Information Sharing Bulletin - Premudasqems.premuda.net/Premuda Bulletin/15.pdfin order to improve either the basic knowledge of SIRE VIQ and its requirements, either the control on

Dear Premuda's fellows,Dear Premuda's fellows,Dear Premuda's fellows,Dear Premuda's fellows,

Another year is ended and hopefully our efforts in providing analysis, comments, information related (but not limited) to safety, vetting, envi-ronmental, commercial issues have been useful to all readers!

By this number, we devoted the “Remarks to be shared” to the safety related matters.

Each publication, from this one onward, will deal with a specific matter under the safety “umbrella”.

The Academic Lesson continues the excursus of the MARPOL history, especially highlighting mat-ters related to the new requirements of the USA, namely the Environmental Compliance Plan and the negotiation of a plea agreement, these two matters being strictly linked to the Vessel Gen-eral Permit.

The latest introduction of the Vessel General Permit in USA and inspections on board by the US Coast Guard expected to be enforced by early next year, have made the Company to de-cide to organize some courses dealing the mat-ter and mainly addressed to the ship/shore per-sonnel. Courses were held in November this year with a good participation of Company personnel.

As far as the commercial section is related, the carriage of steel cargoes and their implication still continue to be dealt with. Survey procedure explanation and descriptions are briefly intro-duced too and will continue to be analysed with next issue.

The vetting section is highlighting a more posi-tive period in comparison to the previous period examined. This thanks to the efforts provided by the Masters and ship staff on board: neverthe-less to say, it’s of top importance for vessels to be vetted and approved by the major number of

The selected closed casesThe selected closed casesThe selected closed casesThe selected closed cases

In this Issue:

• Mobile phones: the concerns for their use on board

• Commercial issues: some words again about the carriage

of steel cargoes.

• Safety issues: The correct maintenance of liferafts

• The Academic Lesson: Environmental compliance plan

Information Sharing Bulletin

is published by:

Premuda SpA - SQE Dept.

Email: [email protected]

Collection of selected Collection of selected Collection of selected Collection of selected

closed cases closed cases closed cases closed cases

Vetting IssuesVetting IssuesVetting IssuesVetting Issues

Commercial issuesCommercial issuesCommercial issuesCommercial issues

Remarks to be sharedRemarks to be sharedRemarks to be sharedRemarks to be shared

Lesson’s bearingLesson’s bearingLesson’s bearingLesson’s bearing

Information Sharing Bulletin

Summary:Summary:Summary:Summary:

§ Hazardous occurrence caused by hazards not properly evidenced § Hazardous occurrence caused by hazards not properly evidenced § Hazardous occurrence caused by hazards not properly evidenced § Hazardous occurrence caused by hazards not properly evidenced

§ A case of cargo contained spill from the PV valves § A case of cargo contained spill from the PV valves § A case of cargo contained spill from the PV valves § A case of cargo contained spill from the PV valves

§ A potential threat to safety § A potential threat to safety § A potential threat to safety § A potential threat to safety

§ A contained oil spill due to break of the Framo line§ A contained oil spill due to break of the Framo line§ A contained oil spill due to break of the Framo line§ A contained oil spill due to break of the Framo line

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Lesson LearnedLesson LearnedLesson LearnedLesson Learned

Issue n° 15

December 2010

MOCs in order to remain in the shipping busi-ness. In a period of “rough seas”, every excuse can be taken by Charterers to put the vessel off hire or to early terminate the contract.

Good reading to everyone!

G. Mortola

Academic lessonAcademic lessonAcademic lessonAcademic lesson

The analyzed occurrence can represent, for any vessel of Premuda fleet, a possible threat to

safety. An effective signaling of mooring lines crossing the deck, has a double function: the

most immediate a concrete is to avoid any possible stumbling or hit onto wires, due to low

visibility of the same, the second purpose is to draw crew’s attention to the potential dan-

gers of the zone in case of snap back of the wire. Present issue is usually highly regarded

by vetting surveyors.

Selected closed cases

Page 2

Selected closed cases

Page 3

Selected closed cases

Page 4

The occurrence in object is a typical example of (sometimes abused

term) lack of safety culture. The lack on which the hazardous occur-

rence is based comes out from very common and routine activity, but

could have been catastrophic consequences in case of a real fire

emergency. Present example show the importance of a deeply

rooted safety culture: hazards can raise also from common activities,

and in these circumstances the most effective way to minimize them

is are well established safe and proactive behavior.

