It has become common practice to employ riding gangs to assist with onboard maintenance and other tasks – and, more recently, armed guards for the protection of the ship and its crew against piracy attacks. But, there do not appear to be any internationally accepted guidelines on the employment conditions for these gangs nor for the tasks on which they can be employed aboard ship, such that there is a risk that riding gangs can be used to bypass the regulations that apply to a ship’s crew.
The International Transport Federation (ITF) advises that riding gangs must be covered by agreements giving at least comparable rates of pay to the crew, and minimum conditions and protections.
The US Coast Guard, through their Maritime Transportation Act of 2006, defines a riding gang member as: someone who is not a registered seafarer and who does not perform watchstanding, automated engine room duty watch, or personnel safety functions; or cargo handling functions, including any activity relating to the loading or unloading of cargo, the operation of cargo-related equipment (whether or not integral to the vessel),
and the handling of mooring lines on the dock when the vessel is made fast or let go; does not serve as part of the crew complement; and is not a member of the steward’s department.
Ocean dumping is a topic that has been the subject of a good deal of public scrutiny over the last several years. Traditionally, when considering restrictions on ocean dumping in the United States the vessel operator may have customarily looked to the widely adopted provisions set forth in MARPOL 73/78. These guidelines, as drafted by the International Maritime Organization, were adopted and implemented in the United States in 1980 as part of the Act to Prevent Pollution from Ships (APPS).
However, it may not be widely known that these guidelines are superseded by a more stringent regulatory scheme known as the Ocean Dumping Act (ODA) that became law in the United States in 1972 and for which the Environmental Protection Agency (EPA) has been an absentee enforcer.
The Ocean Dumping Act, which “prohibits the transporting of any material from the United States for the purpose of dumping it into ocean waters”, was enacted to establish a “no tolerance” policy prohibiting all ocean dumping of waste from the US and was crafted in such a way as to allow the EPA substantial latitude should it decide to police the regulation. Moreover, and perhaps most importantly, the language “for the purpose of” essentially gives the EPA the right to initiate legal action even if it is found that the vessel simply acted with an intention to dump waste material from the US, which itself constitutes a violation.
In such cases the EPA has the discretion to commence civil or criminal litigation against violators and, at the extreme, punishment can result in the forfeiture of the vessel.
The ODA regulation is straightforward. Material prohibited from being dumped is classified as “waste”. Material becomes waste when it no longer has a specific purpose in the transportation of goods. An illustrative example is the function of dunnage in the bracing of steel cargo. Wood used for this purpose is “dunnage” when being used to secure the steel in transit. If the steel is discharged in the US, then the dunnage no longer serves a useful purpose and becomes “waste” from the US. “Material” is defined as matter of any kind, including but not limited to solid waste, garbage and other waste.
The US Coast Guard Captain of the Ports offices have traditionally been tasked with enforcement of ocean dumping regulations; however, historically personnel in these offices have themselves seldom been aware of ODA regulations or their supervisory role in enforcing them. In fact, on at least one occasion a vessel requested clarification from the US Coast Guard concerning dumping of material permitted by Marpol 73/78 and received permission to do so, only to discover that such action would violate the Ocean Dumping Act. The EPA have investigated and later initiated proceedings against the vessel and its crew.
Nevertheless, the EPA retains the right to become involved in an investigation at any time and in a supervisory capacity.
It should be noted that the EPA has typically abstained from an active involvement in maritime matters, and that Marpol 73/78, Annex V, while permitting the overboard discharge of certain ship-generated waste, strongly recommends that disposal be undertaken at port reception facilities.
Moreover, the EPA advises that a vessel forced to discharge waste as the result of an emergency situation endangering the vessel or the lives of the crew could become the subject of an investigation but will generally be absolved of liability. Because the US government has wide discretion in deciding whether or not to investigate, much less prosecute (“prosecutorial discretion”) possible statutory violations and because the EPA only recently has shown interest in ODA in the context of blue water merchant shipping, it is difficult to categorically say to what situations and how vigorously the US
Coast Guard or EPA may decide to apply the Ocean Dumping Act.
It is hoped that the Coast Guard’s expected publication of a new regulation and public comment thereafter will result in clarifying the intentions of the Coast Guard (and of the EPA).
Make the decision to get into sailing and chances are the first thing you’ll discover is the sheer volume of sailing courses being offered across the UK – there are quite literally thousands of them.
Not that this is a negative thing in its own right, but it does mean that those behind the courses are forced to justify themselves as key industry players and standout examples.
An explanation of the processes of dangers -
Solid bulk cargoes can shift by sliding or liquefying, and whilst the factors involved in each of these processes are different, the potentially disastrous consequences are the same – listing or capsizing and/or structural damage.
