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vetting inspections, but to the incident occurred to the ship in Jebel Ali, last November: grounding which caused heavy damages to the rudder stock which was found twisted of about 18°.
The Academic lesson continues its excursus in the bill of ladings issues, while the safety section is dealing with drills issues and self and video trainings.
The section related to the lessons learnt have good points on which people need to think out: an entry in enclosed spaces made without even consider the basic safety procedure and a lack of planning and assessment, with an under evaluation and estimation of the potential dan-ger that can lead to fatal consequences.
Good reading to everyone!
And the best wishes to all, ashore and on board, for a better new year, hopefully much more bet-ter than the one which is going to end.
G. Mortola
Dear Premuda's people, Another year is just going to the end, a year full of challenges to survive is this hard period.
Everyone is well aware the problems every day we are encountering to keep “swimming” in this sea: to everyone of you, Company extend its greeting for the efforts done and for those that will be done in the future.
Back to this edition of the Information Bulletin, the most important and significant part is the Fleet Director’s comments on a recent event occurred to one vessel of ours which entered an ECA zone without having compliant F.O on board. Not only the correct fuel was available, but no action was even planned to mitigate the impact due to the lack of the product.
Also, vessel was not able to provide the proper documentation that efforts were made to pro-cure compliant fuel and that the Administration was properly notified of the status prior to enter said area.
The event took place whilst approaching an US port and the deficiency was detected by the USCG Port State control resulting in vessel’s detention.
Vessel was not prevented to carry our the sched-uled commercial operations , since the correct bunker was immediately ordered and vessel started to burn the LSMGO which ,fortunately, was on board.
The event demonstrated an insufficient control both by ship and shore staff for the rules when approaching an ECA area (which, incidentally, was an USA ECA and not an European ECA, where vessels are used to sail). However, this is not an excuse for the serious event , considering also that
Company provided timely sufficient indications, procedures and instructions regarding the geo-graphic position, time of entering in force and specific indications or requests and change of use for the complain bunker: the deviation seems to be an isolated case, created by some concurrent causes and by an insufficiently ade-quate supervision both on board and ashore.
Masters shall pay extreme attention when plan-ning the passage plans, considering all the ar-eas where the vessel will pass and call and all related regulations: it’s a work to be done and planned in advance, evaluating all the aspects.
With regard to the vetting section, it is high-lighted the positive trend, notwithstanding the technical hold of the F. Wind by most of the MOCs. Anyway this is not due to failure of the
The selected closed cases:
In this Issue:
The vessel in the hurricane: Four Bay Vetting Issues Safety issues: VOD training analysis
Lack of planning related casualties analysis
The Academic Lesson: excursus on B/L (cont.)
Information Sharing Bulletin is published by: Premuda SpA - SQE Dept. Email: [email protected]
- Collection of selected closed cases
- Vetting Issues
- Remarks to be shared
- Lesson’s bearing
- Academic lesson
Information Sharing Bulletin
Summary:
§ Hazardous occurrences
- Unsafe walkway
- Inadequate housekeeping
§ Incidents
- Deck operations
- Client dissatisfaction
- Rudder blade grounding
www.premuda.net Be proactive!