Pagina 5

Page 5

Selected closed cases

The occurrence give us the opportunity to recall the attention to the environmental objectives established

by the Company for the current year and in particular to the aim of minimize contained spills to a maxi-

mum of two per vessel. It must be highlighted that any similar occurrence is to be considered a warning of

a potential pollution, then the efforts made to comply with the objective are not addressed to the achieve-

ment of mere numerical result but to the fulfillment of an important aspect of Company Philosophy.

Pagina 6

Page 6

Vetting Issues

Four Island:Four Island:Four Island:Four Island: Vessel performed a SIRE Inspection with BHPBBHPBBHPBBHPB ---- R i g h t Sh i p , R i g h t Sh i p , R i g h t Sh i p , R i g h t Sh i p , F u j a i r a h F u j a i r a h F u j a i r a h F u j a i r a h 13/12/2010 (5 NO)13/12/2010 (5 NO)13/12/2010 (5 NO)13/12/2010 (5 NO), , , , with positive result. Next SIRE inspection to be performed with Shell in January 2011. Results are good and everyone is waiting for possibility to can-cel the SHELL rejec-tion due do SIRE fail-ure dated June 2010.

For this purpose an Indian team has been embarked to prepare vessel at best. To be remarked anyway the good

job done by Captain Rodolico in leading all the actions we run on the ves-sel following the failures. FramuraFramuraFramuraFramura Vessel performed a SIRE Inspection with Shell, Fu-Shell, Fu-Shell, Fu-Shell, Fu-

jairah 05/09/2010 (7 NO)jairah 05/09/2010 (7 NO)jairah 05/09/2010 (7 NO)jairah 05/09/2010 (7 NO), with positive result. ExxonMobil referred to Shell SIRE Report, as well as Chev-ron, deferring inspection to Jan. 2011. Then vessel performed a SIRE Inspection with BHPBBHPBBHPBBHPB----RightShip, Fujairah RightShip, Fujairah RightShip, Fujairah RightShip, Fujairah 29/12/2010 (14 NO)29/12/2010 (14 NO)29/12/2010 (14 NO)29/12/2010 (14 NO), with positive result. Results are good but the trend is drastically negative as in my opinion the outcome of the BHPB SIRE was barely ac-ceptable and subject to negative analysis by third part. In the next quarter vessel is expected to perform SIRE with BP and then SHELL/CHEVRON at March to confirm the three sister SHELL/CHEVRON EXXON acceptance.

Four Moon:Four Moon:Four Moon:Four Moon: Vessel has been to repair Yard for Intermediate and CAP since end of October to end of the year. No SIRE inspection performed during this period. Vessel is expected to recover the best preparation in terms of vessel

Dear all,

We are here commenting results achieved by Premuda ves-sels on Vetting issue mainly in reference to: SIRE Reports performed during SeptemberSIRE Reports performed during SeptemberSIRE Reports performed during SeptemberSIRE Reports performed during September————December December December December 2010201020102010

Following last tremendous quarter already detailed in the last report, Vetting issues changed the course to positive with nine (9) SIRE inspections and one (1) Safety inspection (Repsol, in Cartagena on M/T Four Smile) carried out with final positive assessments.

As everybody well know, the last WIN-TEC 31 (issue 11/10), reviewed after ITM consultancy given on board of two of fleet vessels (namely the Four Island and the Four Bay) and verification of the Office vetting management process, put the attention to vessels readiness to SIRE inspections and mainly to following points:

• Timed advise to Vessel Master of intention to perform a SIRE at next discharging port: this, in in order to allow more time to preparation.

1 Request to perform an internal self-assessment based on SIRE VIQ, on which the Captain or any Senior Deck Officer is auditing the Officer in charge for the specific Chapter. Same for C/E and Engine Officer (mainly on Chapter 11), in order to improve either the basic knowledge of SIRE VIQ and its requirements, either the control on any issue related.

2 The request for any observation received to perform a dedicated CAR and mainly to report with pictures before and after CAR completed so that the reply to OCIMF could be better addressed and explained.

