In the AM's company, a daily 'Safety Share' on topical marine and port matters is circulated by our HSE Manager and this one caught my eye. The AM holds an Oil Tanker Endorsement for petroleum products and crude oil. Similar endorsements are issued for chemicals, LPG, LNG and Dynamic Positioning ships to name a few. The article's author, Chris Spencer, raises Dry cargo endorsements due to the growing complexity (or worse, ignorance) of the dangers inherent in bulk shipping.
|Bulk salt: UK P&I Club|
'Safety At Sea Magazine' Features, 6th Sep 2012
Bulker safety: Cargo competence
Incorrect documentation and lack of enforcement may not be the only reasons why liquefaction casualties continue. Chris Spencer explains why he feels it might be time for a dry cargo endorsement
The safety issue of the moment in the bulk carrier trade is cargo liquefaction, which has often been highlighted in SAS and by major industry associations such as Intercargo and the International Group of P&I Clubs (IG). The loss of three well-found ships along with the lives of 55 seafarers at the end of 2011 raised existing concerns to a higher level.
The recent IG requirement that owners notify their P&I insurer when loading nickel ore cargoes from ports in Indonesia and the Philippines adds weight to the assertion there is a continuing problem. Some observers have blamed malpractices by cargo interests for inaccurate documentation or lack of cargo analysis, while others point to inadequate local enforcement of regulations as being at the root of these incidents.
It is also true that some masters and operators of bulk carriers are ignorant of the dangers linked to carrying certain bulk cargoes. An analysis of the incidents in which ships have capsized or listed as a result of cargo liquefaction reveals some interesting trends. The paucity of the data draws attention to another difficulty with this phenomenon: a potential lack of transparency from the relevant flag states. Research into figures available from various sources, including Intercargo and flag state accident investigation reports, reveals that since 1999 cargo liquefaction has been responsible for the sinking, with loss of life, of at least 11 ships, yet only three of these incidents merited a flag state investigation report. The ships involved were of all sizes up to handymax bulk carriers; interestingly, all the ships were geared.
This fact should not in itself be unexpected, as the parcel size of the cargoes and the limitations of the load ports restrict the size of ships being used. Geared bulk carriers are built to provide flexibility to carry a range of cargoes including general, bagged, steel, project, timber and of course, bulk cargoes. These ships have become complex in their operation but the seafarers’ and owners’ knowledge of the carriage of these cargoes has not kept pace with this development.
The P&I clubs are asked daily for advice from owners on the carriage requirements and dangers of various dry bulk cargoes. It seems that cargo knowledge is deficient within some operations and chartering departments and also aboard their ships. This presents a real risk when, for example, chartering managers fix cargoes without knowing the hazards associated with them. This can put the master in a difficult position – should he or she continue to load the cargo that has been fixed when it may not be safe to do so? Chartering departments with appropriate cargo knowledge can consider using suitable charter party clauses to protect the owner and master. Many dry cargo operators do not provide the master with the proper guidance for carrying these diverse cargoes. An assessment of risk is an ISM requirement and the carriage of cargo presents a risk to the ship and its crew. Yet the risk cannot be assessed if the appropriate cargo knowledge is lacking on board.
Bulk carriers are often considered the ‘standard’ ship because they are the workhorses of the oceans. Seafarers sailing these ships need only attain the minimum certificates of competency necessary for going to sea. The time may well have come for officers on dry cargo ships to have a ‘dry cargo endorsement’. Cargo-handling officers aboard oil, chemical and gas tankers require a tanker endorsement for the respective cargo type as a statutory requirement, because there are specific dangers and hazards associated with these cargoes.
Dry cargoes are certainly not risk-free – ships and crew have been lost at sea because of shifting steel cargoes, explosions caused by the carriage of direct reduced iron (DRI) or coal cargoes and more recently from bulk cargoes that liquefy, such as fluorspar, nickel ores and iron ore fines. The huge variety of cargoes that can be carried on these multi-purpose ships may require specialised knowledge. It is significant that some of the ships that capsized as a result of cargo liquefaction did not regularly carry bulk cargo. Many surveyors will attest to cases where the officers had no previous experience of the cargo being loaded and therefore scant knowledge of the associated dangers.
Recently, I was asked by a shipowner if it was acceptable to load a bulk cargo that was liable to liquefy (where the moisture content was in excess of the transportable moisture limit) into just two holds of a bulk carrier and where the remaining three holds would have contained ‘sound’ cargo. The answer is, of course, that it is not acceptable, and even asking the question suggests a serious lack of understanding.
Introduction of a cargo endorsement should lead to a reduction in the number of lives and ships lost at sea, and fewer sea rescues, cargo claims and cargo disputes. Dry cargo endorsements would also empower masters and shipowners to stand up to the malpractices adopted by some cargo interests. The knowledge would in time filter down and benefit the industry more widely.
It is evident that oil, chemical and gas tanker dangerous cargo endorsements have helped to improve the overall safety performance of the tanker industry. Perhaps it is time for a dry cargo endorsement to be seriously considered.
A dry cargo endorsement
A dry cargo endorsement for officers responsible for cargo handling and stowage would enhance safety on bulk carriers (and general cargo ships). Training courses could include:
• Likely dangers such as cargo shift, explosion, fire and heating, liquefaction for dry cargoes such as steel, grains, dried distillers’ grains with solubles (DDGS), coal, direct reduced iron (DRI), ore fines and concentrates
• The actions to take in situations such as a sudden list, cargo heating or fire
• Precautions and checks when loading cargo, information and documentation provided by cargo interests
• Stability concerns and calculations
• Lashing requirements and lashing strength calculations
• Cargo care procedures, including hold cleaning, when to ventilate, maintaining hold atmosphere readings throughout the voyage (for coal cargoes, for example)
• Dangers associated with entering enclosed spaces containing certain dry cargoes
• Watertight integrity, hatch cover maintenance, water ingress from ballasting or bilge and ballast systems
• Commercial guidance, bill of lading issues, charter party clauses, when to request P&I assistance.