MARPOL compliance and distances ‘from the nearest land’

MARPOL permits unprocessed food waste to be discharged into the sea from vessels proceeding at a distance not less than 12 nautical miles from the nearest land. Sounds straightforward? Unfortunately, it is not - all coastal states do not define their ‘nearest land boundary’ in the same way.

According to Gard’s Chinese correspondent Hutatai Marine, vessels trading to China are regularly fined for non-compliance with garbage discharge provisions in Chinese waters, most often for illegal dumping of food wastes. In its circular PNI[2022]08, the correspondent explains that the Chinese requirements for discharges of food wastes are generally no stricter than those set forth in MARPOL Annex V. The main reason for being penalised is merely that vessels’ garbage procedures, and nautical charts, are not sufficiently clear on the coordinates of Chinese sea areas in which the discharge of food wastes is prohibited.

Some time ago, a Gard Member’s vessel was detained in Ningbo Port for illegally discharging food waste into Chinese waters. The vessel’s log book showed that it had been approaching Ningbo Port at the time of the alleged incident and the crew had taken all necessary precautions to ensure that the vessel was at least 12 nm from the Chinese shore before discharging any food waste.

However, we have also received reports of vessels being penalised in Australia for the same reasons, that is, for illegally discharging food waste into Australian waters. In one case, the alleged incident took place when the vessel was proceeding at 13 nautical miles (nm) from shore, or more precisely, from an island off the north-east coast of mainland Australia.

In both these cases, the vessel was positioned more than 12 nm from the respective country’s shoreline when discharging its food wastes. So why were the two vessels penalised?

MARPOL Annex V at a glance

The MARPOL Convention prohibits discharge into the sea of nearly all forms of garbage, including plastic. It does, however, contain a specific exemption for food waste. Under MARPOL Annex V, discharge into the sea of food waste is permitted while the vessel is en route and as far as practicable from the nearest land, but in any case, not less than 3 nm from the nearest land if the discharged food waste has been comminuted or ground, and not less than 12 nm for unprocessed food waste. A simplified overview of all MARPOL Annex V discharge provisions can downloaded from IMO’s Website.

Stricter discharge standards do apply in the so-called ‘Special Areas’, however, neither China nor Australia have designated any Special Areas for the purposes of MARPOL Annex V.

Nearest land under MARPOL

When discharge standards under MARPOL require you to be a specified distance from the nearest land, the term ‘from nearest land’ generally means from a country’s territorial sea baseline. There is, however, one exception to this general definition. On the north eastern coast of Australia, Australia’s nearest land boundary extends around the outer edge of the Great Barrier Reef (GBR) region and discharges permitted under MARPOL must be measured seaward of this boundary. The IMO has designated the GBR region as a particularly sensitive sea area (PSSA) and additional protection measures, such as ship routeing systems and restricted discharges, therefore apply to vessels that transit the region. The Australian Maritime Safety Authority’s (AMSA) website “Navigation through the Great Barrier Reef and Torres Strait” contains an overview of all key requirements.

It is also a fact that not all countries define their baselines in the same way. For many countries, the baseline for establishing the territorial sea is drawn at the low-water line, as stated in official charts. Perhaps the easiest way to think of a normal baseline is as an “outline” of a country’s coast. However, a number of countries have established baselines as straight lines between prominent coastal features and others claim “archipelagic status” with baselines joining outlying islands. Such countries’ baselines can therefore lie many nautical miles off their coasts.

So - getting back to why the two vessels were penalised for illegally discharging food waste into the sea:

• In the Chinese case, the crew was not aware that China has declared straight baselines along parts of its coast. In accordance with China’s Declaration of 15 May 1996, the baseline off Ningbo Port is drawn between points situated on two fairly remote islands and basically pushes the territorial sea limit further seaward. Hence, the crew had discharged food waste at a position well beyond the 12 nm limit as measured from China’s shoreline but failed to recognise that the vessel was still operating within Chinese waters. A visual map of China’s declared baselines is available here. As highlighted by our correspondent, note that partly enclosed sea areas, such as the Bohai Sea, are generally considered Chinese inland waters.  
• In the Australian case, the crew had discharged food waste at a position well beyond the 12 nm limit measured from Australia’s territorial baseline but failed to recognise that the vessel was operating within the GBR region. The exact coordinates for the GBR region is included in MARPOL’s definition of ‘nearest land’ and a visual map can be downloaded from AMSA’s website.