Please, send any comment to the Editor: [email protected]
Lesson Learned Issue n° 25
April 2014
- Vessel in the Hurricane
M/T Four Moon sailing in Curacao area
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The vessel in the “Hurricane”
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Four Bay US PSC detention due to MARPOL, Annex VI non compliance (access to US East Coast ECA without LSHFO change over)
The present Premuda Safety Bulletin “vessel in the hur-ricane” case is dedicated to our good M/V Four Bay having been detained by the US Coast Guard at the end of December 2013 on account of the vessel hav-ing entered the US East Cost ECA area without having carried out the required switch to LSHFO Fuel. The purpose of having this case examined in this Safety Bulleting issue is twofold: the first is to focus everybody attention on the fact that PSCs’ controls worldwide are more and more focusing on compliance to all aspects of SOLAS and MARPOL regulation related to ships op-eration ; the second is to stress the fact that no matter how complete and exhaustive company SQEMS proce-dures are, the utmost attention is always required to the vessels commands and Company offices in order to be fully aware of when their due and timely application is required. Facts are well know but can be here summarized for better reference and understanding of everybody: the vessel had been ordered to sail from Malta on 7th De-cember 2013 in ballast bound to the harbor of Philadel-phia for loading. Commercial details were not fixed yet for the loading operations and the vessel sailed from Malta with bunker tanks loaded with HSHFO and LSMGO, the latter being required as four to be used for vessel operations within EU ports as per Eu33/2005 regulation. Upon arrival at Philadelphia , the vessel was anchored at Big Stone Anchorage waiting to be inspected by the US coast guard for COC issuing and ISPS code compli-ance confirmation before being authorized to carry out commercial operations in the US. According to charter-ers’ information the vessel would have had to load from
STS and at berth. During the above inspection on 24th December 2013, the PSC officer found evidence that the vessel had en-tered the US East Coast ECA without switching to the LSHFO required to be used in the same area by MAR-POL Annex VI, Regulation 14.4 i.e. LSHFO having maxi-mum sulfur content non exceeding 1% . The vessel had operated on standard HFO compliant with MARPOL Annex VI requirement but not allowed to be used in ECA areas du to its max Sulfur content of 2,5%. Actually the vessel did not have LSHFO in storage on board either. The PSC offices questioned the vessel master about the occurrence and noticed that the vessel command was not aware of the implementation of the same ECA requirements as well. As a result of the above the vessel was detained on account of non compliance with the MARPOL regulation and only allowed to shift to another anchorage were LSHFO could be loaded. The Company DPA was immediately informed of the US PSC actions and corrective actions were immediately enforced including the change over to LSMGO as fuel for the DD/GG and auxiliary boilers. The latter was available on board in quantity as the vessel had oper-ated in the EU ports recently, were authorities require vessel to burn FO having sulfur content of max 0,1% during commercial operations. Furthermore a supply of LSHFO with 1% max sulfur content was immediately organized and the vessel allowed to shift to a nearby anchorage to carry out the bunkering operations. The fact that the vessel had on board a supply of LSMGO that was immediately put in use helped mitigate the economic and financial consequences of the event but could not cancel the detention. PSC cleared the vessel soon after the Company man-aged to order and have LSHFO delivered on the ship on 26th December and the vessel was then allowed to start her commercial operations. As a consequence of the US PSC detention the Italian Coast Guard 6° Reparto in Rome was duly informed by the DPA who also reported them about the corrective actions that had been enforced. The event allowed the Company to carry out a deep analysis of the occurrence not only as part of the due NCR/detention closing process but also in order to de-termine the causes of what was immediately identified in a breakage of the information/notification chain that is the main instruments through which dangerous situa-tions risks can be mitigated since they arise in order to prevent incidents and /or failures. The results of the internal investigation evidenced that a lack of internal communication and focus on the fact that US East Coast had entered the MARPOL Annex VI special ECA areas the year before and therefore the vessel even if had had no possibility to load LSHFO on the route to the US, the local authorities and flag administration would
Borders of the North America ECA
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Selected closed cases
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The vessel in the “Hurricane”
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have had to be noticed of the fact upon entering the US/ECA area in order for them to evaluate the case and possibly issuing a deviation letter allowing the ves-sel to transit and carry out the operation at the desig-nated US port where LSHFO could have been supplied as well. The fact that the Company was under heavy commer-cial pressure after the vessel had been idle for weeks at Malta waiting for a commercial employment and that it had to leave Malta anchorage quickly after being fixed, somehow overshadowed the focus on the ECA zone requirements that were therefore not recalled and reminded to the vessel master; on the other hand also the vessel Master for some reason missed to focus on the same and the vessel proceeded to the US virtually unaware of the requirements itself. Anyway the above does actually demonstrates that no ISM/SQEMS system is good enough to be error free if the persons managing it are not fully and constantly exchanging one another all information and notices that are the instruments through which the ISM/SQEMS is managed. As a further consequence of the detention, the Italian Coast Guard 6° Reparto in Rome summoned the Com-pany DPA and Fleet Director in order to get the neces-sary explanation of the event as well as the Company analysis and corrective/preventive actions. The meeting was positively concluded with no further action from the Italian Coast Guard but this cannot re-
duce the very negative impact this event had on the Company records and performance as well as its im-age. Notwithstanding the timely corrective actions and proper preventive actions that have been enforced by the Company to prevent the reoccurrence of this event, like the purple-finder vessel position notice system that sends automatically a notice to all office whenever a Company vessel enters a special area, I would like to stress that we have to always find time to analyze properly every event, voyage and consequence of ves-sel operations in order to prevent what has happened to Four Bay in the US. I’d like to conclude this open talk with all of you with the following lesson learnt; stay focused! Until the next, thank You all.
