Professional Documents
Culture Documents
March 2011
RISK WATCH
Nickel ore
Risk management
6 Technical seminars 7 Root cause analysis (RCA)
Safety
10 Death of a tank cleaning contractor
In the last three months of 2010, three bulk carriers loaded with nickel ore sank with a tragic loss of 44 lives (none of the ships were entered in Britannia). All three cargoes had been loaded in Indonesia and were destined for China.The common perception is that the cargo was loaded in wet weather and excess moisture in the cargo led to liquefaction.
Nickel is a major component in the manufacture of stainless steel and other corrosion resistant alloys.The addition of nickel to alloys substantially increases their corrosion resistance and strength, and these alloys are widely used in the aerospace, chemical and vehicle industries. Nickel is also used in coins, batteries and armour plating. A decline in stainless steel production led to a fall in nickel prices and production in 2006 2008. However, an increasing global demand, particularly from China and India, resulted in an increase in nickel prices and a consequential higher demand for nickel ore in 2010. Typically the ore comprises a mixture of fine clay-like particles and larger rock sized particles, and it is the former which is prone to liquefaction.The mined ore is usually stored in large open stockpiles before being transported to a ship, so that any drying of the ore depends largely on the prevalent conditions.
Miscellaneous
10 Publications
The International Maritime Solid Bulk Cargoes (IMSBC) Code became mandatory on 01 January 2011, superseding the IMOs Solid Bulk Cargo (BC) Code.The Code is fully integrated with, and has the same legal and regulatory status as, the International Convention for Safety of Life at Sea (SOLAS) Regulations, 1974, as amended. The IMSBC Code stipulates certain guidelines and tests for mineral ore cargoes which are prone to liquefaction, a category which includes nickel ores. In particular, the Code notes that such cargoes may appear to be in a relatively dry granular state when loaded, and yet may contain sufficient moisture to become fluid under the stimulus of compaction and the vibration which occurs during a voyage.
Flow moisture point and transportable moisture limit
knowledge and belief, the average moisture content of the cargo at the time the declaration is presented to the Master. The certificate of moisture content must certify the moisture content of each type of finely grained material loaded into each cargo space, however if the sampling indicates that moisture content is uniform throughout the consignment, then one certificate or declaration of average moisture content for all the cargo spaces is acceptable. The shipper must identify the laboratory used to conduct the tests.The shipper must identify the stockpiles from which the cargo is to be loaded and confirm in writing that the samples tested - and in respect of which certificates have been issued/declarations made - originated from those stockpiles.
Sampling
Section 4.3.3 states that separate testing and certification is required for each type of finely grained material loaded into each cargo space. The Code goes on to state that any substantial portions of material which appear to be contaminated or significantly different in characteristics or moisture content from the bulk of the consignment shall be sampled and analysed separately. Depending upon the results obtained in these tests, it may be necessary to reject those particular portions as unfit for shipment. Section 7.2.3 states Some cargoes are susceptible to moisture migration and may develop a wet base even if the average moisture content is less than the TML. Although the cargo surface may appear dry, undetected liquefaction may take place, resulting in shifting of the cargo.
Sample testing
In order to determine whether a solid bulk cargo is safe for shipment, the cargos flow moisture point (FMP) has to be ascertained. The transportable moisture limit (TML) of the cargo is then calculated as 90% of the FMP, and as long as the moisture content of the cargo offered for shipment is lower than the TML, the cargo can be accepted for loading. Shippers of a solid bulk cargo are obliged to: Provide the Master or his representative with appropriate information on the cargo sufficiently in advance of loading to enable the precautions which may be necessary for proper stowage and safe carriage of the cargo to be put into effect (Section 4.3.2.1). Section 4.3.2 of the IMSBC Code goes on to state: When a concentrate or other cargo which may liquefy is carried, the shipper shall provide the ships Master or his representative with a signed certificate of the TML, and a signed certificate or declaration of the moisture content.The certificate of TML shall contain, or be accompanied by, the result of the test for determining the TML.The declaration of moisture content shall contain, or be accompanied by, a statement by the shipper that the moisture content is, to the best of his
Due to the non-homogeneous nature of nickel ores, preparation and testing of samples can be a lengthy process. Determination of the FMP requires samples of a relatively uniform size and composition, and the moisture content of the samples being tested can vary depending on the proportion of clay or rocks in the sample. Marine experts Minton Treharn & Davies note that it is crucial to ascertain the moisture content of the particular portion of the nickel ore cargo that liquefies i.e. particles smaller than 7mm, for comparison with the TML.The larger stones have significantly lower moisture content and their inclusion in the samples can make it appear that the cargo is below the TML, whilst in fact the liquefiable portion of the cargo is actually above the TML. Section 4.5.2 of the IMSBC states: Sampling and testing for moisture content shall be conducted as near as practicable to the time of loading. If there has been significant rain or snow between the time of testing and loading, check tests shall be conducted to ensure that the moisture content of the cargo is still less than its TML. The interval between sampling/testing and loading shall never be more than seven days.
