Permits to work: a seafarer’s friend

Procedures can be adequate for many jobs carried out onboard, but others require extra care due to the risks involved. Frequently, fatalities or serious injury to seafarers – or environmental, ship or cargo incidents – are caused by failing to use the Permit to Work system, or the requirements have been ignored or misunderstood when the permit has been issued. The London P&I Club has launched new LP Focus issue to address all issues related to permits to work .

A Permit to Work should be a simple formal system stating exactly what work is to be done, when it is being done and the safety controls that must be put in place to avoid injury or death. Permits are also a means of communication between those who carry out the work, the person responsible for their safety and someone who could introduce a hazard if they were unaware the work was taking place. It can also coordinate different work activities to avoid conflicts.

However, issuing a permit does not by itself, make a task safe. That can only be achieved by the thoroughness of those preparing, supervising and carrying out the work. Permits to Work come in different forms. All companies should prepare a format that is suitable for their ships, and their crews should be trained to use the permit system.

When should a permit be used?                                                                                                      

Wherever there is a high-risk job taking place, a written Permit to Work procedure should always be used. Jobs considered to be high risk should include:

·         Entry into enclosed or confined spaces

·         Working on machinery or equipment which can start automatically or requires isolation

·         Hot work including welding

·         Working aloft or overside

·         General electrical work (Under 1000 Volts)

·         Electrical high voltage work (Over 1000 Volts)

·         Working on lift machinery

Additional Permits to Work may be required depending on the trade of the ship and the work carried out. Permits can be individual or cover a number of work types.

What should a Permit to Work system cover?                                                                                                   
The following should be taken into account in a good system:

·         Human factors

·         Management of the work permit systems

·         Poorly-skilled work force

·         Unconscious and conscious incompetence

·         Objectives of the work permit system

·         Types of work permits required

·         Contents of the work permits

When does a Permit to Work fail?
Accident investigations generally find that the ship’s Permit to Work system has been utilised and a permit completed, but an accident has still happened. The most common reasons for this are:

·         Wrong type of work permit used, resulting in the hazards and precautions required not being identified

·         Incorrect information about work to be carried out and precautions not identified

·         Failure to recognise the hazards where work is carried out (e.g. flammable substances)

·         Introduction of ignition source in controlled flameproof area (e.g. welding, non-spark-proof tools, non-intrinsically safe equipment used in intrinsically safe zones)

·         Terms of work on the permit not adhered to, despite having been identified (e.g. failure to isolate plant and/or drain lines of hazardous substances)

·         Unauthorised staff performing work permit functions

·         Permit system completed incorrectly or without sufficient thought (a tick-box mentality)

·         Insufficient monitoring of the work permit system (e.g. permit out of date/time)

·         Permit to work issued for too long a period of time allowing circumstances to change

·         Prescribed permit is complicated and not properly understood

Considerations when completing a Permit to Work

·         Whether staff have been instructed, trained and are properly supervised

·         Whether the permit includes sufficient safety information, maintenance instructions, correct PPE and equipment for use

·         Whether the work permit contains sufficient information about the type of work and the environment being worked in

·         That the work is properly authorised by a responsible person

·         Human factors (stress, fatigue, shift work, attitude)

·         Whether sufficient precautions are taken prior to initiating a work permit (isolation, draining, flushing, environmental monitoring, risk assessments, communication, time allotted for the work)

·         Whether the person responsible is aware of the type of maintenance involved and how long it is likely to take

·         Whether the work permit system involves a formal procedure of any maintained equipment being handed back to operation

·         Whether all hazards have been considered

·         That all personnel are aware of the permit being issued (e.g. Bridge, Cargo room, Engine Control Room)

Company responsibilities

Shipping companies should ensure that they have in place a robust and easy-to-use Permit to Work system which is relevant to the ship. They should ensure that everyone involved in the system has been properly trained in its use and how to complete it. When visiting the ships and conducting audits, the Permit to Work system should be reviewed to ensure that it is being properly managed, and that permits are actually being used, are correctly completed and are effective. Crew should be interviewed to ensure they understand the system and whether they have any suggestions for improvement.