Federico Beltrami
POSTER N°56 a issued by Company as part of corrective actions to reinforce compliance with MARPOL
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Pagina 11
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Vetting Issues
Dear All,
Good day, We are here addressing the first quarter of 2014 that differ-ently from past years showed up in an extreme positive trend speaking about SIRE inspection results. I am saying this as in the past three years seemed as we were asleep and normally we had one/two bad SIRE inspections we all then were working for in order to correct it. The only negative impact and not a small one is coming out from incident occurred to M/T Four Wind, grounding with rudder blade at Jebel Alì port and causing heavy damages to rudder stock, found twisted of around 18° and deflected too. Upon due declaration of incident occurred all main Oil Ma-jors, BP, SHELL, Exxon, STATOIL, put the vessel in “technical hold” and after vessel moving out from repair Yard is now time of heavy work on paper side in order to clear the vessel by the hold and restore the Lady to the usual commercial level.
Regards to all M. Leveratto
***********
SIRE Inspections performed during
January– April 2014
Four Bay Vessel performed SIRE inspection with BHPB-RightShip, Singapore 23/02/2014 (4 No) with positive result. Shell accepted vessel referring to last BHPB-RightShip SIRE Re-port, Chevron and ExxonMobil referring to last Shell SIRE Report if necessary. Due to PSC detention at Delaware, USA, on 24 Dec. 2013 vessel was not accepted by BP until in-spection to be requested not before 24 June 2014. Vessel was sold at Khor Fakkan, U.A.E. on 27 March 2014. Four Island Vessel did not perform any SIRE Inspection during this pe-riod. Next SIRE Inspection to be performed either with Shell or with PDVSA. Four Moon Vessel performed SIRE inspection with PDVSA, Bonaire 27/02/2014 (10 No) with positive result. Presently no other inspection can be scheduled due to vessel’s age policy of other Major Oil Companies. Four Smile Vessel performed SIRE inspection with Shell, Sikka 08/02/2014 (3 NO), with positive result. On 25 November 2013 Total screened vessel negatively due to anchor studs and BHPB-Rightship SIRE Report. Chevron and ExxonMobil referring to last Shell SIRE Report available if necessary. Next SIRE Inspection to be performed with BP.
Four Wind: Vessel did not perform any SIRE Inspection during this period. After rudder stock repair at Dubai Dry-docks com-pleted on 20 Feb. 2014 and first available documentation sent to ExxonMobil, Shell, BP, Chevron, Total, Repsol and Statoil, vessel was cleared by BP on 24 Feb. 2014, while incident report and other related documentation was sent on 3-4 April 2014 for vessel’s clearance. Next SIRE Inspection to be performed with Shell at Mom-basa, Kenya on 1 April 2014. Four Sky: Vessel performed SIRE Inspection with Shell, Bayonne, NJ 14/02/2014 (2 No) with very positive result. Exxon and Chevron referring to last Shell SIRE Report if necessary. Next SIRE Inspection to be performed with BHPB-RightShip. Bulk Carriers: Four Springs
Vessel did not perform any inspection during this period. . 06.05.2014 VETTING DEPARTMENT
Remarks to be shared
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Dear All,
WELCOME INTO THE SAFETY PAGE!
Dear readers welcome into safety area In this issue, we will deal and underline training on board.
SELF TRAINING
Crew safety knowledge improvement has been demanded to Use of VOD (Videotel On Demand). All crew have free access to all study package and can se-lect specific videos or CBT (Computer Based Training) or learning study case to improve his knowledge. Company has prepared a Company training matrix that will be sent on board every two years, where are listed all vid-eos, CBT drills, all crew should attend. CBT’s are a very good opportunity for the crew due to they provide a certificate of competence if they achieve at least 70% of correct answer. Furthermore some certificate can be validate from Videotel that can be add to crew personal qualification file. The scope of this section is to bring to the attention to all persons employed on company vessels the importance to improve proper knowledge using VOD. Company have the possibility to monitor ship’s performance on videos, CBT’s, interactive CBT, learning study case through internet Videotel web site. Please find here below summary of ship’s performance for 2013 year.
CBT’S TRAINING SUMMARY
Some vessel must improve training on board since there is evidence that, VOD use is limited to safety day only.