The IMSBC Code requires that the properties of a solid bulk cargo be determined in accordance with test procedures approved by a competent authority in the country of origin or, if such procedures do not exist, in accordance with the test procedures prescribed in Appendix 2 to the Code. Determination of the FMP of samples of nickel ore in a laboratory should be done in accordance with one of the three recommended methods in the IMSBC Code listed below:
Flow table test (drop test)
Suitable for concentrates or fine material of grain size 1mm (up to 7mm for some cargo types).
Penetration test (vibration test)
Suitable for fine and coarse grained ore concentrates up to 5mm. The flow table test is the method of choice for testing nickel ores. However, best results are generally obtained when testing homogeneous samples of cargo.
The Code cautions that the flow table test may not give satisfactory results for some materials with high clay content and this, along with the non-homogeneous nature of nickel ores, is why the test should ideally be performed by experienced technicians. Full details of the test equipment and procedures are given in Appendix 2 of the Code. The samples being tested are also often laid out on a flat surface for sorting, and moisture loss can take place in these circumstances.This could result in the test not accurately reflecting any propensity for the cargo to liquefy.Testing of samples should therefore be carried out by a properly equipped and competent testing facility/laboratory. When assessing whether a nickel ore cargo complies with the IMSBC Code, it is not usually possible to determine from a visual inspection or simple test on board the ship whether a cargo has a moisture content above or below the TML. We can reasonably conclude that a cargo that is visibly wet or saturated is unsafe, but the reverse is not true.
Cargo sampling/discharge after loading
Marine experts Brookes Bell advise that individual spot samples should be obtained in each cargo hold on the basis of one subsample for every 500MT, as specified in the IMSBC Code.The samples would normally be collected from five separate sampling pits, at a range of depths in each pit. The cargo in each hold would be considered acceptable as long as the average moisture of all sub-samples in each hold is below the TML, and there are no more than isolated individual moisture results (say, one or two per hold) above the TMP. In particular, the moisture content of samples taken from the tanktop should be below the TMP. If the cargo already on board is found to be unsafe, it is often difficult to discharge this potentially unsafe cargo because of the lack of discharging equipment at the load ports. At intermediate ports Customs may not allow the discharge. Shippers often suggest the possibility of leaving some unsafe cargo on board and overstowing it with fresh safe cargo.This practice is not in compliance with the IMSBC Code, as highlighted above.
Masters obligations
The Master or his representative should monitor the loading operation from start to finish. Loading should not be commenced until the Master or the ships representative is in possession of all requisite cargo information in writing as described above. Masters should be wary of moisture content certificates provided by the shippers laboratory and moisture content percentages that are very close to the TML. If there is significant rainfall between the time of testing and the time of loading the shipper must conduct further sampling and testing. If in any doubt of the moisture content, can tests should be conducted, particularly when rainfall has been experienced.The can test is described in section 8 of the IMSBC Code as a spot check a Master can conduct if he is suspicious of the condition of the cargo, and is not meant to replace or supersede laboratory testing. Section 8 states that if the sample shows signs of liquefaction i.e. flat surface with evidence of free moisture, arrangements should be made to have additional laboratory tests conducted on the material before it is accepted for loading. Nevertheless, cargo should never be accepted on the basis of the can test alone.The test may indicate if cargo is unfit for shipment but cannot determine if a cargo is fit to be loaded this can only be determined by laboratory testing.