3 The needing to report the observation closing and mainly NCR arisen from analysis of the CARs if any.

Resuming, the Working Instruction is concentrated on two aspects:

1. Prepare the vessel and Staff as much as possible to re-quested items.

2. Be precise as much as possible in case of any observa-tion in order to clear the root causing it.

Four BayFour BayFour BayFour Bay Vessel started again the Vetting activity after the Special Survey and CAP completed in October. In order to recover a good situation, a Croatian team has been embarked to perform maintenance of Main Deck and fittings since departure from Yard for a complete month. Vessel performed a SIRE Inspection with BHPBBHPBBHPBBHPB----RightShip, RightShip, RightShip, RightShip, Bin Qasim 16/11/2010 (4 NO)Bin Qasim 16/11/2010 (4 NO)Bin Qasim 16/11/2010 (4 NO)Bin Qasim 16/11/2010 (4 NO), with positive result, then with Shell, Bin Qasim 30/11/2010 (4 NO)Shell, Bin Qasim 30/11/2010 (4 NO)Shell, Bin Qasim 30/11/2010 (4 NO)Shell, Bin Qasim 30/11/2010 (4 NO), with positive re-sult. Next SIRE inspection scheduled to be performed with BP in January 2011. Results are good.

Pagina 7

Page 7

Vetting Issues

cosmetic and Staff readiness in order to clear SHELL out-standing.

Four SmileFour SmileFour SmileFour Smile Vessel performed a SIRE Inspection with BHPBBHPBBHPBBHPB----RightShip, RightShip, RightShip, RightShip,

S i n g a p o r e S i n g a p o r e S i n g a p o r e S i n g a p o r e 09/10/2010 (10 09/10/2010 (10 09/10/2010 (10 09/10/2010 (10 NO)NO)NO)NO), with positive result, then with Repsol, Cartagena Repsol, Cartagena Repsol, Cartagena Repsol, Cartagena 24/11/2010 (19 24/11/2010 (19 24/11/2010 (19 24/11/2010 (19 NO)NO)NO)NO), , , , with positive result, but no SIRE Report issued. Shell accepted vessel referring to BHPB-RightShip SIRE dd. 9 Oct. 2010 defer-ring inspection until April 2011, as well as Chevron, defer-ring inspection to February 2011.

Vessel is performing well either if trend is not very clear. In fact REPSOL Safety inspection performed still under Capt.

Rainò, before changing over to Capt Albamonte, was barely acceptable and forcing the Technical Dept. to several activities in order to address and close few observations that if left open would not lead the vessel to an approval. So the action must be fol-lowed in order to have the vessel always at the best

performance. Expected SHELL/CHEVRON in-spection at next discharge in Cart-agena.

Four WindFour WindFour WindFour Wind Vessel performed a SIRE Inspection w i t h B HPBBHPBBHPBBHPB ----RightShip, Tor-RightShip, Tor-RightShip, Tor-RightShip, Tor-bay 23/11/2010 (4 NO)bay 23/11/2010 (4 NO)bay 23/11/2010 (4 NO)bay 23/11/2010 (4 NO), with positive result, then with Shell, Amsterdam 19/12/2010 (6 NO),Shell, Amsterdam 19/12/2010 (6 NO),Shell, Amsterdam 19/12/2010 (6 NO),Shell, Amsterdam 19/12/2010 (6 NO), with positive result. BP referred to Shell SIRE Report dd. 19 December 2010, inspection not required until 19 December 2011. Vessel is performing good even if the target for these new vessels should be not to get any observation over few ones (maximum 3/4). Four SkyFour SkyFour SkyFour Sky Vessel performed a SIRE inspection with Statoil, Southwold Statoil, Southwold Statoil, Southwold Statoil, Southwold OPL 26/11/2010 (4 NO)OPL 26/11/2010 (4 NO)OPL 26/11/2010 (4 NO)OPL 26/11/2010 (4 NO), with positive result. ExxonMobil referred to Statoil SIRE Report, while Chevron referred to Shell SIRE Rep. dd. 24 March 2010 and other SIRE Reports, as well as BP, deferring inspection until 24 March 2011. Vessel is performing good. The target for these new vessels should be not to get any observation over few ones à maxi-mum 3/4. Bulk CarriersBulk CarriersBulk CarriersBulk Carriers

