The Britannia Steam Ship Insurance Association LimitedRISK WATCH

Volume 22: Number 1

April 2015

Claims for short-landed cargo arise if anexcessive residue of the cargo loaded remainson board after completion of the discharge. To assist in defending such claims, the shipmust show that all ‘pumpable’ cargo wasdischarged. In order to do this, the ship’s crewmust carefully record all details of the loadingand discharge operations and must show thatthey acted in accordance with the ship’sprocedures. They must also show that theywere complying with the industry standardsfor the carriage of the particular cargo.

Our analysis of recent shortage claims againstMembers shows that there are three mainfactors which contribute to ROB claims:

Loss prevention 1 Tanker shortage claims: cargo remaining on board (ROB)

4 New CTU Code: improved guidelines for intermodal container packing

6 Know your break bulk cargo 8 Publications

8 Loss prevention poster campaign: COLREGs 5, 6, 19 and 35

Tanker shortage claims: cargo remaining on board (ROB)

This article continues our series highlighting good practices thatcan be shared with Members and looks at shortage claims due tocargo residues remaining on board (ROB).

Loss prevention editionFeaturing articles on tanker shortage claims, the new CTU Code and the carriage of break bulk cargo.

1) Nature of the cargo.2) Heating of the cargo during carriage and at discharge.3) Unpumpable cargo: sediment/sludge.

We will discuss these factors in detail belowand provide examples of claims handled bythe Club. In all cases, and always prior toloading, it is essential that Members receiveclear instructions from charterers (andshippers, as appropriate) on the cargo,including any specific handling requirementseg when, for how long and to whattemperature to heat cargo. In turn, thoseinstructions should be provided to the master and crew.

2 Britannia RISK WATCH Volume 22: Number 1: April 2015

Loss prevention

1) Nature of the cargoIt is often the case that the inherentnature of the cargo is not properlyconsidered when fixing the ship,especially when looking at the pumpingcapabilities and the heating system ofthe ship.

MolassesMolasses is a dark, viscous by-product of thesugar refining process. Molasses may have aviscosity of several hundred centistokes (as acomparison, a very heavy lubricating oil maybe in the region of 100 centistokes). Theviscosity of molasses is affected both by drymatter content and temperature. For example,a rise in temperature of 10°C may reduce theviscosity to half (or even less) and a reductionin the dry matter content will also decreaseviscosity. Due to high viscosity and dry matterin the cargo, it can be difficult to handle thecargo with traditional centrifugal pumps and,therefore, screw pumps are best suited forhandling molasses cargo. Sometimes steam is required to help with the removal of ROB.Chartering and commercial departmentsshould be aware of these issues when fixing a molasses cargo.

Further observations:

• Heating instructions must be followedprecisely and a heating log must bemaintained.

• The temperature should be measured atseveral positions and levels in the tank asdifferent temperatures can be experiencedwithin the cargo.

• At a temperature of 40°C molasses isrelatively stable but as the temperature israised, sugar may be lost by thermaldecomposition and the cargo could be foundto be off-spec. Where temperatures over 60°Care recorded there is a heightened possibilityof thermal decomposition that could result inthe complete destruction of the cargo. Thecrew should be vigilant in monitoring thetemperature of the cargo to ensure that itdoes not exceed 40°C.

Crude oilOver the past few years there has been anincrease in the number of variations in boththe types and quality of crude oil. Traditionally,crude oil is heated when it is carried and acrude oil wash (COW) is carried out at thecompletion of discharge. However, there areexceptions, two of which were apparent fromour analysis of shortage claims where it willnot be appropriate to carry out a COW:

• Viscous/waxy cargoes – COW may lead tohigh ROB; and

• Volatile cargoes – COW causes excessive gasevolution.

Crude palm oilIn order to maximise outturn, it is usuallynecessary to sweep any residue of crude palmoil manually from the cargo tanks at the finalstage of discharge. The Club has handled ashortage claim where the shortage was due,in part at least, to the fact that the terminalrestricted this sweeping of the cargo tanks.

2) Heating of the cargo during carriageand at dischargeMany cargoes need to be maintained atspecific temperatures during the voyageand at the discharge port. The Federationof Oils, Seeds and Fats Associations(FOSFA) provides heating instructions for vegetable oil cargoes during the seavoyage and discharge operations.

In a recent case, a Member’s ship loaded2,555.942 mt of Indonesian RBD palm stearinin bulk destined for Europe. The cargo wasloaded into ship’s tank no. 3 starboard. In thiscase, the ship’s temperature records, obtainedfrom the chief officer, indicated that theFOSFA recommended temperatures weremaintained throughout the sea passage.