In both cases the crews had acted in good faith at all times and there was no attempt to deliberately circumvent the requirements of MARPOL.

Considerations and recommendations

In the two cases described above, discharges were related to MARPOL Annex V and garbage. However, other discharges from vessels controlled by the MARPOL Convention also have a minimum distance from the nearest land requirement that must be met.

Masters must make sure that environmental issues are considered in voyage and passage planning. Areas where specific marine environmental measures apply should be noted in the detailed passage plan. IMO’s circular MEPC.1/Circ.778/Rev.3 provides an overview of all Special Areas defined under MARPOL Annexes I, II and V and Emission Control Areas (ECAs) defined under MARPOL Annex VI. The circular also lists all IMO designated PSSAs and their associated protective measures.

Operators must ensure that vessel procedures, such as the Garbage Management Plan and Record Book, and nautical charts, contain all relevant information and are up to date. According to AMSA, vessels that do not carry adequate and up-to-date nautical charts may be detained and refers to this media release as an example of such a detention. Relying on unofficial charts demonstrates inadequate voyage planning under a vessel's safety management system. It may also indicate that a vessel may be in an unfit state for the voyage or poses a threat to the environment.

Vessel crews must be reminded that ’nearest land’ in MARPOL does not necessarily mean the ‘nearest shoreline’. In Australia, the nearest land boundary extends around the outer edge of the GBR region. Other countries have established baselines which lie off their coasts and it is from these baselines that the minimum distance requirements apply.

Consult your local agents if there is any doubt surrounding the baselines and any designated areas adopted locally. And remember, while discharge of food waste may be permitted, the food must not be contained in a plastic garbage bag since plastic cannot be discharged into the sea under any circumstances.

 

  

Flashback in maritime history: RENA oil spill 5th Oct 2011

 When the MV Rena container ship (owned by Greek shipping company Costamare Inc.) ran aground on Astrolabe Reef 12 miles off the coast of New Zealand's North Island, a leak of fuel and diesel oil eventually spilled 93,000 gallons into the Bay of Plenty.

The disaster killed thousands of birds, with some death estimates as high as 20,000. Some species, such as the New Zealand dotterels, were preemptively captured and sequestered for their own survival. Some dotterels weren't so lucky; a number died of respiratory infections due to the spill.

Many local residents disregarded orders from the goverment and began to organize cleanup efforts. Five thousand volunteers were involved in cleaning the bay's shoreline.

Although signs of the ship splitting in two were reported as early as Oct. 12, the Rena eventually broke apart in January. More oil was found leaking from the wreckage, but it is unknown how much more leaked into the ocean. One slick from this secondary spill stretched over one square kilometer of water.

As early spring storms lashed against the wreckage, oil continued to slowly leak from the hull. Much of the wreckage continued to be collected eight six months after the crash.

On May 25, Captain Mauro Balomaga and his navigation officer, Leonil Relon, were found guilty of operating the ship in a dangerous manner as well as changing navigation records in order to mislead investigators. They were both sentenced to seven months.

The Liberian-registered container ship Rena had left the New Zealand port of Napier at 1020 on 4 October 2011 and was bound for the New Zealand port of Tauranga. The master had given an estimated time of arrival at the Tauranga pilot station of 0300 the next day. The master calculated the estimated time of arrival by dividing the distance to go by the Rena's normal service speed. The calculation did not account for the unfavourable currents that normally prevailed down that stretch of coastline.

After departure from Napier the master learned from notes on the chart of the unfavourable currents. He then authorised the watchkeepers to deviate from the planned course lines on the chart to shorten the distance, and to search for the least unfavourable currents.

The Rena's second mate took over the watch shortly after midnight on 4 October. He calculated that the Rena would arrive at the port of Tauranga pilot station at 0300 at the ship's then current speed. Times for ships entering and leaving Tauranga Harbour are limited by the depth of water and the strength of the tidal currents in the entrance channel. Tauranga Harbour Control informed the second mate that the latest time the Rena could take the harbour pilot on board was 0300.