Four SpringsFour SpringsFour SpringsFour Springs Vessel is subject to RIGHTSHIP vetting due to the possibility to perform voyages in Australia. Last inspection has been performed by RIGHTSHIP, at Ha-RIGHTSHIP, at Ha-RIGHTSHIP, at Ha-RIGHTSHIP, at Ha-dong Korea on 08/11/2010 (10 No).dong Korea on 08/11/2010 (10 No).dong Korea on 08/11/2010 (10 No).dong Korea on 08/11/2010 (10 No). Result has been ex-tremely positive as the vessel has been awarded by 5 stars, top of marking for RIGHTSHIP marking. This position must be held for the next annual inspection to be prepared for next 10/2011. By M. Leveratto

Pagina 8

Page 8

Commercial Issues

“The carriage of steel cargo: “The carriage of steel cargo: “The carriage of steel cargo: “The carriage of steel cargo:

some guidelines” some guidelines” some guidelines” some guidelines”

Dear all,

Some more information related to the carriage of steel car-goes…

Cargo CareCargo CareCargo CareCargo Care

• Steel cargoes are easily damaged by salt water. Before loading, test hatch covers for water tightness and repair the covers if leakage is found. After loading and closing hatch covers, apply cross joint wedges before hatch skirt cleats. Additional protection, such as sealing foam and tape, can be applied along hatch cover cross-joints in exposed areas. Avoid loading ballast in wing tanks when holds contain steel. Ballast should be carried only fro trim and stability purposes, and propeller immersion.

• During the voyage, control the dew point in the cargo hold by ventilation.

• Take daily dew point temperatures of hold and outside air with a wet and dry bulb thermometer. Ventilate when the dew point of outside air is less than the dew point of hold air. This will normally occur when cargo is loaded in warmer conditions for delivery to a port (or passage through an area) with colder conditions.

• Keep detailed records of hold and outside air tempera-ture, at the load port, during the voyage and at the dis-charge port. Record times of hold ventilation and of heat-ing fuel in tanks adjacent to holds loaded with steel

Steel cargo surveysSteel cargo surveysSteel cargo surveysSteel cargo surveys

Shipowners have an obligation to cargo receivers to deliver cargo in the same apparent condition as loaded (shipped).

Finished steel products can suffer physical damage or rust-ing during transit to the port or during storage at the port.

Finished steel is most problematic because, at the dis-charge port, it is difficult to determine whether the damage occurred before loading or while on board.

Consequently, it is essential to examine finished steel for defects before loading and to identify and record any dam-age or rusting. This information is needed to prove to cargo

receivers that such damage occurred prior to shipment and not on board the ship.

The P&I Clubs usually arrange preloading surveys of fin-ished steel as a means of preventing shipowners facing pre-shipment cargo damage claims where damage occurred before loading.

Generally, Clubs will only want to survey finished steel which includes:

• Hot or cold-rolled steel coils • Steel wire coils • Steel plate, bars, profiles, channels, angles and joists • Sheet steel • Steel pipes Finished steel excludes:

• Steel billets, ingots, blooms and ore • Semi finished steel slabs • Scrap steel • Steel re-bars

Survey procedureSurvey procedureSurvey procedureSurvey procedure

Preloading steel surveys are usually undertaken by survey-ors appointed by the P&I Clubs.

The surveyor has number of duties: the most important is to examine cargo for damage and to advise the master on suitable clauses to endorse on the mate’s receipts and Bill of lading.

However, Surveyor should also examine the ship’s hatch covers, cargo holds and observe stowage, pointing out to the master any hatch cover defects that could give rise to leakage and any other aspect of stowahe that appears in-correct. By G. Mortola CONTINUE ON NEXT ISSUECONTINUE ON NEXT ISSUECONTINUE ON NEXT ISSUECONTINUE ON NEXT ISSUE

Remarks to be shared

Page 9

Dear All,

WELCOME INTO THE SAFETY PAGE!WELCOME INTO THE SAFETY PAGE!WELCOME INTO THE SAFETY PAGE!WELCOME INTO THE SAFETY PAGE! In this issue, we will deal and underline items that can be object of PSC remarks:

LIFEBOATSLIFEBOATSLIFEBOATSLIFEBOATS Lifeboats cleaning and their correct maintenance is the right way to pre-vent any future remarks by PSC In-spectors. Always remember that all belts belts belts belts and hookshookshookshooks shall be well lubricated. Belts Belts Belts Belts have to be well cleaned and all seatsseatsseatsseats shall be marked as indicated by the SOLAS.