Dense cargoes, e.g. ore concentrates, have by definition a relatively high mass to volume ratio, so even a small amount of shifted cargo can have a large mass. Coupled with the momentum generated by a moving vessel considerable forces can act upon the ship’s structure.
This force will be even greater when the cargo level within the hold is above the sea level outside the hold, so that the counter-acting force of buoyancy is absent
Add to this the frequent occurrence of multiple or repetitive shifts and the result can be excessive plate flexing increasing the risk of cracking and failure.
In terms of stability, shifting cargo can have numerous consequences. The shift in cargo will cause a list if the cargo does not return to its original position with subsequent vessel movement.
Apart from increased draft concerns, the angle at which the vessel is listed will, if uncorrected, become that about which the vessel rolls. This will usually mean that the righting lever for angles of heel towards the side the vessel is listed will be less than that when the vessel is heeled from her upright position, which in turn means that the force returning the vessel from angles of heel beyond the angle of list, back to the same angle, will be less than the force returning the vessel to the upright had she not been listed.
The angle of deck edge immersion will also be closer than that for an upright vessel and if this is reached stability will also be reduced. A list will also tend to subject the vessel to greater angles of heel and this may give rise to a domino effect causing other cargo and objects to break securings and/or to shift.
Solid bulk cargoes that shift from one side of the vessel to the other with the rolling of the vessel, that is to say, cargoes behaving like a liquid in a part-filled tank, will also give rise to a Free Surface Effect, and this again will reduce the vessel’s stability in a similar way to that described above.
The gravest consequence of shifting is capsizing of the vessel, and this can happen when multiple shifts occur with little return of cargo to original positions. This process can be very quick and obviously disastrous.
Sliding occurs when the cohesive strength, or “stickiness” of the cargo, is insufficient to withstand the effects of rolling. Cohesive strength varies according to moisture content and the height of the stockpile.
A good illustration of this is provided by sand. Wet or dry there is a limit on the height of a pile of sand, but damp sand tends to permit a higher sand pile. A common example of a cargo prone to sliding is grain (The term grain includes wheat, maize, oats, rye, barley, rice, pulses and seeds.), which is particularly free flowing.
The International Maritime Organisation (IMO) Code of Safe Practice for Solid Bulk Cargoes 1991 states (at Para 184.108.40.206) that “non-cohesive bulk cargoes having an angle of repose.( The angle which the cargo naturally, and of its own accord, makes with the horizontal.) less than or equal to 30 degrees flow freely like grain and should be carried according to the provisions applicable to the stowage of grain cargoes”.
The stowage and carriage of grain is governed by the IMO Grain Rules 1982 which set out a number of requirements including specific stability criteria.
There is also some industry authority to support a theory that sliding can also occur when, due to downward moisture migration, a saturated base layer (which need not be liquefied) is formed allowing the upper, relatively drier layer, to move against it.
Liquefaction of solid bulk cargoes depends on particle size and distribution as well as moisture content. The former determines whether moisture can drain freely through the cargo, and will obviously change during a vessel’s voyage due to vibration, rolling, pitching and twisting. The effect of this movement is to break down lumps of cargo and reduce the space between particles – effectively compacting the cargo.
Moisture can then become trapped between cargo particles and if there is sufficient saturation a flow state can develop. The point at which this occurs is called the Flow Moisture Point (FMP) and is usually expressed as a percentage of the moisture content.
The IMO Bulk Cargo Code referred to above adopts what is known as the Transportable Moisture Limit (TML), and this is the maximum moisture content of a cargo deemed safe for carriage by sea in ships other than “specially designed ships”. It is defined as 90 per cent of the FMP.
Cargoes prone to liquefaction are those with a small particle size and those which contain moisture as a result of the way they are processed before loading, e.g. iron ore concentrates and coal slurry or duff (The IMO Code of Safe Practice for Solid Bulk Cargoes 1991 (as amended) lists some commodities which may liquefy).
It is perhaps worth mentioning here that solid bulk cargoes are increasingly being carried in Intermediate Bulk Containers (IBC)( An IBC may be described as a disposable or re-usable receptacle designed for the carriage of bulk commodities in parcels of 0.5 to 3.0 tonnes. They can be of rigid (e.g. fibre board) or flexible (e.g. bags) construction).The general experience with this type of carriage suggests that the dangers of shifting cargo can be just as real. Solid bulk cargoes which are prone to sliding have been known to force the sides of even rigid IBC’s to move and if there are gaps within the stow, or the sides of the stow are insufficiently shored, a general collapse of the stow can occur.
