was accepted by the load port surveyor and also passed a subsequent wall-wash survey and first-foot analysis. No residual odour of styrene monomer was noted at the load port.

Upon arrival at the discharge port, the methanol in the wing tanks (i.e. those coated with epoxy paint) was found to be contaminated. The methanol carried in the stainless steel centre tanks was, however, within specification.

An expert was appointed by the Club and concluded that styrene monomer present in the paint coatings of the wing tanks had desorbed during the voyage, contaminating the methanol. The expert’s view was that the tank cleaning appeared to have been carried out to the highest industry standards for cleaning styrene monomer but this was insufficient to prevent it from subsequently desorbing. Furthermore, styrene monomer residues in the tank coatings had not been detected by routine analyses carried out at the load port prior to the full cargo being loaded nor by smell.

In the expert’s view, the only way to remove styrene monomer that has been absorbed into tank paint coatings is to allow it to desorb naturally over a period of time. This could take months or even years. In this case the level of cargo contamination in the tanks where styrene monomer had been the last cargo was markedly greater than in the tanks where it had been the second last cargo, indicating natural desorption over time. Increasing the temperature of the tank surfaces, for example by loading hot liquid, will accelerate the rate of desorption and this may, therefore, reduce the time taken to achieve thorough cleaning.

In order to avoid claims, Members should avoid loading cargoes of methanol or other high purity chemical cargoes in tanks with epoxy paint coatings which have previously held styrene monomer unless they have expert confirmation that there is no longer a risk that the styrene monomer will desorb. Zinc-rich tank coatings also do not absorb styrene monomer residues but they are porous and can, therefore, to a certain degree, retain elements of previous cargoes. Although this problem is not insurmountable, it does make zinc-rich coatings more difficult to clean than stainless steel tanks. Ideally such sensitive cargoes should only be loaded in stainless steel tanks, which are easily cleaned and do not absorb styrene monomer.

REGULATORY UPDATE

Black sea: Grey water
 

Many owners are no doubt aware of the enthusiasm with which the authorities in the Black Sea levy fines and penalties on ships in their waters. We have recently been involved in a matter, which although not generating a significant fine, did have an unintended consequence.

In August this year, a container ship operated by one of the Association’s liner Members, called at Ilyichevsk. Upon arrival, it was alleged that the ship had allowed grey water to be discharged overboard and the local authorities notified their intention to investigate.

Following an onboard investigation, it was alleged that two valves on the vessel’s sewage system had not been closed properly and as a result, had led to an overboard discharge. This was considered to be a violation of MARPOL as well as a violation of local regulations and the authorities signalled their intention to levy a fine on the ship. The fine was assessed to be in the region of USD3,000 - USD3,500.

With the intervention of the Association’s local correspondent, it was established that the valves in question served the ship’s refrigeration and air conditioning systems and not the sewage system and that grey water from the ship’s sewage system was pumped directly into a sewage tank. This was communicated to the authorities and a further attendance on board was convened with the local authorities.

Although the local authorities were subsequently able to agree with the findings of the surveyor appointed by the Member unfortunately they were unable to locate the sewage tank on board, in spite of detailed ship’s plans. Under the circumstances, this was considered to be a violation of Ukrainian environmental legislation and it was decided to levy a fine on the ship!

In view of time constraints and that a continued discussion over the validity of the fine would have led to further delays to the ship, the decision was taken to settle the fine rather than incur additional costs.

It would seem that there is little that can be done to stop the local authorities from pursuing these matters with excessive enthusiasm. Members are reminded however to ensure that the local correspondent is contacted as a matter of urgency as soon as there is any indication from local authorities that attempts are being made to pursue an environmental fine against a ship for alleged discrepancies in MARPOL or local regulations.

New SOLAS regulation dictates the phased introduction of long range identification and tracking (LRIT)
 

A new regulation that is likely to enter into force on 1 January 2008 will introduce the requirement for the long range identification and tracking of ships (LRIT). Although there is a phased implementation programme ship owners will need to familiarise themselves with the new technical requirements and satisfy themselves that the GMDSS equipment on board their ships has the required capabilities as dictated by the new regulation.

The UK Maritime and Coastguard Agency will shortly be issuing a Marine Information Note.

NAVIGATION AND SEAMANSHIP

How good is the data on which your charts are based?
 

Most mariners are aware that there is great variation in the extent to which waters around the world have been surveyed.

Navigation Charts indicate the hydrographic surveys which relate to the charted area. A recent incident in UK waters has highlighted that it is not only the more remote coastal waters that have not been surveyed or charted by modern methods. Many of the developed littoral nations need to identify areas of their coast which have historically been ignored for the purpose of hydrographic survey as they might require attention by virtue of increased utilisation by various sectors of maritime industry.