The planned course to the Tauranga pilot station was to pass two nautical miles north of Astrolabe Reef before making the final adjustment in course to the pilot station. The second mate decided to reduce the two miles to one mile in order to save time. The second mate then made a series of small course adjustments towards Astrolabe Reef to make the shortcut. In doing so he altered the course 5 degrees past the required track and did not make an allowance for any compass error or sideways "drift", and as a consequence the Rena was making a ground track directly for Astrolabe Reef. Meanwhile, the master had been woken and arrived on the bridge to prepare for arrival at the port.

The master and second mate discussed preparations for arrival at the pilot station. The master then assumed control of the ship, having received virtually no information on where the ship was, where it was heading, and what immediate dangers to navigation he needed to consider.

During this period of handover, no-one was monitoring the position of the ship. At 0214 the Rena ran aground at full speed on Astrolabe Reef. The ship remained stuck fast on the reef and in the ensuing months it broke in two. The aft section moved off the reef and sank. About 200 tonnes of heavy fuel oil were lost to the sea. A substantial amount of cargo in the containers was lost. The vessel became a total loss on 11 October 2011.

The Transport Accident Investigation Commission (the Commission) concluded that the Rena grounding was not in any way attributable to the malfunction of any on-board machinery or equipment, including on-board navigational equipment.

Factors that directly contributed to the grounding included the crew:

• not following standard good practice for planning and executing the voyage
• not following standard good practice for navigation watchkeeping
• not following standard good practice when taking over control of the ship.

Safety issues that the Commission identified in the wider context included: CIEL Shipmanagement S.A.'s oversight of the Rena's safety management system was not sufficient to prevent a high number of port state control deficiencies identified during two port state control "initial" inspections about three months prior to the grounding, and routine violations of some company procedures for voyage planning and navigation an independent audit had found that the Philippines' maritime education, training and certification system did not meet the mandatory standards specified in the Convention on Standards of Training, Certification and Watchkeeping for Seafarers 1978 (the STCW Convention) the current auditing protocols of the STCW Convention lack the transparency that would assist member states to decide whether other countries' training systems meet the standards of competency required by the STCW Convention, and therefore whether to recognise certificates of competency issued by those countries.

The report also discusses two other considerations that were raised during the inquiry - whether there is a need for ship routing in some form around the New Zealand coast, and how far maritime authorities should go in marking hazards to navigation such as Astrolabe Reef.

The Commission identified two issues: first, with regard to shipping, there is insufficient data being collected to make a meaningful analysis of shipping movements around the New Zealand coast; and secondly, with regard to marking hazards, a new type of "virtual aid to navigation" is being used for marking hazards to navigation before this system has been fully tested and endorsed by the International Association of Marine Aids to Navigation and Lighthouse Authorities.

The Commission made recommendations to: CIEL Shipmanagement S.A. to evaluate the effectiveness of its safety management system to ensure that the issues identified with that system as applied on board the Rena do not affect other vessels within its fleet Maritime New Zealand to promote, through the International Maritime Organization, the transparency of the system for auditing countries' seafarer training systems Maritime New Zealand to collect sufficient data on shipping movements around the New Zealand coast, and monitor and control the use of virtual aids to navigation around the New Zealand coast.

The key lessons learnt from the inquiry into this accident were: ship managers must ensure that their safety management systems are delivering safe ship operations for every ship in their fleets ships' crews must comply with the mandatory requirements and recommended best industry practice for passage planning, navigation and watchkeeping if similar groundings and other equally catastrophic maritime casualties are to be avoided countries' maritime education, training and certification systems must be capable of meeting the standards required by the STCW Convention to ensure that seafarers emerging from the system are trained to an appropriate standard.

Further details may be found by reading the FINAL report below:

https://maritimecyprus.com/wp-content/uploads/2014/12/rena_final_taic_report-1.pdf

ATSB issues fire incident report and statement for repetitive fires

 The Australian Transport Safety Bureau (ATSB) issued safety recommendations to the managers and parent company of the cargo ship BBC Rhonetal, following an investigation into a fire in the hold of the vessel at Port Hedland, Western Australia.

The incident

At 0420 Australian Western Standard Time1 on 24 March 2021, the geared general cargo ship BBC Rhonetal (Cover image) berthed at number two berth in Port Hedland, Western Australia. The ship was to discharge cargo which consisted of project cargo2 and large metal structures of various shapes and sizes.