VIDEO’S TRAINING SUMMARY
DRILLS TRAING SUMMARY
Training is the only way to brake the error chain and pre-vent any injury or accident. Is responsibility of everyone on board to pay attention dur-ing the proper duty. TRAINING: peoples are learning the correct safe way to carry on a job and prevent injury. DRILL : verification of what peoples learned like an exami-nation. Drills can be carried out in presence of external person that can arise a serious deficiency if drills was not satisfac-tory.
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Annual CBT’s summary Continuity training report
Is very important that training should be conduct in a
continuity manner in order to avoid gap during perform-
ance.
SAFETY IS A STATE OF MIND
THINK SAFETY
Masters should encourage proper crew to use VOD
since a trained crew is a qualified crew and a will give a
result a excellent performance in all areas with a good
image for a Company.
Don’t think to be able to carry on a job only with poor
information passed to you during hand over, this is the
way to have an injury , prevent it with improvement of
your safety personal knowledge.
Remarks to be shared
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Lesson’s Bearing
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Lack of planning related casualties
PREAMBLE - This month we will present two different cases among the published lesson learned proposed by IMO, to be considered and analyzed by ship-ping Companies. These two cases are dealing with very different types of operation, but both of them raised from lack of planning and passive atti-tude relatively to safety implementation. The first one deal again with entry in enclosed spaces, engaged without any consideration of basic safety procedure. The second one,
relative to mooring operation, shows how a lack of planning and assessment can lead to the under evaluation of potential danger that can produce fatal consequences.
Case N°1 - Fatal accident in an enclosed space What happened? During a loaded voyage on board a bulk carrier, the chief mate and a deck cadet went inside one of the vessel’s bilge space enclosures to repair a sounding pipe. To gain access to the enclosure, the two crew members had to walk inside the duct keel and then through a steel hatch, which opened up‐wards inside the transverse bulkhead lower stool. Once inside the lower stool space, a manhole cover had to be removed to crawl inside the bilge space enclosure. The crew members started work‐ing on the sounding pipe but about an hour later, a second cadet found them unconscious inside the enclosure. The alarm was raised and the two crew members were pulled out to the main deck. First
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Lesson’s Bearing
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aid was administered; however, they were both proclaimed dead later that evening. Why did it happen?
1. The bilge space enclosure had been closed for a considerable period and the atmosphere inside
the space was non‐life supporting. 2. Prior to entry, the atmosphere inside the bilge space enclosure inside the bilge space enclosure
was not tested as required by the company’s safety management system. 3. A Permit‐to‐Work was not issued before access was made inside the enclosed space, as re‐
quired by the procedures laid down in the safety management system manual. 4. The Master was not aware of the work in progress. 5. The chief mate involved failed to appreciate a life‐threatening situation inside the bilge space
enclosure. 6. Evidence indicates circumventing of safety norms and procedures. 7. The chief mate was likely to have consumed more alcohol than the limit stipulated in the com‐
pany’s safety management system. What can we learn? Crew members cannot afford a passive attitude, especially when it comes to the implementation of the safety management system. Rather, they should be fully alert and aware of the potential hazards on board their ships. A permit‐to‐work system should be an undisputed means of enforcing correct safety procedures. Small quantities of alcohol can impair safe behavior, compromising safety of the ship, crew, cargo and environment.
Case N°2 - Enclosed space entry causing death and personal injury What happened? A seaman was killed by a wire mooring line while a ship was in the process of berthing. The wire had been led from a mooring winch through a snatch block attached to a U‐shaped rope guide on a set of mooring bitts during an unusual mooring operation. While the ship was berthing the seamen was told to go to the starboard winch to relay some instructions to the operator. As he was walking through the bight in the mooring wire, formed by the snatch block, weight came on the wire and the U‐shaped rope guide failed. The seaman was caught by the flying wire and sustained fatal injuries.
Why did it happen? 1. The U‐shaped rope guide should not have been used to attach the snatch block as it was not
strong enough. 2. The mooring operation was unusual and untested and should have been approached with con‐
siderable caution. 3. Communication was poor between the mate supervising the operation and the seaman operat‐
ing the starboard winch since they could not see each other, they did not speak the same lan‐guage and they did not have radios.
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Lesson’s Bearing
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4. The poor communication meant that the seaman, who was killed, had to move through an area of danger and the bight of the loaded wire mooring line, to pass instructions between the men.
What can we learn? Mooring operations should be carefully planned and carried out. All load‐bearing mooring equipment should be fit for purpose and periodically tested. Moving through, or working within, the bight of a loaded wire or cable is very dangerous and should be avoided.