• Always use a Permit to Work when the job requires it
• Complete it correctly
• Think carefully when you are completing it
• Make sure it is in date and time
• Remember it could save your life or the lives of those you are responsible for

 The Loss Prevention bulletin may be downloaded at,

https://www.londonpandi.com/_common/updateable/downloads/documents/5704lpfocus5v2aug2016.pdf

Towing industry safety statistics for 2015

The U.S. Coast Guard, in partnership with the American Waterways Operators (AWO),  has released the National Quality Steering Committee’s annual safety report. The report details towing industry data and safety measures for calendar years 1994 to 2015.

The National Quality Steering Committee looks at three safety measures to track overall trends in towing vessel safety and environmental protection: 

1. Crew fatalities per 100,000 towing industry workers.
2. Gallons of oil spilled from tank barges per million gallons transported.
3. The number of towing vessel marine casualties (overall or by incident severity).

There were six crew fatalities in 2015. This translates to a projected fatality rate of seven per 100,000 workers. Three of these fatalities were the result of falls overboard. Since the beginning of the safety partnership, the committee has focused on falls overboard since they account for approximately 50 percent of towing vessel fatalities.

Approximately 147,070 gallons of oil was spilled as a result of 68 tank barge pollution incidents in 2015. This translates to a projected oil spill rate of 1.92 gallons of oil spilled, per million gallons transported. Two incidents account for 97 percent of the volume spilled. The committee has convened several working groups to address oil spills, and most recently has focused efforts to address smaller spills resulting from oil transfers.

There were 1,184 marine casualties involving towing vessels or barges in 2015.
Eighty four percent of the towing vessel casualties were classified as low severity incidents. Medium and high severity incidents represented 6 percent and 10 percent of all casualties, respectively. There was a significant decrease (34 percent) in all towing vessel casualties recorded between 2014 and 2015. This decrease may be attributed to changes in Coast Guard policy and procedures which impacted both marine casualty reporting and classification of incidents.

Further details may be found in the report at,

https://www.uscg.mil/hq/cg5/cg545/docs/CGAWO03Aug16.pdf

Caribbean MOU launches CIC on enclosed space entry

The 17 Member States and 1 Associate Member State of the Caribbean Memorandum of Understanding (CMOU) on Port State Control will launch its fourth Concentrated Inspection Campaign (CIC) with the purpose of ensuring effective procedures and measures are in place to safeguard the seafarers who are serving on board ships by checking all aspects of compliance with respect to Crew Familiarization for Enclosed Space Entry during a PSC Inspection.

This inspection campaign will be held for three months, commencing from September 1st, 2016 and ending on November 30th, 2016.

The CIC is designed to:

·         ensure that there is compliance with the requirements of the SOLAS, STCW, MLC and ILO Conventions as applicable;

·         ensure that the Masters, Officers and Crew are familiar with relevant equipment and have received training in carrying out their duties;

·         raise safety awareness among the crew serving on board;

·         ensure that the ship’s crew identify and understand the hazards associated with entry into enclosed spaces.

In practice, the CIC will mean that during a regular port State control inspection conducted under the targeting matrix criteria within the CMOU region will target aspects of compliance with respect to crew familiarisation for enclosed space entry and with the provisions of SOLAS and Chapter XI-1 regulation 7, STCW-, MLC- and ILO conventions. In addition, the CIC will include these check for vessels certified under the Safety of Commercial Vessels (SCV) Code, the Caribbean Cargo Ship Safety (CCSS) Code as well as those non-conventional certified vessels .

For this purpose, PSCO’s will apply a questionnaire listing a number of items to be covered during the Concentrated Inspection Campaign. When deficiencies are found, actions by the port State may vary from recording a deficiency and instructing the master to rectify it within a certain period to detaining the ship until serious deficiencies have been rectified.

In the case of detention, publication in the monthly detention lists of the CMOU web site will take place. It is expected that the CMOU will carry out approximately 200 inspections during the CIC.

The results of the campaign will be analysed and findings will be presented to the governing body of the CMOU for submission to the relevant IMO sub-committees.

Source: Caribbean MoU

Overview of National BW requirements amendments

The circular contains information about latest updates and amendments in National Ballast Water regulations and requirements. SQEMARINE provides an overview of the major changes in a number of national, regional and local ballast water management regulations issued lately.

The main changes presented:

·         in Australia, where a new Biosecurity Act entered into force, replacing the Quarantine Act of 1908,

·         in Canada, where the St. Lawrence Seaway Ballast Water Reporting Form has been updated,

·         in New Zealand, where the Import Health Standard – Ballast Water from All Countries has been revised, and

·         in USA where US Coast Guard’s ballast water management reporting and recordkeeping requirements have been amended.