While the ship had been at sea, the cargo had been lashed to sea fastenings; metal D-ring brackets that had been welded to the ship’s cargo areas at various locations to keep it from shifting (see the section titled Cargo securing arrangements). These fastenings needed to be removed through hot work such as cutting and gouging before the cargo could be discharged.

After arriving, the ship’s chief mate convened a safety meeting at 0430 to discuss removal of the sea fastenings using a plasma torch and to review the existing hot work risk assessment and procedure.3 This 10-minute meeting was attended by the master, chief mate, second mate, a junior officer, the bosun, two ordinary seaman (OS), two able seaman and two deck cadets. A safety meeting form was printed out and each crew member signed it to confirm their attendance. The chief mate then issued a hot work permit which was to commence at 0500 and remain in effect for the following 24-hour period.

At about 2358 on 24 March, the bosun and an OS, along with the second mate as supervisor, arrived on deck to assume the cargo watch. Shortly after, they started preparations as planned to cut the sea fastenings. In anticipation of this hot work, several crew members on the earlier watch had opened the hatch covers to number two cargo hold and prepared firefighting equipment on the tween deck in the hold.

CCTV images of the hot work with the locations indicated on the stowage plan / Credit: : Briese Schiffahrts and Pilbara Ports Authority

At 0030 on 25 March, the bosun began using the plasma torch to remove sea fastenings at the forward end of the tween deck. The cutting gradually progressed towards the aft end of the deck. Stevedores followed the bosun’s progress aft, using the ship’s crane to discharge items of cargo as the fastenings were removed. Meanwhile, the OS maintained a fire watch in the lower hold, directly below the hot work progressing on the tween deck. He was ready with a fire extinguisher, two buckets of water, a flashlight and a handheld radio. During this time, the OS saw sparks from the plasma cutting above falling into the lower hold and extinguishing before reaching the bottom of the hold. As the work continued, the second mate remained on the tween deck to supervise and oversee both the hot work and the cargo operations.

At about 0250, the bosun called the OS using a handheld radio and instructed him to conduct a final inspection of the lower hold and then go to the tween deck to assist with removing the sea fastenings. At 0300, having checked that there were no sparks or signs of fire in the lower hold, the OS started working at the forward part of the tween deck, using a grinder to remove remnants of the fastenings left after the plasma cutting.

Meanwhile, the bosun continued using the plasma torch and had progressed to the aft part of the tween deck, located above the plastic-wrapped screen assemblies in the lower hold below. At that time, sparks from the plasma cutting were spreading across a broad area. A smaller quantity of sparks was also generated by the grinding work forward.

At 0309, the second mate on the tween deck saw smoke rising from the aft part of the lower hold. The smoke intensified quickly and began billowing over the cargo hold and the wharf. The stevedores also saw the smoke and quickly left the ship, leaving behind an item of cargo on the tween deck connected to the crane hook in preparation for discharge.

At about 0312, the second mate rushed up to the navigation bridge, sounded the general alarm and made an announcement on the public address system. At about the same time, Port Hedland vessel traffic service (VTS) received a telephone call from security personnel on the wharf reporting the fire. At about 0315, the master and chief mate arrived on the bridge, and the master called VTS via VHF radio and requested harbour tugs to assist the firefighting efforts.

The crew’s attempts to extinguish the fire with hoses were unsuccessful, so the master ordered them to evacuate the hold, intending to use the ship’s fixed carbon dioxide (CO2) extinguishing system for the holds. The hatch covers, however, could not be closed due to the cargo connected to the crane’s hook. A short time later, the chief mate, wearing a self-contained breathing apparatus, climbed up to the crane operator cabin and landed the cargo onto the wharf.

At 0410, on the master’s orders, the ship’s crew closed the hatch covers and then released carbon dioxide into the hold. At about this time, the second mate began feeling unwell due to smoke inhalation and was taken to hospital.

Analysis

#1 Origin of the fire

Shortly before smoke was observed rising from the lower hold, the bosun had been cutting fastenings with a plasma torch in an area on the tween deck which was located above a vibrating screen assembly stowed in the lower hold. The screen was later identified by firefighters from the Western Australia Department of Fire and Emergency Services as the origin of the fire.