A case example – Liquefaction of scale dust
An increasingly common solid bulk cargo is dust, commonly originating from industrial chimneys. Industry has for some time been required to limit the pollutants discharged into the environment and to this end chimneys can be installed with filters.
The material collected by these filters is generally termed filter dust; material which builds up on the inner chimney surfaces also gives rise to another type of dust – scale dust. The contents of these substances vary enormously and chemical hazards are often associated with them.
This is one of the reasons why many societies in our greener world no longer allow them to be left stored and forgotten on open slag heaps or in land-fill sites.
The option to be considered in many of today’s societies is re-cycling and it is this which has, to some extent, led to the water transport of dust.
The experience with problems and dangers of watery filter dust, suggests to us that these problems and dangers are not fully understood and that essential precautions are not being adhered to.
The vessel in question loaded at Algeciras, Spain, and the scale dust in bulk was to take up most of her centre hold. The majority of the scale dust was noted by the master to be in open storage on land, unprotected from the elements, and on closer examination, was found to have a high moisture content in parts.
Whilst the master was concerned as to the state of the cargo, loading commenced, and since this took place during periods of rainfall, moisture levels increased.
No documents were produced by the shippers to record the properties of the scale dust, and when the master did raise concerns with the various cargo interests, including their surveyors, he was told that the loading of the cargo during rain, and the wetting of the cargo, was normal and of no importance with regard to the quality of the cargo.
The loading of the cargo seemed to be completed without further event or protest and clean bills of lading were issued. On the loaded passage the vessel encountered moderately heavy weather, causing heavy rolling and pitching at times. Four days into the passage a series of splashing and banging noises were heard which seemed to come from the hold containing the scale dust.
Inspection of this hold revealed that the scale dust had become fluid and was splashing violently against the hold sides. The inspection itself was not without danger as a 5 – 6 meter geyser erupted from the booby hatch opened for inspection. The resultant mess on the ship’s superstructure was the least of the worries facing the master as shortly afterwards the vessel took on a list.
Fortunately the vessel was able to compensate for this by careful and strategic ballasting and was able to reach the discharge port without further serious incident.
Further inspection at the discharge port revealed that the forces involved with the shifting of the liquefied scale dust had resulted in the penetration of the cargo into an adjacent hold under and above a moveable transverse grain bulkhead.
Problems ensued with the consignees who held the vessel liable for loss and damage to the cargo and the extra costs of discharging and storing the fluid cargo. The surveyors appointed by the owners learnt that the surveyors appointed on behalf of shippers, had issued a “certificate” of the moisture content at the loading port and given this to the consignees, but not to the master.
The certified moisture content was said to be in the region of 11 per cent but tests at the discharge port determined a moisture content of nearly double this figure.
Collision avoidance can be said to be a bit like riding a bicycle. After a (frequently) wobbly start, once people get the hang of it, the ability never leaves them. However,knowledge, understanding and the correct application of the Rules do take a little time to accomplish.
The Rules are not intended to be an intellectual challenge.They are a logical protocol designed to keep vessels apart and to provide a complete and sufficient framework, within which to defend yourself, your vessel and the lives of others.
Here then, are a few ‘tricks of the trade’:
Over the years the merchant shipping has had experience of several serious incidents involving containers shifting.
Most problems arise with containers loaded on deck, and this is not surprising as under-deck stowage is often in cell guides(There are a number of container vessels operating today with cell guides fitted on deck.)
Deck cargoes are exposed to the elements and greater transverse forces, and there are numerous things required of the carrier if deck carriage is to be successful (which also means there are numerous things that can go wrong).
Apart from deck stowage being the most common factor involved with shifting containers, the consequences of shifting on deck can be particularly wide ranging and costly.
Damage may be caused to the shifted container or other units contacted, and where this involves toppling from a stack, damage may be extreme.
This may be particularly critical if a reefer or tank container is involved. Where adjacent units are affected, a domino effect can result in a number of containers shifting and even being lost overboard.
If numerous containers are lost the vessel may be caused to list and this could lead to further shifting as well as stability problems.
Invariably the contents of lost containers will be a total loss, and added to the cost of this is the likelihood that the shipowner may be required by the State, whose waters may be affected, to carry out search and recovery (or at least pay for it, this will be particularly likely if shipping lanes are affected or there is a threat to the environment caused by the container or its contents.)
The contents of containers may also cause harm to the environment and this may lead to claims for damage to property and/or resources. State penalties and fines may be imposed.
There are numerous factors involved with the shifting of containers carried on deck
and this blog attempts to identify and discuss these.
Defective securing devices -Very often the proximate cause of containers shifting is a defect in the securing devices themselves.
Securing devices invariably receive some fairly rough treatment, and this can result in metal fatigue, fractures, breakage, excessive wearing, distortion or other damage.