If a potentially dangerous cargo has been loaded, the actual moisture content of the cargo will need to be ascertained. Sampling should only take place after the cargo has been trimmed reasonably level in the holds. In a bulk carrier with hopper type holds, sampling in the centre of the stow can be carried out with grabs, however sampling in the wings or overhangs may only be possible using excavators.
The Master has an overriding authority under SOLAS not to load the cargo and/or to stop the loading of the cargo if he has any concerns that the condition of the cargo might affect the safety of the ship.
P&I surveyor
Summary
Slam the can against a hard surface from a height of about 0.2m
Members intending to load nickel ore from ports in Indonesia, New Caledonia and the Philippines are advised to contact the Managers and the Associations local Correspondent at the earliest opportunity, in order to arrange for guidance and expert assistance to be provided. Many of the load ports in the countries specified are in remote areas which means that a cargo surveyor or expert will require plenty of time to travel to the port and carry out the required investigations and tests. It should be made clear to the port and competent authorities, shippers and charterers that the appointment of a surveyor by the ship is not intended to and does not relieve the shipper of his obligations under the IMSBC Code or local regulations.
Cargo documentation provided for nickel ore cargoes is often deficient and may not alert the crew to the potential danger of the cargo liquefying. It is essential for the safe operation of the ship that the officers on board fully understand the characteristics of the cargo to be loaded. The cargo should not be accepted for loading if any of the above conditions are not met or if there is any doubt about the cargo or the test certificates.The Master has the authority to reject any cargo, or to refuse to sail with the cargo on board, if he reasonably suspects that there is a risk that the aforementioned requirements are not being met.
It should be possible to see if cargo displays free moisture or fluid conditions, if so, arrange for laboratory testing of samples of the cargo before loading
Sampling risks
Sampling is an important part of the bulk liquid cargo custody transfer process and can help in protecting the ships interests in the event of disputes over cargo contamination. Precautions should be observed in taking and keeping appropriate and representative samples.
Surveyors appointed on behalf of cargo interests will take samples for their principals, but are not required to supply a set of samples for the ships retention. It is advisable for the ships crew to take samples to protect the ships interests. Any sampling should be undertaken according to standard industry practice as described in various guidelines and standards published by American Society for Testing and Materials (ASTM), Institute of Petroleum (IP), the American Petroleum Institute (API) and British Standard (BS) for example.The following guidance, supplied by Messrs CWA International Ltd, consultants, addresses some of the deficiencies observed when crew have undertaken sampling. Generally a running sample taken using bottle and sample cage is preferred for taking samples in a homogenous cargo. If the cargo is not homogeneous then sampling from various cargo zones should be carried out e.g. upper, middle lower tank samples or changeover of shore tanks during loading. Cleanliness of both sampling equipment and sampling ports or manifolds is important to avoid inadvertent contamination of the sample with extraneous dirt, water or previous cargo. All containers used should be clean, dry and appropriate for the type of cargo being sampled. Clear glass bottles are
generally acceptable for most chemical or petrochemical products, but there are some exceptions, including caustic soda or potash cargoes, which should be stored only in plastic bottles. Lacquer-lined cans can be used for most petroleum products but are not appropriate for many chemical cargoes. Poor sample labelling can lead to a sample being rejected for analysis if there is lack of identification or doubt over its provenance. Information on labels should include date and time, vessel name, port, location (e.g. cargo tank, manifold), description of cargo, type of sample (e.g. first foot, composite, running,Upper, Middle, Lower), identity of sampler, and seal number. The use of seals or at least tamper-proof self- seal lids will help to maintain the integrity of the samples and should be applied if available. Samples should be taken after completion of loading and prior to commencement of discharge from ships cargo tanks, and at the manifold at the start of loading and discharge. Occasional manifold samples should be taken, especially during discharge. First foot samples should always be taken. If possible, samples from shore tanks before loading and after discharge should also be obtained.
Contamination allegations can often be resolved by reference to samples of previous cargoes and not just samples of the cargo in question. Further, allegations of contamination can be made some time after discharge. Accordingly samples need to be retained for some time. Although space is limited for sample storage on board ships, samples should be stored in cool, dark conditions and retained where possible for a minimum of 12 months especially if the cargo is known or suspected to be the subject of a dispute. If samples are sent for storage at, for example, surveyors premises or a local laboratory, ensure that the storage facilitys initial instructions are for indefinite storage as otherwise samples are usually disposed of after a maximum of three months. A log should be kept of samples with details as per the sample labels and seal numbers. Finally, many cargoes may be flammable or toxic, so it is vital that appropriate safety precautions are taken during sampling procedures and also on storage of such samples. If samples are not required, they should be disposed of by appropriate procedures: the services of local cargo surveyors or testing laboratories who are familiar with the correct disposal methods available may be used.