The fire started when sparks and globules of molten metal generated by the plasma cutting fell through gaps in the tween deck and down onto the screen below. The hot material swiftly melted through the protective plastic covering on the screen and then onto its combustible internal components, which ignited shortly afterwards.

#2 Fire watch

The shipboard safety management system (SMS) provided guidance for performing hot work safely. It required fire watches to be in place at all times during the work, including in adjacent compartments where appropriate, and fire rounds to be made for at least 2 hours following the conclusion of hot work.

However, the recall and reassignment of the ordinary seaman (OS) on fire watch to other duties meant that there was no fire watch in the lower hold while the bosun continued hot work activity above. At the time the OS was recalled, there was no sign of fire or smoke in the lower hold. This indicates that the fire almost certainly developed after the OS was recalled and left his post.

Had a continuous fire watch been maintained, it is likely that the sparks and molten metal falling from above would have been immediately identified and smothered by the OS before they ignited the combustible cargo. In the unlikely event that they did catch fire, the OS would have been stationed to promptly raise the alarm and attempt extinguishing the fire with the firefighting equipment at hand.

#3 Fire risk assessment 

Hot work practices on board indicated some general awareness of the fire risk associated with removing sea fastenings. This was evidenced by the completion of a hot work permit, availability and deployment of firefighting and fire prevention equipment and assigning a fire watch.

However, no efforts were made to assess or address specific fire risks associated with the flammability of vibrating screens in the lower hold. As a result, the cargo was not protected with specific, effective measures such as fire-retardant coverings and a continuous fire watch.

#4 Safety management system implementation 

The evidence shows that this fire resulted because the SMS procedure and guidance were not properly followed. A proper inspection for fire risks at the work site and surrounding areas was not undertaken. The risk assessment procedure was not followed to ensure specific risks associated with the task were identified, documented and mitigated and a continuous fire watch was not maintained for the duration of the hot work. While a safety meeting was held for the planned hot work, it was not effectively executed so as to prepare the crew for carrying out the task safely.

Non-adherence to basic safety precautions and hot work procedures have been a common factor in fires on board Briese ships. The number and frequency of these incidents in recent years, together with the circumstances of this fire, shows that the company had not effectively implemented its SMS procedures across its fleet.

Findings

From the evidence available, the following findings are made with respect to the fire within cargo hold number two on board BBC Rhonetal, Port Hedland, Western Australia on 25 March 2021.

#1 Contributing factors

• Sparks and molten metal generated from the removal of sea fastenings from the tween deck using a plasma cutting torch fell through gaps in the deck and ignited combustible cargo stowed in the cargo hold below.
• Hot work continued on the tween deck after the fire watch had been asked to leave the lower hold to perform other duties. As a result, no one was in a position to immediately identify and respond to the fire that developed in the lower hold.

#2 Other factors that increased risk

• Items of cargo stowed in the lower hold below the work site were not adequately assessed as a fire risk and protected before starting the hot work.
• BBC Rhonetal’s managers had not effectively implemented the shipboard safety management system procedures in place to prevent the fire. This was the tenth such fire on a company ship in the past 14 years, and the fourth investigated by the ATSB, identifying similar contributing factors

https://safety4sea.com/wp-content/uploads/2022/09/ATSB-Fire-onboard-BBC-Rhonetal-2022_09.pdf

Methane slip is the escape of methane gas from production

Methane slip is the escape of methane gas from production, processing, transport, operation or combustion. In terms of internal combustion (IC) engines, “methane slip” refers to the unburned methane present in IC engine exhaust emissions. The amount of methane contained in the IC engine exhaust varies greatly between engine combustion types (Otto or Diesel), specific engine designs and engine loads.

Methane is of primary concern due to its increased Global Warming Potential (GWP) over other greenhouse gases (GHGs). There are various studies on the life-cycle GHG emissions, the results of which are typically shown on a 100-year or 20-year GWP basis.

It is known that methane emissions in the atmosphere can trap solar radiation more than carbon dioxide (CO2). Methane emissions are estimated to be 84 times more severe than CO2 on a 20-year basis and 28 times more severe than CO2 over the 100-year basis by the IPCC AR5 report

According to the report, there are three primary causes of methane slip:

• Scavenging leakage
• Incomplete combustion
• Trapped methane in the combustion chamber crevices.