The cargo tanks were equipped with framocargo heaters. In order to heat the cargo, thecargo pumps are used to re-circulate thecargo through the heater until the requiredtemperature is achieved. Cargo cannot bedischarged and heated at the same time andso when cargo is being heated, dischargemust stop.

The cargo discharge was stopped twice inorder for the ship to conduct heating and re-circulation of the cargo. Despite this, thecargo temperature during discharge wasbelow the required level.

When the ROB was 50mt, the hose wasdisconnected by the terminal due to amisunderstanding between the chief mateand the terminal staff. The chief officerimmediately requested that the hose bereconnected with the intention to reload asmall quantity of the cargo from the terminalin order to warm up the remaining cargo.

Tanker shortage claims: cargo remaining on board (ROB) (continued)

Molasses Crude oil Crude palm oil

throughout the cargo (typically 1 metre ofsounding). This would ensure that theremaining cargo could be pumped, despitethe absence of heating. Discharge could thenbe completed with final stripping.

• The crew should also have consideredinternal stripping of cargo ROB into one tank.

In similar cases, the Club has noted that therehas been a high ROB due to heat loss causedby cold ballast water reaching the tank top.When ballasting, the tanks should be keptslack if possible to avoid the tank top coolingdown too quickly during discharge.

3) Unpumpable cargo: sediment/sludgeROB claims can arise from cargosediments remaining in the tank.

The Club recently handled a claim in respectof a cargo of waxy paraffinic crude oil wherethe total wax content and pour point valueswere not declared in the cargo documentsissued by the load port terminal. As aconsequence, the crew were under amisapprehension as to the nature of thecargo and they treated this cargo as if it werea waxy crude oil, heating all the cargo tanksand the slop tank in order to carry out a COW.

If the correct cargo documentation had beenavailable and had been read properly then thecrew would have realised that the propertiesof this waxy paraffinic crude oil meant thatthey did not need to carry out a COW.

3

However, on instructions from the cargoreceivers, the terminal rejected the chiefofficer’s request. The ship was then instructedby the local agent to shift to another terminalin order to discharge further parcels and toavoid both delay and expense.

The master and chief officer issued protestsbut the ship had to change berths while thecrew heated the ROB cargo. After completingdischarge of the other parcels, the masterinformed the agents that more time wasrequired to heat the ROB cargo from the firstparcel. As a result the ship was moved toanchorage.

The remaining 50mt of palm stearin cargowas discharged after several hours of heating,re-circulation, sweeping and also mopping-upof the dense/solidified product in the tankbottom, by the ship’s crew.

The delay to the ship and additional costscould have been prevented by betterpreparation of the cargo plan, includingconsideration of the nature of the ship’s cargoheating system. In addition, the dischargeshould have been carried out with more careas follows:

• As soon as the chief officer noticed areduction in the discharge rate (due to lowtemperature) discharge should have beensuspended. The cargo lines should then have been cleared and the heating system re-started, with the discharge resuming assoon as the temperature reached theminimum level required.

• This operation should have continued untilthe minimum amount of cargo remained inorder to maintain sufficient heat transfer

ConclusionMembers should always ensure that they receive clear and understandableinstructions from the charterers, whichshould include tank cleaning requirementsand tank heating instructions.

The instructions may also includereferences to particular traderequirements, such as FOSFA.

The instructions should be communicatedto the master and crew and if there is anydoubt about the exact nature of thecargo to be carried or about the voyageinstructions, then immediate clarificationshould be sought from the charterers.

In addition, before loading anddischarging the master and crew musthave full knowledge of the intendedloading/discharge plan.

Framo cargo heaters Waxy sediment/sludge at the bottom of the tank

Loss prevention

New CTU Code: improved guidelines for intermodal container packing

There has been increasing concernthroughout the intermodal transport industrythat containers are being packed many milesfrom the sea without consideration for thefact that the cargo must be properly securedfor the entire transit, including the sea voyage.The shipper has the responsibility for declaring,packing and securing the cargo. The nature ofthe transport chain can mean that once theunit is packed and sealed it may not beopened again until it reaches the consignee.

The new Code sets out to reduce damage tocargo caused by poor packing and securingwithin the CTU with the overall aim of making the supply chain safer. The Codeprovides advice about the basic principles of planning and packing of CTUs and thensecuring the cargo in accordance with theproposed transport plan. The Code alsoincludes information about the potentialcauses of cargo damage, such ascondensation and infestation.

Three UN agencies are involved (IMO, ILO and UNECE) as the Code covers the entireintermodal transport network and not justthe maritime sector. The Code includes alltypes of CTUs and is not confined toContainer Safety Convention (CSC) platedInternational Organisation for Standardisation(ISO) containers.