Risk management
Technical seminars
Britannias technical seminar programme is now a well-established item in the Britannia calendar and during 2010 the risk management team has hosted 16 separate seminars in five countries, attracting over 1,000 officers and crew.
The programme is part of the Clubs risk management activities designed to provide a forum for serving officers and superintendents to hear from fellow professionals about current topics in the marine industry relating to safety and best practice. Audience participation is encouraged and the format of the days programme provides plenty of opportunity for discussion within the allotted time for the presentations, as well as during the coffee breaks and lunchtime when a buffet is provided for the delegates. Subjects covered in 2010 included:
Bulk cargo care ECDIS
The ECDIS presentation reviewed the basics of the ECDIS system, including a study of the relevant rules and regulations, together with the challenges presented by transferring from paper charts to ECDIS. Practical problems and potential pitfalls were dealt with by reference to recent incidents.
Oily water separator and oil record book
The format of the collision presentation is always popular with delegates and a lively debate is guaranteed. All the presentations were based, in part, on actual claims handled by the Club, and incorporated photographs, video clips and simulations. The location of the seminars has been influenced by the responses received from Members to our enquiry requesting up-todate data on manning arrangements.The technical seminar road show visited India, Indonesia, Philippines, South Korea and Taiwan with Indonesia, South Korea and Taiwan being new locations for the seminars in 2010. The locations and dates for the 2011 programme will be posted on the Club diary page on the Britannia website as early as possible.The first seminar in 2011 is scheduled to be held at the Radisson Blu Hotel, Szczecin, Poland on Tuesday 5 and Thursday 7 April 2011. It is anticipated that the road show will also visit India, Philippines, South Korea and Taiwan during the year. The feedback has been very positive from those attending the seminars and it is hoped that the practical and technical information imparted will enhance the Members own training programmes. We hope you will continue to support the Club in its efforts to assist Members and their Manning Agents to raise safety awareness on board by sending delegates to these seminars.
A primary aim of this session was to reinforce the overriding obligation of owners/ operators/Masters to ensure that cargoes to be carried comply with SOLAS and the IMSBC Code which became mandatory on 1 January.The talk addressed typical problems encountered with the carriage of a variety of bulk cargoes, namely iron ore fines, nickel ore, direct reduced iron (DRI), coal and seed cakes. Mindful of the catastrophic loss of three ships loaded with Indonesian nickel ore which sunk with tragic loss of life in 2010, delegates were reminded of the importance of ensuring that nickel ore is safe to load and were made aware of the dangers of liquefaction. Attention was also drawn to the safe shipment of iron ore fines from Indian ports. Delegates were reminded that in 2009 two ships the ASIAN FOREST and the BLACK ROSE (neither of which were entered in Britannia) capsized and sank following liquefaction of iron ore fines at the Indian ports of Mangalore and Paradip.
The oily water separator and oil record book presentation highlighted Marpol violations in USA, reviewing the US legal framework and providing guidance for crew. The talk also addressed Port State Control inspections exploring what the inspectors are looking for and how crew can best prepare for these inspections. The session provided vivid examples of poor environmental practices on board ships, and the severe financial consequences arising from them, encouraging Members to ensure their environmental compliance programmes are rigorously enforced onboard all their ships.
Collisions
The collisions presentation used a Britannia case to highlight common communication and bridge team management faults which led to an increased risk of collision.The presentation was supported by a computer simulation based on the actual VDR and audio recording of the collision incident.The presentation also drew on the salient points made in the complementary presentations given on the topics of Risk Assessment & Safety Culture and Bridge Risk Management.
Risk management
The research
Risk Managers monitor a continuous flow of information on individual claims and series of claims which could trigger a RCA. In addition, statistical analysis of the Clubs claims data is used to identify trends of poor performance in all types of claim which may also lead to a RCA. In the majority of investigations, analysis shows that the safety culture of an organisation, or the absence of such a culture, lies at the heart of the problem. In most cases, a visit to the Members organisation would be required in order to observe both the relationship and communication between management ashore and crew on board the ships.