As result of final analysis of both occurrences, we can find out that in both cases the main cause of fatalities was the lack of planning and the unsuccessful applica-tion of Company procedures. The work permit system was completely unattended on the first case; in the second case it was performed one operation not consid-ered by procedures without an adequate planning.
Selected and commented by Andrea Pittaluga
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The Academic Lesson
BILLS OF LADINGS— cont.
BOLERO (electronic B/L)
A specific and more detailed point is to be addressed to BOLERO B/L.
BOLERO stands for Bill of Lading Elec-tronic Registry Organization and let’s start with some words about its history.
In 1993 the European Union studied the possibility of elec-tronic exchange of trade documents. Once the study was completed, the EU turned the project over the Society for Worlwide Interbank Financial Communications (SWIFT) and to the Through Transport Mutual Insurance Association (TT Club) as an independent joint venture.
BOLERO started then to operate on a commercial basis in 1999.
But what an electronic BL (eBL) is? It’s not simply an elec-tronic version of the paper bill of lading. It’s rather a combi-nation of a legal rulebook and technology which can repli-cate the functions of a traditional bill of lading.
The eBL is a combination of the title registry record and an attached document that contains the eBL data.
BOLERO enables sourced eBL to be imported either by PDF, ScanPDF, etc or even directly imported into the BO-LERO eBL web application.
More deeply:
A BOLERO eBL can only have one holder at any time;
There must be a holder at all times;
The title registry records who is the holder;
Holdership is the electronic equivalent or possession of the physical paper BL
Benefits include:
Removes paper based bills as part of the trade process
Supports full electronic presentation of Letters of Credits
Facilitates adoption of the new bank payment obligation
Reduces risk of fraud
Removes the requirement for Letters of Indemnity
The eBL contains the same information as the paper docu-ment, and just like “order” BLs can be subject to the Hague-Visby Rules if so stated in the contract of carriage and if local laws have provisions for electronic BLs.
A carrier with an agreement with the BOLERO organization can electronically originate and transmit a BL.
BOLERO verifies the carrier’s electronic signature and for-ward s the BL to the shipper.
The shipper can transfer the title to a subsequent BL holder by way of a unique set of instructions sent to BOLERO.
This last feature will go a long way to protecting a shipowner against mis-delivery of a cargo where the BL has not been presented in the discharge port. It will also probably elimi-nate the problem of forged BLs.
However, notwithstanding the benefits of using eBLs, there are still a lot of obstacles before electronic transfer of trade documents will replace paper documents.
The main problem is that most local laws do not contain provisions yet for paperless trading. It will probably take sev-eral years till countries have passed proper legislation to make paperless trading possible.
Another reason why BOLERO starts to run so slowly is that advanced technology is not available in all parts of the world.
Also, the costs of BOLERO membership may be also a factor for carriers that do not produce a lot of BLs, such as in bulk shipping.
On the contrary, it’s undeniable that the BOLERO system may greatly contribute to improved standardisation of Bills of lading and other trade documents, to less duplications and errors, to more reliable delivery of documents, to elimi-nation of fraudulent practices, to faster banking operations and to greater efficiency of international trade.
So far, P&I Clubs do not automatically cover liability for dam-ages stemming from using BOLERO that would not have oc-curred under proper documentation, but carriers can apply for coverage through a special endorsement.
As a matter of fact, the P&I Clubs main concern is that some systems which use electronic bills of lading may not be uni-versally recognised as satisfactorily performing the three functions of a bill of lading which customarily underpin P&I cover, namely:
as a receipt
as a document of title
as a contract of carriage which incorporates the Hague or Hague‐Visby Rules
Of course, shippers remain responsible to carriers for provid-ing the proper BL description, including the proper classifica-tion of dangerous goods.
Selected by P. Linari
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Visit our web at: www.premuda.net
Premuda, founded in 1907, is one of the most expe-rienced shipping Company with the mission of tran-sporting oil and dry-bulk cargoes.
The Company operates also in the FPSO market.
Premuda holds the most qualified certifications in Safety, Environmental protection, Quality and Secu-rity standards.
Premuda S.p.A
Via Fieschi 3/21 I—16121, Genova
Tel.: +39 010 5444.421 Fax: +39 010 5444.313 E-mail: [email protected]
There are no shortcuts to safety, and everyone has to contribute
