Global treaty to halt invasive aquatic species to enter into force in 2017

http://www.imo.org/en/MediaCentre/PressBriefings/Pages/22-BWM-.aspx

Sally Ann C – Enclosed Space Fatalities and Near Fatality

A casualty report into the enclosed space multiple deaths on board the bulk carrier Sally Ann C in March this year has been released.

It points to an incomplete safety management system (SMS), absence of warning notices in the danger spot, and "impulsive actions" as among the causes of the casualty.

The incident, which occurred on 13 March 2015 while the Isle of Man-flagged ship was on passage from San Pedro, Ivory Coast, to Dakar, Senegal, carrying a cargo of sawn timber, resulted in the deaths of the chief officer and chief engineer from asphyxiation, and serious skull injuries to the ship's second officer.

The chief officer had entered the cargo hold where the timber was stowed, and collapsed. Finding him there, the chief engineer entered the hold to rescue him. He also collapsed. The same actions were taken by the third crew member, the second officer, but fortunately a rescue operation launched by the other crew members meant that he was successfully resuscitated.

The Isle of Man Ship Registry (IMSR) report found that the ship owner, Carisbrooke Shipping, had "failed to implement a detailed key shipboard operation into its SMS, specifically in the area of enclosed space entry procedures".

While each vessel "must produce its own list as to where all the enclosed spaces are identified", the IMSR report says that at the time of the investigation "no evidence could be found that the ship possessed a record noting the whereabouts of all the enclosed spaces on board", or indeed any note indicating the number of enclosed spaces on the ship.

IMSR notes that a simulation drill was probably practiced in January, but the level of detail deployed in that drill - such as whether it had included the entry into an actual tank - could not be known as "no safe work permit or risk assessment [was] issued for that day or exercise".

Therefore it cannot be ascertained whether "actual physical training takes place on board or whether it is purely a simulation-type drill". The report also observed the absence of a "training dummy" for use during drill exercises.

In addition, the report found no evidence of specific shipboard procedures on the carriage of timber related products, or the dangers of oxygen depletion, "The existing safety management system and shipboard operational procedures do not take into account the carriage of timber related cargoes and the dangers posed by oxygen depletion."

The dangers of oxygen depletion are outlined in a table in the report, which shows the physical effects dependent upon percentage of oxygen. At 4-6%, an individual would fall into a coma in 40 seconds, and meet their death in three minutes. As part of the investigation a measure of the oxygen levels in the incident-related cargo hold access and stairway were taken using a portable oxygen meter. The report found, "One such reading indicated an oxygen level of 4.5%. The lowest observed reading was noted to be 3.5% of oxygen."

While six laminated warning and information notices on enclosed space entry were found "in the accommodation" of the ship, no notices were posted at the point of entry to the cargo hold access where the accidents occurred - either on the outside or inside of the access lid.

The behavior of the crew responding to the incident was found to be a cause for "serious concern".

"Despite" training and rescue drills, that two of the ship's officers "persisted on entering a space totally unprepared for the consequences of their actions", shows, said the report, that the "message about the dangers associated of entering such spaces has apparently still not permeated the human psyche".

However, the rescue operation by the more junior crew members was praised in the report as "quickly and effectively executed".

The IMSR states that it is satisfied Carisbrooke Shipping "have taken the appropriate steps … to amend and issue new procedures to avoid a reoccurrence of this incident" as per the report's recommendations.

Among the recommendations, Carisbrooke Shipping should review its SMS to ensure that procedures for entering enclosed spaces are included as key shipboard operations, and also review its SMS cargo operations procedures to include hazardous and/or oxygen depleting cargoes.

Recommendations to the IMSR include the re-issue of Merchant Shipping Notice No.23 Entry to enclosed spaces and the dangers posed by oxygen depletion from timber cargoes, and circulation of the current report to all Isle of Man-registered ships.

In a statement sent to IHS Maritime, Carisbrooke Shipping said it "welcomes and accepts the findings" of the IMSR casualty investigation.

The company said that the second officer injured during the accident "is at home with his family and is making steady progress in his recovery". Carisbrooke chief executive officer Robert Wester said the company "remained deeply shocked by this incident and the loss of our two valued colleagues".

The company confirmed its implementation of "all" the recommendations cited in the report including reviewing its SMS and conducting risk assessments of all enclosed spaces on its vessels.

Commenting on the report, safety expert and chairman of safety product company Salvare Worldwide, Captain Michael Lloyd, told IHS Maritime that enclosed space equipment "is still a rare commodity".

"Think what a difference a resuscitator or meaningful exercises with a proper dummy may have meant. Or a proper enclosed space management system that would prevent anyone from entering without reference to this, and would provide the data required both for entry and rescue," he said.

Around 50% of enclosed space deaths on ships are multiple tragedies. Lloyd said that while tanker and chemical carriers have made progress in stamping out the problem, the "general cargo and bulk sectors still bury their collective head in the sand and cling to the industry's motto, 'if it's not required by SOLAS, don't do it'".

He said that the latest IMO recommendation calling for all ships to audit their spaces and list them "has been totally ignored by almost all shipping companies".

Further details may be found in the report below

https://www.google.gr/?gfe_rd=cr&ei=0-uhVp6YIs-z8wfRwb6YAQ&gws_rd=ssl#q=Isle+of+Man+Ship+Registry+Enclosed+Space+Fatality+and+Near+Fatality+

Revised MARPOL requirements for oil residue (sludge) piping arrangements (REPEATED POST)

The IMO has adopted amendments to Regulation 12 of MARPOL Annex I (see Resolution MEPC.266(68)), which will enter into force on 1 January, 2017.

The amendments mean that oil residue (sludge) tanks must have no discharge connections to the bilge system, oily bilge water holding tank(s), tank top or oily water separators.

The only exceptions to this are as follows:

• Tanks may be fitted with drains (with manually operated self-closing valves and arrangements for subsequent visual monitoring of the settled water) that lead to an oily bilge water holding tank or bilge well or they may be fitted with an alternative arrangement, provided that this arrangement does not connect directly to the bilge piping system.
• The sludge tank discharge piping and bilge-water piping may be connected to a common discharge connection provided it does not allow for the transfer of sludge to the bilge system.

These requirements apply to all new and existing vessels 400 gt and above (previously, they did not apply to vessels delivered before 1 January 2014*). All ships 400 gt and above, constructed before 1 January 2017 must be arranged to comply with the requirements no later than the first renewal survey carried out on or after 1 January 2017.

It is anticipated that the biggest impact will be on existing vessels with keels laid before 31 December 1990, which may have connections between the bilge and sludge systems. Connections between designated sludge pumps and the oily water separator are not uncommon and will need to be removed.

Some examples of compliant and non-compliant arrangements are shown at the link,

http://storage.pardot.com/12702/147888/LR_MARPOL_Oil_Residue_Piping_Arrangements_August_2016.pdf

BWMC ratification comes closer

According to Finland’s Ministry of Transport and Communications, the country is about to ratify the Ballast Water Management Convention this September.

On 16 June 2016, the Finnish Government proposed President of the Republic to adopt the Convention as well as to ratify acts that lay down the provisions on the entry into force of the convention. The acts would become effective only after the convention has entered into force in Finland and internationally. Although country’s President, Sauli Niinistö, approved this proposal, the process to ratification has been delayed.

In addition, Panama’s ratification is on schedule and needs President’s approval to be incorporated into national law.

It remains to see if Finland would ratify the Convention during the month. If so, based on current figures, the Convention will come effective officially a year earlier than expected, as Finland’s 0.14 per cent of the world fleet will cover the total tonnage needed.

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