The Code has been drafted by a singleworking group affiliated to all three UNagencies and is available on the UNECE andILO websites (details are provided at the endof this article). The previous guidelines werehard to locate, although they did appear inthe supplement to IMDG Code. The intentionof the UN working group was to produce aCode that would be comprehensive and freelyavailable throughout the supply chain, inorder to promote its use.

Although the Code has more authority thanits predecessor guidelines, it is still not amandatory document. That said, it may beadopted into local law by nationalgovernments. Should sufficient nationalgovernments adopt the Code it could, in time,become globally mandatory in the same wayas the IMDG Code.

The Code has 13 chapters and 10 annexes.Much of the information collated in preparing the Code was considered to be too specific or likely to become out of dateand therefore was not included in the Code.This information has been designated as‘related material’ and can be updated byinterested industry bodies in the future. It is not envisaged that the Code will be updated regularly in the same manner as the IMDG Code.

4 Britannia RISK WATCH Volume 22: Number 1: April 2015

In November 2014 the ‘Guidelines for Packing Cargo Transport Units (CTUs )’ were replaced andupgraded from guidelines to a code of practice. It is now commonly known as the CTU Code. The original guidelines were produced by three UN agencies, the International MaritimeOrganisation (IMO), the International Labour Organisation(ILO) and the United Nations EconomicCommission for Europe (UNECE).

Irregular shaped packages blocked withdunnage bags

Temporary timber floorCell guides and lashing rods on a container ship

ConclusionThe Code will only become effective if it isimplemented by all parties involved inthe transport supply chain. It is mostimportant that the Code is advertised toshippers and packers of cargo. The ILO,IMO and UNECE will promote the Code. In the meantime, the UN working groupof experts felt that one of the bestmethods to achieve rapid and wideacceptance is for the container carriers to promote the Code when acceptingbookings. The ILO website link, which will give free access to the Code andAnnexes, could be placed on bookingconfirmations in order to help promotethe Code.

The ILO website includes French and Spanish versions.

The full Code is available on the following links:http://goo.gl/UYmptJhttp://goo.gl/FHQ5V6

Related material:http://goo.gl/d06LzR

Chapter 1 IntroductionScope, safety and security.

Chapter 2 DefinitionsClarifying commonly used terms in thecarriage of a CTU. This is intended to promotestandardised vocabulary used in CTU packing.

Chapter 3 Key requirements Simple concise guidance for those packingand securing cargo in CTUs.

Chapter 4 ResponsibilitiesMaking it clear who is responsible for eachaspect of the supply chain.

Chapter 5 Transport conditionsA summary of forces that each transportmode places on the cargo, includingconsideration of the extremes of temperaturethe CTU would be exposed to and thepossibility of the formation of condensationin certain climatic conditions.

Chapter 6 CTU propertiesThe properties of freight containers, regionaland domestic containers, swap bodies, roadand rail vehicles.

Chapter 7 CTU suitabilityThe necessity of selecting the correct CTUtype for differing cargoes and transport mode.

Chapter 8 Arrival checking and positioning CTU for loading/dischargingConsideration of the checks of approvalplates and internal and external checks onthe CTU prior to packing.

Chapter 9 Packing cargo into the CTUPrinciples, planning and securing.

Chapter 10 Advice when packing dangerous cargo

Chapter 11 Advice on completion of packingClosing, securing and marking the CTU.

Chapter 12 Advice on receipt and unpacking of CTUPrecautions to be undertaken, unpackingand returning the CTU to the carrier.

Chapter 13 Training: regulatory bodies This section provides for regulatory bodiesto make sure that training is given for thoseinvolved in the packing of a CTU. This will be at the discretion of each nationalgovernment to implement as they deem fit.

AnnexesThese cover a wide variety of subjects, such as detailing prevention methods for condensation and minimisingcontamination. There is also cargo specificinformation on packing and securing,packaging marks, use of friction mats and fumigation.

5

An overview of the structure of the CTU Code:

Cutting the sealCargo firmly secured to pallets by textile lashingsContainer fitted with flexitank

The Club has recently noted a number of incidents involving bulk carriers. The majority of these claimsfall into two types. The first is where the loading, stowage and securing of break bulk cargoes has beeninadequate and has led to cargo shifting and stows collapsing. As well as damage to the cargo, this hasalso led to problems with the stability of the ship. The second type is where vehicles have beenincorrectly identified as non-dangerous cargo. In this article, we look at examples of both types ofincidents and aim to provide guidance as to how such incidents can be avoided.