The jack-up barge OCTOPUS was being towed from Kirkwall to Seal Skerry Bay in the Orkney Islands by the tug HARALD. The voyage was planned by the HARALD’s skipper using Admiralty paper charts. The echo sounder was running throughout the voyage although turbulence caused by the fast flowing tides resulted in the trace becoming illegible. Once clear of the approaches to Kirkwall the tug’s skipper lowered the barge legs from 5 metres to 9 metres in order to improve the OCTOPUS’s stability during anticipated swell when passing east of Shapinsay. The possibility existed of proceeding to the east of the Green Holm Islands but on approach the strong spring ebb tide appeared to set the tug and tow to the west which would set them towards Green Holm Island. Accordingly, a decision was made by the tug’s skipper, in conjunction with the tow master, to proceed west of Little Green Holm Island on a route which the chart indicated had a depth in excess of 20 metres. Again the barge legs were lowered, this time to 13 metres, to reduce expected rolling as they crossed the tidal flow to the north of the Falls of Warness. At 1755 hrs on 8 September 2006 the rig’s two forward legs grounded heavily in a position 3 cables south, south west of Little Green Holm Island. The nearest sounding indicated on the chart showed a depth of 26 metres. The OCTOPUS was refloated 40 minutes later and subsequent survey showed that all 4 legs were found to be damaged. Repair costs were in the region of USD2 million.

Following the grounding the area was immediately surveyed using modern methods which revealed a depth of 7.1 metres; as would be expected this amendment was the subject of a Notice to Mariners. A more general and significant lesson to be learnt is that many areas of the world have not been surveyed by modern methods, if at all. Changing patterns of usage - for example, the Shetland Isles is becoming increasingly utilised by cruise vessels and, as in this case, tidal/wave energy developers - means that navigators have to take particular note of the age and methodology of surveys upon which their charts are based. Had the passage planners for the OCTOPUS rig taken note of the source data shown on the chart, they would have perhaps been surprised to learn that the area was last surveyed by HMS MASTIFF in 1844 and that the methodology used was lead-line depth sounding. Further the BA chart carried the warning: ‘depths in these areas have not been systematically surveyed. Depths in these areas are from miscellaneous lines of passage sounding on old lead-line surveys. Un-charted dangers may exist’.

Mariners of course could and should also refer to the Admiralty Sailing Directions or pilot books to give warning of unreliable depths. Although those involved with the passage planning of the OCTOPUS could have been more aware of these factors, there was a significant amount of bad luck involved in the incident. The area had in fact been surveyed in early 2006 by a modern commercial survey vessel and changes to the charted depth were noted. Unfortunately the significant 7.1m shoal patch was not noted because the southern limit of the surveyed area stopped less than 200 metres north of the unknown 7.1 metre shoal. The full MAIB report is available on:

www.maib.gov.uk/cms_resources/Harold_Octopus.pdf

Although of little use navigationally, navigators may be interested to note that there is a summary report on the status of hydrographic surveys worldwide available at:

www.iho.shom.fr./PUBLICATIONS/S-55/S_55.htm

The table of geographic areas in the latter site gives a percentage of those areas which require re-survey on a larger scale or with modern techniques and those areas which have never been systematically surveyed. There are some surprising results. For example, 35% of USA waters are deemed to require re-survey at larger scales or to modern standards. The figure for Japan is 53%. The Orkney and Shetland Islands remain 65% unsurveyed. Only 1% of Vietnamese waters is deemed to have been adequately surveyed.

MISCELLANEOUS

Bunker delivery by tank truck in Nigeria - to be avoided
 

One of our Members suffered difficulties when required by charterers to take delivery of diesel by tank truck at Apapa in Nigeria. As soon as tank trucks began delivery from the jetty it became clear that the hoses used were in poor, if not unsafe, condition. Continual leakage occurred on the jetty throughout the delivery of what was supposed to be 240 M/Ts. Despite continual protest by the ship neither the charterers nor the bunker suppliers made any attempt to either clean up the spill or indeed stop the leakage. It was clear that to avoid delay and penalty from the local authorities the ship would have to undertake the clean up of the jetty despite neither causing the spill nor being able to prevent it. To add insult to injury the bunker suppliers threatened to detain the vessel should the vessel not agree that 250 M/Ts of diesel was delivered, whereas ship’s figures indicated that only 223.46 M/Ts were delivered. Correspondents (African Marine Services) advised that circumstances in Nigeria are such that the suppliers’ extortion would probably be supported by the courts or the Port Authorities should the supplier wish the vessel be detained. Correspondents advise that there is little that can be done to ameliorate such circumstances except to avoid bunkering alongside by tank truck and to persuade charterers not to do so.

USCG Alert on pneumatic pump maintenance
 

The US Coast Guard (USCG) has issued Marine Safety Alert 4-07 (http://www.uscg.mil/hq/g-m/moa/docs/ 4-07.pdf ) concerning a recent incident in which the crew experienced difficulty manually deploying the vessel’s life rafts from their mounting cradles.

The life rafts were fitted with individual Hammar Manual Remote Release System (MRRS) pneumatic vacuum pump units. When the pumps are manually operated a vacuum is quickly and easily created that actuates a corresponding Hammar H20 hydrostatic release unit. In this case a large number of the pumps failed to activate the hydrostatic release units as they had not been lubricated as required. In order to launch all of the vessel’s life rafts successfully the crew had to manually cut the life raft canister lashings.

The casualty investigation is not complete and additional recommendations are likely to follow. However, in the interim, the USCG strongly recommends that Hammar MRRS pneumatic pump units, as well as all other survival equipment, be maintained in accordance with the manufacturer’s recommended maintenance schedules.

Publications

Handy guide to SECAs and SOx

Messrs Shiptalk Legal Guides, in cooperation, with Clyde & Co law firm have produced a small booklet giving a simple outline of SECAs and SOx regulations. Copies are available from Clyde & Co (£10 each).

email: Andrew.preston@clydeco.com
email: Cris.partiridge@clydeco.com

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