At the same time, minor updates and changes reviewed in a number of local BW regulations. All the above mentioned updates, changes and amendments are described thoroughly below.

Australia
On 16 June 2016 a new Biosecurity Act entered into force in Australia, replacing the Quarantine Act of 1908. The main legislative change, in relation to the operation of vessels, is alignment of Australian ballast water management requirements with those in the IMO’s Ballast Water Management (BWM) Convention. The Department of Agriculture and Water Resources is the lead Australian Government agency responsible for regulating the management and discharge of international ballast water inside Australian seas (the area within 12 nautical miles of the Australian coastal baseline). Reporting processes, forms and templates also updated.

Canada
A Reporting Form should be submitted, via email, prior to entry into Canadian waters. Vessels entering the Great Lakes are requested to use the St. Lawrence Seaway Form and for all other destinations in Canada the Canadian Form. St. Lawrence Seaway Form has been updated on 24 February 2016 thus it must be used accordingly. Minor changes have been also presented regarding sampling of ballast water, information about the use of Ballast Water Management Plan and Masters’ or Operators’ commitment to keep on board a copy of each Ballast Water Reporting Form for 24 months after it is submitted.

New Zealand

New version of Import Health Standard – Ballast Water from All Countries, issued on 17 May 2016, has been published. Ministry of Primary Industries (MPI) New Zealand is the new National Monitoring Authority. Records and reporting requirements have been updated while update control measures and sampling procedures have been revised.

USA
US Coast Guard’s ballast water management reporting and recordkeeping requirements have been recently amended. The amendments of CFR §§ 151.2060 Reporting Requirements (b) through (f) and 151.2070 Recordkeeping Requirements published Nov. 24, 2015 are effective Feb. 22, 2016. Furthermore, California State Lands Commission, beginning from July 01, 2016, only accepts the new Ballast Water Management Report.

Other minor updates of local national Ballast Water Requirements may be found below

Ship managers are advised to ensure that:

·         Ballast Water Management Plans are updated, effective and properly implemented on board in accordance with national requirements.

·         Vessel’s Crew is properly trained in Ballast Water Operations through on board training.

·         Master and Designated Ballast Water Management Officer are properly instructed regarding the local National Ballast Water requirements amendments.

·         Master and Designated Ballast Water Management Officers to be instructed to consult individual country authorities before entering their jurisdiction, to ensure compliance with any relevant ballast water regulation.

You may also read

Australian BWM requirements according to Biosecurity Act 2015

http://www.green4sea.com/australian-bwm-requirements-according-to-biosecurity-act-2015/

New BW Reporting for California Ports

http://www.green4sea.com/new-bw-reporting-form-for-california-ports/

Source: SQEMARINE

Avoidable hazards can put seafarers in danger

The Standard Club is working with the Confidential Hazardous Incident Reporting Programme (CHIRP) to promote safety at sea and accident prevention. CHIRP receives reports of hazardous incidents which they investigate with the ship’s owner. The case studies and lessons learnt are published in their quarterly bulletin Maritime Feedback in both written and video form. These videos provide excellent material for discussion during a ship’s safety committee meeting.

The third bulletin looks at three hazards which put seafarers in danger. 

In the first case a large car carrier, under pilotage and with a tug attached astern, was entering a lock in poor visibility, when the engine failed to operate astern. Emergency action was taken by the bridge team. This example underlines the importance of clear briefings and pre-arrival checks between pilot and master, including testing of procedures, well in advance. The engine on this ship had failed to start twice, which should have been highlighted. Deck officers should also be involved in the design of deck layout to raise potential issues. In the second example, a ship was moored on a berth which was too small and consequently its stern lines were badly deployed. A passing passenger ship caused a dangerous surge. This incident highlights many hazards, in particular:

·         the badly chosen berth 

·         the incorrect application of stern lines

·         crew standing in the dangerous snap-back zone

In the last report, a fouled anchor on a super yacht lead to a crew member engaging in an extremely hazardous operation to clear the obstruction while the yacht was underway. The seafarer put himself in danger and there did not seem to be any supervision of the operation. Health and safety awareness should be promoted on all types of vessel, and a safety culture reinforced within the company, including safe working procedures.  