A RCA conducted for a Member
The report contained advice for the Member concerning information flow between its port agents and the port authorities to ensure best possible levels of support from the port authorities. Recommendations were also made for the Masters in terms of pre-arrival and pre-departure briefings, planning and assertiveness in dealing with port authorities and pilotage services.The report made observations on the bridge team, focusing on attention to detail with regard to conduct of navigation and ensuring the team had shared situational awareness. Finally, the report addressed current manning levels and the bridge team organisation.The Member implemented all the recommendations into operational procedures for the ships engaged in the particular trades identified.
Lessons learned for Britannia Members
Comprehensive pre-arrival and pre-departure briefings should be conducted to raise the level of attention in the team and refresh their shortterm memories for instant recall and action. When a ship requires inbound pilotage it is essential, particularly with respect to any berthing manoeuvres, that the Pilot is on board early enough to conduct a proper and thorough Master/Pilot exchange. Bridge teams need to be aware that Pilots in certain ports tend to want to embark much later and much closer to the intended port than the declared boarding position on the nautical chart. When a pilot is on board, the bridge team must ensure that the pilots knowledge and experience of local conditions is clearly communicated to them and integrated into the bridge teams information flow and passage plan. Standard procedures should be adopted to ensure that everyone executes orders in the same agreed way and that there is consistency in approach. The bridge team must monitor the voyage and remain alert to everything happening around them (situational awareness).This should include a comparison of what is actually happening to what should be happening at any given time or position en route. Assertive error spotting by the team should be encouraged to combat complacency or distraction. Fatigue in crew should be monitored. The bridge team should have adequate rest periods to avoid any potential failure in planning, communication and situational awareness which is the result of short and long term tiredness. Teamwork is essential to ensure the bridge team is working together towards the common goal of a safe and successful voyage.
At the request of a Member with concerns over two dock damage incidents involving the same ship within a calendar year, the Association instructed independent consultants to conduct an investigation. Their remit was to sail with the ship for a two week period to observe the shipboard navigational practices and bridge resource management.The consultants also reviewed the earlier incidents and were asked to comment on whether the observed practices on board the ship may have contributed to either of the incidents. During the two week period the consultants were able to observe many day and night time berthing, un-berthing and anchoring operations, as well as a night time transit of the Dardanelles Strait under pilotage.
The RCA highlighted a number of observations which are helpful for all Members:
Bridge resource management (BRM)
The bridge team must understand their individual and collective responsibilities and they must be able to communicate clearly and effectively their observations on the ships progress and contribute to any decision made by the team. Voyage planning must be from berth to berth. A full appraisal of the traffic density, navigational hazards and statutory requirements should be conducted for the route, together with a risk assessment and contingency plan for any unexpected incidents.
Tindall Riley (Britannia) Limited New City Court 20 St Thomas Street London SE1 9RR Tel +44 (0)20 7407 3588 Fax +44 (0)20 7403 3942 www.britanniapandi.com
RISK WATCH is published by The Britannia Steam Ship Insurance Association Limited, and can be found at www.britanniapandi.com/en/publications The Britannia Steam Ship Insurance Association Limited is happy for any of the material in Risk Watch to be reproduced but would ask that written permission is obtained in advance from the Editor.
Miscellaneous
Safety
Publications
Piracy: BMP3
Members are reminded that BMP3 was published in June 2010 and is available to download free from the following site:
http://www.britanniapandi.com/download. cfm?docid=8838B55F-72DC-4D97-BF2841 A5865A7DAF
The purpose of the booklet is to assist ships to avoid, deter or delay piracy attacks off the coast of Somalia, including the Gulf of Aden and the Arabian Sea area.The booklet sets out the Best Management Practice (BMP) and updates the guidance contained in the second edition of the BMP document which was published in August 2009. Experience, supported by data collected by Naval forces, shows that the application of the recommendations contained within the booklet can and will make a significant difference in preventing a ship becoming a victim of piracy. Members are also reminded that the latest piracy attacks can be viewed on the IMB Live Piracy Map at:
www.icc-ccs.org/livepiracymap
Editors 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