Scavenging leakage takes place when the methane and air mixture passes directly to the exhaust, for example when gas injection to the cylinder occurs prior to closing the exhaust valve. Incomplete combustion occurs in all IC engine types but is primarily an issue for lean burn Otto process gas engines.

As ABS says, incomplete combustion can occur for many reasons (including trapped methane, detailed below) but it is typically due to flame quenching close to the cylinder walls and extinguishing of the combustion flame at low pressure and temperature.

This is effectively fuel quenching at the coldest part of the combustion chamber while the engine is running. This results in increased methane emissions during transient operation and operation at low engine loads.

To keep combustion stable and reduce methane slip, lean burn Otto engines need to accurately control combustion between knock and misfire conditions.

Dead volumes, or crevices, within an IC engine cylinder and combustion chamber are also a source for incomplete combustion and an opportunity for methane to leak directly to the exhaust. The amount of methane slip emitted is highly dependent on the installed engine technology.

For example, high-pressure gas injection engines using the diesel combustion process in gas mode can reduce levels of methane slip to the engine exhaust more so than low-pressure engines applying the Otto combustion process in gas mode. A two-stroke engine, when compared to a four-stroke engine, is also typically more effective at reducing methane slip due to the reduced quantities of geometric gas traps.

Methane slip can be reduced by running engines at higher power output. While this is not possible in all ship propulsion and power generation arrangements, it can be used in power generation load sharing to optimize power plant operation to reduce methane emissions.

The IMO’s Intersessional Working Group on Reduction of GHG Emissions from Ships continues to consider approaches to control methane slip, which is part of the 37 Candidate Measure Proposals submitted to IMO for adoption. Options to address methane slip include direct methane emission controls or indirect means through fuel carbon factors. The engine manufacturers’ latest specifications and latest updates on the dual-fuel (DF) engine concepts regarding possible primary reductions of methane slip, should be referenced, the report concludes.

https://ww2.eagle.org/content/dam/eagle/advisories-and-debriefs/sustainability-whitepaper-lng-as-marine-fuel.pdf

Maritime Compliance: Load Lines

A ship’s waterline is the line where its hull meets the surface of the water. A load line, also called Plimsoll mark, is a marking indicating the extent to which the weight of a load may safely submerge a ship, by way of a waterline limit. It is positioned amidships on both sides of a vessel’s hull and indicates the draft of the ship and the legal limit to which a ship may be loaded for specific geographical areas and seasons of the year. The purpose of the load line is to ensure that a ship has sufficient freeboard (the height from the waterline to the main deck) and thus sufficient reserve buoyancy (volume of ship above the waterline). It should also ensure adequate stability and avoid excessive stress on the ship’s hull as a result of overloading. Ships intended for the carriage of timber deck cargo are assigned a smaller freeboard as the deck cargo provides protection against the impact of waves.

The exact location of the load line markings is calculated and/or verified by a classification society, which then issues a load line certificate.

The first international convention on load lines was adopted in 1930. It was based on the principle of reserve buoyancy. In 1966 the IMO adopted a new convention, determining the freeboard of ships by subdivision and damage stability calculations. The International Convention on Load Lines 1966 applies to all vessels engaged in international trade and determines the permitted draft/freeboard for a vessel in different climate zones and seasons, which are defined in a special international load line zones and areas map.

Load line markings are as follows:

TF           Tropic Freshwater – the deepest permitted draft considering the relatively benign weather conditions in tropical waters and the fact that the vessel floats deeper in freshwater due to lower density than in saltwater.

F              Freshwater – the deepest permitted draft in freshwater considering that the vessel floats deeper in freshwater than in saltwater.

T              Tropics – deepest permitted draft in tropical waters considering the benign weather conditions in tropical waters.

S              Summer – deepest permitted draft during summer considering benign weather conditions.

W            Winter – deepest permitted draft during winter considering rougher weather conditions.

WNA     Winter North Atlantic – deepest draft permitted considering the rough weather conditions likely to be encountered during winter in the North Atlantic.

Draft surveys

In addition to the association with reserve buoyancy and stability, load lines make it possible to determine, with reasonable accuracy by draft survey, the amount of cargo on board a ship.