The bulletin is available for viewing,
https://www.youtube.com/watch?v=y0jnWD7viwo&feature=youtu.be

Source: The Standard P&I Club

26 hours of information recovered from El Faro’s VDR

The National Transportation Safety Board has announced the convening of a voyage data recorder group, to develop a detailed transcript of the sounds and discernible words captured on the El Faro’s bridge audio, following the audition of the ship’s VDR.

The voyage data recorder from the El Faro, a US flagged cargo ship that sank during Hurricane Joaquin in October 2015, was successfully recovered from the ocean floor Aug. 8, 2016, and transported to the NTSB’s laboratory here Aug. 12.  Information from the El Faro’s VDR was successfully recovered Aug. 15.



About 26 hours of information was recovered from the VDR, including bridge audio, navigational data, onboard radar images and wind data.  Investigators examined the VDR, found it to be in good condition, and downloaded its memory module data in accordance with the manufacturer’s recommended procedures.

Numerous events leading up to the loss of the El Faro are heard on the VDR’s audio, recorded from microphones on the ship’s bridge.  The quality of audio contains high levels of background noise.  There are times during the recording when the content of crew discussion is difficult to determine, at other times the content can be determined using advanced audio filtering.
The recording began about 5:37 a.m., Sept. 30, 2015 – about 8 hours after the El Faro departed Jacksonville, Florida, with the ship about 150 nautical miles southeast of the city.  The bridge audio from the morning of Oct. 1, captured the master and crew discussing their actions regarding flooding and the vessel’s list.  The vessel’s loss of propulsion was mentioned on the bridge audio about 6:13 a.m.  Also captured was the master speaking on the telephone, notifying shore side personnel of the vessel’s critical situation.  He also informed them he was going to send out an emergency distress signal. 

The master sounded the abandon ship alarm about 7:30 a.m., Oct. 1, 2015.  The recording ended about 10 minutes later when the El Faro was about 39 nautical miles northeast of Crooked Island, Bahamas.  These times are preliminary and subject to change and final validation by the voyage data recorder group.

The VDR group, comprised of technical experts, will continue reviewing the entire recording, including crew discussions regarding the weather situation and the operation and condition of the ship. 

Families of the El Faro’s crew were briefed about the results of the audition Wednesday prior to the NTSB’s public release of the characterization of the audition. It remains unknown how long it will take to develop the final transcript of the El Faro’s VDR.  The length of the recording and high levels of background noise will make transcript development a time consuming process. An update will be provided when warranted.

Source: NTSB

Global limitation of liability and claims for salvage costs

Two recent decisions from the Court of Appeal of The Hague have highlighted the issue of which claims fall under Articles 2(d) and (e) of the Convention on Limitation of Liability for Maritime Claims (LLMC).

Background

The first incident before the court of appeal stemmed from a collision between the inland container barge Margreta and the seagoing chemical tanker Sichem Anne in the Hollandsch Diep, an estuary of the Rhine and Meuse rivers. After the Sichem Anne hit the Margreta amidships, the container barge nearly sank due to water ingressing through a large gash in its hull. Extensive salvage operations followed, with water being pumped out of the Margreta and tugs pushing the ship off the fairway to set it aground. Cranes were also employed to lift a number of containers off the vessel. The barge owner lodged extensive damages claims – including claims for the salvage costs – against the owners of the Sichem Anne, which set up a property fund under the LLMC.

The second incident was the subject of an earlier decision from the Rotterdam court dealing with a dispute following a collision between the seagoing cargo vessel Wisdom and the barge Riad at the Oude Maas near Rotterdam. The Riad sank and the interested parties attached the Wisdom for various claims, including claims relating to salvaging the cargo from the wreck. The owner of the Wisdom also constituted a property fund under the LLMC.

LLMC

Articles 2 and 18 of the LLMC are relevant to these disputes.

The pertinent sections of Article 2 provide as follows:

"Claims subject to limitation... The following claims, whatever the basis of liability may be, shall be subject to limitation of liability:

(a) Claims in respect of loss of life or personal injury or loss of or damage to property (including damage to harbour works, basins and waterways and aids to navigation), occurring on board or in direct connexion with the operation of the ship or with salvage operations, and consequential loss resulting therefrom...