Members are reminded that cargo mustalways be loaded, stowed and secured inaccordance with the Code of Safe Practice forCargo Stowage and Securing (CSS Code) andthe ship’s cargo securing manual (CSM).

1) Loading, stowing and securing

There have been a number of incidentswhere vehicles and heavy project cargoeshave been stowed on top of bagged cargowhich does not always provide a firmenough base for safely stowing or securingthe heavier cargo.

Other cases have shown that wheel-basedcargoes are often secured to other cargo andnot to the ship as they should be in order tocomply with the ship’s CSM. Cargoes ofvehicles are often lashed to non-approvedlashing points on bulkheads and sometimesthey are even lashed to each other. Lashingsare not always checked and tightenedregularly and the failure of any one lashingor lashing point in the chain could mean thatvehicles in the stow shift.

It is often the case that insufficient dunnage,chocking and shoring is provided forvehicles, steel coils, project cargo andbagged cargoes when stowed together.

The crew should be aware of the followingissues at the various stages of the voyage.

Prior to carriage• A list of the proposed cargo must beobtained from the shipper/charterer,including any stowage or lashingrequirements and restrictions (SOLAS,Chapter VI, Regulation 2 and CSS Code sub-chapter 1.9).

• A risk assessment must be undertaken toassess the carriage considerations, cargocare, stowage, lashing requirements and anylimitations.

• Any ship, including a bulk carrier, that carriesbreak-bulk or general cargo is required tocarry an approved and up-to-date CSM,drawn up to a standard at least equivalent tothe IMO guidelines and which is appropriatefor all the cargoes to be carried on board thatship. If required, the CSM should be updatedto make sure that it covers the cargoproposed for carriage.

• Responsibilities for stowage and lashingshould be clarified and agreed in thecharterparty in line with the ship’s CSM, andappropriate instructions issued to the master.

• If required, a suitable port captain orsurveyor should be appointed to assist the master.

Pre-loading• Any additional lashing points in the cargoholds or on deck must be approved by theappropriate flag state administration.

• Suitable dunnage and lashing equipmentmust be provided, taking into account thedimensions and stability of the cargo, theexpected weather conditions en-route andthe requirements of the ship-specific CSM, the CSS Code and/or SOLAS, as appropriate.

During loading• All loading and lashing must be supervisedby the ship’s staff to ensure that the cargo isstowed in compliance with the approvedloading and lashing plan.

• Appropriate lashings should be attached to approved lashing points.

• Dunnage, chocking and lashing must bechecked and verified prior to signing anyrelevant documentation.

En-route• Regular checks of the cargo and lashingmust be carried out, particularly prior to andafter any heavy weather and lashings must be tightened as required.

• If any damage is noted, the owners/managers, P&I and other relevant partiesmust be notified promptly.

Stowage and lashing of vehicles stowed on topof cement cargo

General cargo loaded in a bulk carrier

Loss prevention

6 Britannia RISK WATCH Volume 22: Number 1: April 2015

Know your break bulk cargo

At the discharge port• The discharge operation should be monitoredby the ship’s staff and any damage noted andsigned for.

• Photographs and other evidence should beobtained and retained for investigation.

2) Vehicles incorrectly identified as non-dangerous cargo

The carriage of vehicles presents a potentialfire hazard which is covered by the IMDGCode UN No 3166 (including specialprovisions 961 and 962) which allows motorvehicles with fuel in their tanks for their ownpropulsion to be carried in specially designed‘vehicle spaces’. If certain criteria are met (fueltanks being empty and installed batteriesbeing protected from short circuit) thenvehicles can be accepted as non-dangerousgoods. Otherwise, the vehicles must bedeclared as Class 9 dangerous goods.

SOLAS regulation II-2/3.49 defines ‘VehicleSpaces’ as: ‘cargo spaces intended for carriageof motor vehicles with fuel in their tanks fortheir own propulsion.’

When vehicles or dangerous goods arecarried in general cargo holds or on deck, asClass 9 UN No 3166 dangerous cargo, thestowage instructions of the IMDG Code shallbe followed and stowage shall be in line withthe ship’s certificate of fitness to carrydangerous cargo (per SOLAS Reg. II-2/10).

Fire safety• Bulk carriers do not usually have fixed fireextinguishing systems fitted in cargo holds,unless they are designed for the carriage ofdangerous cargoes and provided with aDocument of Compliance for the Carriage ofDangerous Goods.

• A ship engaged in the carriage of dangerousgoods in any cargo spaces shall be providedwith a fixed carbon dioxide or inert gas fire-extinguishing system complying with theprovisions of the Fire Safety Systems Code (or equivalent).