Rust will readily form under the conditions experienced at sea and this process of corrosion will accelerate the weakening process.
Simple wearing can affect devices such as shoe twistlocks and base sockets to which the former fit. With such devices the edges/lips can become so worn that the twistlock can easily slip out or leave such a small degree of metal to metal contact that the excess clearance allows the containers to move.
Once this momentum is started and excessive loading results, all other securing devices can quickly fail.
Mechanical failure sometimes results from a manufacturing defect and more often than not this is associated with cheaply made devices.
Incompatible securing devices - With the multiplicity of device manufacturers and the lack of standardization, many devices are designed to be used only in conjunction with other devices of the same make.
An example of this is shoe twistlocks which are incompatible with deck sockets.
Another example is the joint use of twistlocks having either right or left handed closing levers.
In such circumstances it is very difficult to tell if the twistlock is closed or open, since in the same lever position one device would appear to be closed and the other would appear to be open. One can imagine how dangerous such a practice is.
Incorrect securing device application -Non-purpose-built containerships are frequently involved with many securing device application problems.
On such vessels steel wires are the common lashing medium, and where bulldog grips are used to either join two ends or form a loop, numerous failures have been found to occur.
Incorrect grip sizes, numbers of grips and improper grip to wire application have all contributed to these failures.
Timber chocking is popular practice on non-purpose-built containerships, principally because it is cheaper and quicker than welding restraints, e.g., I-beams or base sockets (for twistlocks).
Sometimes, however, the chocking is not secure within itself, and shipped seas in particular have a habit of breaking up the chocking arrangement.
Poor lashing angles and leads are yet another example of incorrect securing device application. This is not usually a problem on vessels designed or properly adapted
for the carriage of containers on deck, since the deck/hatch lashing points are positioned to avoid chafing and to be most effective in terms of resisting forces.
A common example of the chafing problem arising on non-purpose-built containerships is loop lashing. This is the bad practice of lashing two adjacent containers with one wire, which passes through the adjacent corner castings of each container. Such a practice may lead to the wire becoming overloaded.
Overloading can also occur where fixed securing devices, like deck eye pads, are made to hold more lashings than they can safely take. Such an arrangement is often associated with poor lashing leads, and accordingly the problem becomes compounded.
The looseness of lashings could be said to be another area of incorrect securing device application.
This can lead to a container or containers gaining momentum as mentioned above. Slack securing usually arises from stevedore/ crew laziness, poor workmanship and/ or perceived/actual time constraints, and such shortfalls are exacerbated when, through poor maintenance, devices are too stiff to operate. Common examples of this are twistlocks left in the not fully closed position and slack turnbuckles.
Of course, securing devices may also work themselves loose during a voyage, particularly in heavy weather.
The sophistication of ECDIS technology, incorporates many additional planning features that are simply not available using paper charts.
These include safety contours, click-and-drop facilities for waypoints, markers and alarms.
However, inevitably with sophisticated technology mistakes through human error as a result of lack of familiarisation or training have led to disastrous consequences.
Officers using ECDIS for passage planning should be fully confident in their ability to effectively use ECDIS, with specific emphasis on risk assessing the route for possible dangers, commonly referred to as ‘validating’ the route.
ECDIS passage planning tips -
There is a basic relationship between engine reliability and quality of fuel oil and lubricating oil.
Introduction - Hand in hand with new secondary refinery processes, which have developed during the last decades, new engine problems have emerged. It is, unfortunately, a proven fact of life that the end users often have to “pay” for technological advances, until all the links in the chain have adapted to the new parameters.
The significance of fuel oil quality in relation to the condition of an engine is obvious. But this will always have to be considered taking into account the complex system of the main parameters, such as engine/turbocharger specifications, load parameters (high/low), environment, filters, purifying systems, quality of the lubricating oil and the qualifications of the operating engineer. It is not the intention to expand on all the aforementioned aspects in this blog, but mainly to highlight the basic relation between engine reliability and quality of fuel oil/lubricating oil.
According to a Moody’s Investors Service analysis, the global shipping slump is expected to last well into 2013 as a glut of vessels and a growing credit squeeze will challenge even the toughest companies in the seaborne sector.
Shipping companies, especially in the oil tanker and dry bulk sectors, already hit by worsening economic turmoil, weak earnings and oversupply ordered in the good times, now face tighter financing as banks cut their exposure to risky and dollar denominated assets such as ship finance to meet tougher capital rules.
However, the above mentioned shipping-related crisis seems to reinforce the Greek ship-owners, who were able to save liquidity thanks to very good years they had, and to keep significant funds in their “coffers.” And now, just before overcoming the crisis, they are trying to seize the newly emerged business opportunities.