(d ) Claims in respect of the raising, removal, destruction or the rendering harmless of a ship which is sunk, wrecked, stranded or abandoned, including anything that is or has been on board such ship;

(e) Claims in respect of the removal, destruction or the rendering harmless of the cargo of the ship".

Article 18, meanwhile, provides in relevant part as follows:

"Reservations. Any State may, at the time of signature, ratification, acceptance, approval or accession, or at any time thereafter, reserve the right:

(a) To exclude the application of Article 2, paragraphs 1(d) and (e)."

The Netherlands made the reservation under Article 18 of the LLMC. Domestic law in turn provides for the possibility to establish a separate fund – commonly referred to as a 'wreck fund' – to limit liability for claims falling under Articles 2(d) and (e) of the LLMC.

Decisions

In both cases, the barge and cargo owners claimed the costs associated with salvaging the barge and cargo against the owners of the seagoing vessels, which sought to limit their liability under the LLMC. They maintained that since there was still a positive value in the property, the claims against them were in respect of salvaging efforts and therefore did not qualify as costs for wreck or cargo removal; as such, the claims did not fall under Articles 2(d) and (e) of the LLMC, but rather under Article 2(a). For obvious reasons, the owners wanted to establish only one property fund under the LLMC, under which all claims would fall, rather than also having to establish a wreck fund under domestic law.

The court of appeal disagreed, holding that the costs of salvaging the barge and cargo fell under Articles 2(d) and (e) of the LLMC, despite the fact that the property still had a positive value. The court reviewed the preparatory works of the LLMC and referred to the wording of Article 2(d), which covers all claims "in respect of the raising… of a ship which is… sunk [or] stranded…, including anything that is or has been on board such ship". It subsequently held that the remaining value of the ship or property being raised was irrelevant – only the actual activities involved were relevant. The owners therefore had to establish a separate wreck fund under Netherlands law in order to limit liability for the claims.

The court of appeal also held that Article 3 of the LLMC did not apply, as this exclusion deals only with direct claims made by salvors and not to recourse claims for salvage.

The LLMC Convention may be downloaded at,

http://www.admiraltylawguide.com/conven/limitation1976.html

Reminding of previous post the New Limits Under 1996 Protocol to LLMC 1976 to Enter Into Force June 2015 may be viewed at,

http://www.westpandi.com/globalassets/pdf/20150604-147887-new-limits-under-1996-protocol-to-llmc-1976-to-enter-into-force-june-2015.pdf

REPEATED POST - CIC Pilot Transfer Arrangement

Six (6) countries
Bahrain, Kuwait, Qatar, Saudi Arabia, Oman and UAE
of the Riyadh MoU in the Gulf Region are planning the following PSC Concentrated Inspection Campaign (CIC); 

1. Focus of CIC: Pilot Transfer Arrangement  
2. CIC period:  From 1 September 2016 to 30 November 2016 

During the campaign period, not only condition of pilot transfer arrangement, but also crew familiarization, inspection/repair records etc. will be verified in more detail as described in Press Release by Riyadh MoU

The Class NK alert may be viewed at,

http://www.classnk.or.jp/hp/pdf/tech_info/tech_img/T1082e.pdf

USCG warns how to avoid auto-pilot induced casualties

USCG has issued a safety alert to address the safe navigation of vessels with auto-pilot engaged. Auto-pilot systems can reduce the monotony of steering by freeing up the helmsman to step away from the helm in order to perform other minor pilot house tasks and gain different navigational viewpoints. There are also disadvantages that have the potential to lead to negligent navigational practices. Over-reliance on these systems can allow an operator to get too engrossed in performing other work on the bridge and, in some extreme cases, can lead to watchstanders leaving the bridge for extended periods of time. This inattentiveness to the vessel’s navigation has led to marine casualties.

In the recent past there have been numerous instances in the Gulf of Mexico where a crew boat or supply vessel and other commercial craft allided with oil rigs or structures or collided with other vessels, causing significant injuries, property damage, platform fires, and oil or gas well shut-ins. These casualties often result in serious injuries and have the potential for multiple fatalities and serious environmental damage. In the “Oil Patch” it is standard practice to engage auto-pilot systems while transiting to and from job sites both in open and in restricted waters (e.g., platform fields), often regardless of visibility. Auto-pilot induced casualties are not limited to commercial oil field vessels and casualties have occurred on other vessel types that are equipped with auto-pilot systems.