Securing vehicles• They should be secured to the ship bylashings made of material with strength andelongation characteristics at least equivalentto steel chain or wire.

• If carried as part cargo, they should bestowed close to the ship’s side or in stowagepositions which provide plenty of securingpoints of sufficient strength or they should be block stowed from side to side in the cargo space.

• They should be stowed in a fore-and-aftdirection rather than athwartships. If stowedathwartships, additional securing of sufficientstrength may be necessary.

• Brakes should be set and the wheels blockedto prevent shifting.

Full details of how to secure vehicles iscovered by the CSS Code, Annex 4.

SummaryThe master and crew must ensure thatthey have a comprehensive workingknowledge of the stowage and securingcapabilities of their ship and that theycarry out risk assessments for all cargoescarried. Particular attention needs to begiven to the carriage of all break bulkcargoes. Where vehicles are beingcarried, proper consideration needs to begiven to the potential fire risk on board.This will require full appraisal of firehazards, including the fuel tanks andbatteries of the vehicles.

Proximity stowage of vehicles stowed on topof cement cargo

Damaged cargo at the discharge port Inadequate separation, securing and lashings

7

8 Britannia RISK WATCH RISK WATCH is published by The Britannia SteamShip Insurance Association Limited, and can befound on the publications page of the Britanniawebsite: www.britanniapandi.com

The Britannia Steam Ship Insurance AssociationLimited is happy for any of the material in Risk Watchto be reproduced but would ask that writtenpermission is obtained in advance from the Editor.

Tindall Riley (Britannia) LimitedRegis House45 King William StreetLondon EC4R 9AN

Tel +44 (0)20 7407 3588Fax +44 (0)20 7403 3942 www.britanniapandi.com

Editor’s messageWe are always looking for ways to maintain and increase the usefulness, relevance and general interest of the articleswithin Risk Watch. Please forward any comments to: rwatched@triley.co.uk

Loss prevention

A Master's Guide to Cyber SecurityWitherby Seamanship February 2015

The Guide is written in non-technicallanguage to ensure it is accessible to thosefor whom English is not their first languageand it includes an ‘aide-memoire’ to givequick, practical advice to masters. It is notUK specific and relevant to all nationalitiesof ship, operator and crew.

Maritime Cyber Security is a topic ofserious concern to the shipowningcommunity. It affects almost all areas ofship operations and has significantimplications for safety and business risk.

http://goo.gl/MZ34TW

Publications

Operating in Emission Control Areas: Part 1 The Guide 2015 Edition

Operating in Emission Control Areas: Part 2 The Manual 2015 EditionWitherby Seamanship January 2015

The January 2015 <0.1% sulphur limit inEmission Control Areas has a real impact onhow owners and operators must managetheir fleets to ensure safe, effective andcompetitive operations.

This comprehensive resource ensures shipowners and operators understand how toeffect a smooth transition and furthermoreoperate competitive, safe and cost effectiveoperations within ECAs. Produced inassociation with Lloyd’s Register, the Guidedelivers impartial, expert guidance andpractical information on all aspects ofoperating within Emission Control Areas andthe Manual provides a total reference guidefor crews on board in a durable hard cover filethat ensures crews have complete knowledgeof all procedures required for compliance.

http://goo.gl/YvYBZa

http://goo.gl/1NeBLh

Loss prevention poster campaign:COLREGs 5, 6, 19 and 35

The sixth poster in the series considers poorvisibility and the fact that in many such casesthat have been reviewed by the loss preventionteam, the ships have not sounded the fog signalas required by the rules.

The poster shows a young officer on thestarboard bridge wing who is reporting to themaster than he can neither see nor hear theapproaching ship which is 10° forward of thestarboard beam. The other ship is being plottedand is on a collision course. Both ships areproceeding at what each master considers to be a safe speed and both should, therefore, beready for immediate manoeuvre.

The master makes the decision to alter course to starboard in accordance with rule 19 as theother ship is forward of his beam and not on orabaft the starboard beam. In altering course he is making a really bold alteration. It will be veryobvious to the other ship that action has been taken.

The plot on the other ship will soon highlightthe alteration and the closest point of approachwill start increasing. Once the ship is past andclear, the plot will allow our ship to return to theoriginal track.

Rule 5 states that a good lookout should bemaintained by all available means and shouldcarry on throughout the manoeuvring process.In the poster, the young officer is shown holdingan ear trumpet which highlights the need tokeep a good listening watch for fog signals from other ships. In addition, the mastercontinues to sound the fog signal – despite thepossible disturbance for those trying to getsome rest – in order to comply with rule 35.