A draft survey is used to determine the weight of any materials being loaded into or discharged from a vessel. It measures the displacement of the water both before and after the loading or unloading, with the resulting difference between the two displacements representing the weight of the cargo.  A draft survey is based on solid mathematics but usually involves one of the ship’s officers gauging the draft of the vessel from visual reference to the vessel’s forward, amidships and aft draft marks along with the ascertained list the vessel may have. The combination of pure science and practical experience allows the officer to calculate the amount of cargo on board to within more or less 0.5 per cent of the actual quantity.

In many ports, a draft survey is the only way of independently confirming the amount of cargo the shipper declares as having been shipped and thus the only way of checking the accuracy of the quantity stated in the bill of lading (which is normally based on the shipper’s figures) and how much cargo was on board the vessel prior to the start of discharge. 

https://maritimecyprus.com/2022/09/25/maritime-compliance-load-lines/

Maritime Risk focus: Lithium-ion Batteries - A growing Fire risk to shipping

Randall Lund, a senior marine risk consultant for AGCS, said the combination of ever-larger vessels and more hazardous cargo is leading to “astronomical” losses for insurers. Fire/explosion was the most expensive cause of loss for marine claims in 2021, accounting for 18% of US$9.2 billion in total losses, according to an analysis of 240,000 marine insurance claims over the past five years.

Lund said “without a doubt” the risk of fire at sea is going to keep growing.

“The increase in the volume of electric vehicles transiting across our oceans and the demand coming worldwide is continuing to increase,” he said. “Everybody is looking for the longest-lasting batteries. That just means there’s much more energy stored in that battery that is going to be released if something goes wrong.”

Damaged or defective lithium-ion batteries can experience a chemical reaction known as "thermal runaway" that generates heat and can ignite surrounding substances. Lund said batteries can be damaged while loading and quietly smolder without being noticed.

The vast size of modern container vessels and car carriers makes detection and firefighting more challenging. AGCS says container-carrying capacity has increased by around 1,500% since 1968 and has almost doubled over the past decade.

Lund said it can take several hours to get to the base of a fire on a container ship that has 20,000 containers on board, stacked ten high.

Fires in electric vehicles with lithium-ion batteries burn more ferociously, are difficult to extinguish and can spontaneously reignite hours or even days after they have been put out, the bulletin says.

Car carriers that are loaded and unloaded by rolling vehicles on and off them present unique safety issues that lead to “disproportionately high losses,” according to the bulletin. Lund said the batteries of electric cars are almost always carried on the bottom of the vehicles, which can strike any protrusions coming out of the vessel.

Often, fires on vessels lead to total loss. In 2021, fire was the cause of eight of 54 total losses reported, second only to foundering, with 12 losses, as the most frequent cause.

High-profile losses continued in 2022. In February, a fire that broke out on the Felicity Ace while the car carrier was crossing the Atlantic Ocean caused it to sink in 10,000 feet of water. Numerous Porsches, Bentleys and some Lamborghinis went down with the ship. Russell Group, a London-based risk consultant, estimated total losses of more than $400 million.

The cause of the fire is unknown. Lund said that is a common problem with fires started by lithium-ion batteries. The fires burn so intensely that all evidence is lost.

Lund said AGCS first issued a bulletin about the risk posed by lithium-ion batteries in 2017. He said the carrier decided to follow up on the report this month because of the growing frequency of high-dollar losses.

At present, there is no unified legislation for the safe storage of lithium-ion batteries. What’s more, fire testing has been limited because the technology is continuously evolving.

Lund said loss-control measures will improve over time and awareness about the fire risk increases. He said quite a few new products are being developed. Car carrier operators are exploring the use of “fire blankets” that can be thrown over an electric vehicle with batteries that are experiencing thermal runaways.
In the meantime, AGCS offers these tips to prevent losses:

·        Transport only batteries from reputable manufacturers to avoid substandard product, which is known to self-ignite.

·        Ensure that batteries being transported are at 30% to 50% state of charge, the exact amount depending on the manufacturer’s recommendation.

·        Beware of short circuits that can occur when the protection between the cathodes and anodes is compromised.

·        Follow packing instructions and train staff on dangerous goods recommendations.