It should come as no surprise that when an inattentive operator meets with extreme circumstances, he or she usually has no time to take corrective actions. Also, in some past incidents, when there was time to take corrective action, the operator’s lack of system knowledge hindered the need to rapidly change over from auto-pilot to manual steerage mode.

Specific regulations govern the use of auto-pilots, and these regulations can be found throughout 46 Code of Federal Regulations, with specific applicability within the respective subchapters. (46 CFR 35.20-45, 46 CFR 97.16, 46 CFR 122.360, 46 CFR 131.960, and 46 CFR 185.360) The general regulation found in 46 Code of Federal Regulations reads as follows:

Use of Auto-Pilot – When the automatic pilot is used in areas of high traffic density, conditions of restricted visibility, or any other hazardous navigational situations, the master shall ensure that:

• It is possible to immediately establish manual control of the vessel’s steering;

• A competent person is ready at all times to take over steering control; and

• The changeover from automatic to manual control of the vessel’s steering and the reverse is made by, or under the supervision of, the master or officer of the watch.

The U.S. Coast Guard strongly recommends that owners and operators ensure that all credentialed mariners:

• Are fully aware of “Use of Auto-Pilot” regulations found in the vessel’s respective subchapter in 46 Code of Federal Regulations.

• Conduct periodic training to ensure that crews are properly versed in the operations and limitations of the auto-pilot system.

• Develop and prominently post written procedures on how to switch from auto-pilot to manual control in the vicinity of the auto-pilot system.

• Review company policies and evaluate setting operational limitations on the use of auto-pilot with regard to areas of high traffic density, conditions of restricted visibility, or any other hazardous navigational situations.

NOTHING exempts a vessel operator from the requirements of the International and Inland Navigation Rules of the Road. Conduct of vessels in any condition of visibility: Rule 5 – Look-Out: Every vessel shall at all times maintain a proper look-out by sight and hearing as well as by all available means appropriate in the prevailing circumstances and conditions so as to make a full appraisal of the situation and of the risk of collision.

Statutory Alert: Amendments to MLC, 2006 on financial security – Entry into force

The 2014 amendments to the Maritime Labour Convention, 2006 will come into force on 18 January 2017. The changes relate to financial security and are as follows.
Standard A2.5.2 – Financial Security

This standard requires a financial security system to be provided to assist seafarers in the event of abandonment. The standard defines abandonment as:

1. when the ship owner fails to cover the cost of the seafarer’s repatriation;
2. or when the ship owner has left the seafarer without the necessary maintenance and support; and
3. when the ship owner has otherwise unilaterally severed their ties with the seafarer, including failure to pay contractual wages for a period of at least two months.

Ships will have to carry on board a certificate or other documentary evidence of financial security issued by the financial security provider. New Appendix A2-1 will detail the information required to be on the certificate or documentary evidence.
Standard A4.2.1 – Ship owner’s Liability

This standard sets out minimum requirements for a system of financial security that assures compensation in the event of a contractual claim (see the definition under Standard A4.2.2 below). Again, ships will be required to carry a certificate or other documentary evidence of financial security issued by the financial security provider.
Standard A4.2.2 – Treatment of Contractual Claims

This standard defines ‘contractual claim’ as “any claim which relates to death or long-term disability of seafarers due to an occupational injury, illness or hazard as set out in national law, the seafarers’ employment agreement or collective agreement.” The standard also requires that effective means are in place to deal with and settle contractual claims for compensation.
Appendices A4-1 and B4-1

Appendix A4-1 details the evidence of financial security that is required. Appendix B4-1 details a model Receipt and Release Form, referred to in new Guideline B.4.2.2. Where there is more than one financial security provider for repatriation or shipowner’s liability, documentary evidence from each provider shall be carried on board.
What the changes mean for the Declaration of Maritime Labour Compliance (DMLC)

Financial security for repatriation and financial security for ship owner’s liability are both areas that have to be inspected and approved when a ship is certified in accordance with Standard A5.1.3, paragraph 1. The DMLC Part I will need to be re-issued by the flag administration and the DMLC Part II will have to be updated by the ship owner. Flag administrations have yet to confirm the form of financial security that will be acceptable but it is likely that most administrations will accept the proposal by the International Group of P & I Clubs.