The air releasing system air releasing system air releasing system air releasing system and cylinder shall be well cleaned and maintained: all IMO signs IMO signs IMO signs IMO signs are to be correctly posted, including all the engine instructions.

One more important safety aspect that many times is noted by Class and PSC surveyor during their inspections: all life-life-life-life-boat windows boat windows boat windows boat windows should be kept in good condition. When the operator is unable to see through the window, the latter must be replaced immediately. Do not forget propeller grid propeller grid propeller grid propeller grid and lifeboats protection brack-brack-brack-brack-ets : ets : ets : ets : also these parts are inspected by the Surveyor so they must be kept well maintained. Finally, which brakes and Jacob ladder supports shall not be rusted.

All ship staff shall have well in mind the importance to have All ship staff shall have well in mind the importance to have All ship staff shall have well in mind the importance to have All ship staff shall have well in mind the importance to have all safety equipments well maintained.all safety equipments well maintained.all safety equipments well maintained.all safety equipments well maintained.

Another safety matter will be dealt with next Bulletin: good reading to all!Another safety matter will be dealt with next Bulletin: good reading to all!Another safety matter will be dealt with next Bulletin: good reading to all!Another safety matter will be dealt with next Bulletin: good reading to all!

LIFEBOAT: CORRECT MAINTENANCE TO PREVENT PSC REMARKSLIFEBOAT: CORRECT MAINTENANCE TO PREVENT PSC REMARKSLIFEBOAT: CORRECT MAINTENANCE TO PREVENT PSC REMARKSLIFEBOAT: CORRECT MAINTENANCE TO PREVENT PSC REMARKS

Lesson’s Bearing

Page 10

CRACK DOWN ON CREW USE OF CELL PHONESCRACK DOWN ON CREW USE OF CELL PHONESCRACK DOWN ON CREW USE OF CELL PHONESCRACK DOWN ON CREW USE OF CELL PHONES

Two marine collisions occurred in 2009 involving U.S. Two marine collisions occurred in 2009 involving U.S. Two marine collisions occurred in 2009 involving U.S. Two marine collisions occurred in 2009 involving U.S. Coast Guard shoreCoast Guard shoreCoast Guard shoreCoast Guard shore----based boats and other vessels, resulted in based boats and other vessels, resulted in based boats and other vessels, resulted in based boats and other vessels, resulted in serious injuries and one death. Those occurrences have led serious injuries and one death. Those occurrences have led serious injuries and one death. Those occurrences have led serious injuries and one death. Those occurrences have led several coastal authorities to issue recommendations to several coastal authorities to issue recommendations to several coastal authorities to issue recommendations to several coastal authorities to issue recommendations to

avoid the inappropriate use of mobile phones.avoid the inappropriate use of mobile phones.avoid the inappropriate use of mobile phones.avoid the inappropriate use of mobile phones.

There is growing concern that the use of mobile phones at inappropri-There is growing concern that the use of mobile phones at inappropri-There is growing concern that the use of mobile phones at inappropri-There is growing concern that the use of mobile phones at inappropri-ate times is distracting Bridge Management Teams from their primary ate times is distracting Bridge Management Teams from their primary ate times is distracting Bridge Management Teams from their primary ate times is distracting Bridge Management Teams from their primary duties of navigating and conning their vessel. duties of navigating and conning their vessel. duties of navigating and conning their vessel. duties of navigating and conning their vessel.

Key PointsKey PointsKey PointsKey Points

• Interference, in this context, relates to the distraction caused by making or re-ceiving mobile phone calls at inappropriate times during the conduct of the ves-sel’s navigation and conning.

• Such activity is liable to demand the attention of bridge personnel when full at-tention should be devoted to the safe and efficient navigation of the vessel.

• Many individuals and organisations with business with the vessel, expect an in-stant response to their phone calls without being aware of the demands this places on the personnel responsible for the vessel’s safe navigation.

• Ship operators are recommended to have procedures in place, in the vessel’s Safety Management System, as part of International Safety Management (ISM) Code compliance, to regulate the usage of mobile phone on ships’ bridges.

• Consideration should also be given to prohibiting all mobile phone usage when navigational requirements demand the individual attention of all those respon-sible for the safe conduct of the vessel.

Pagina 11

Page 11

The Academic Lesson

“MARPOL: a brief excursus”“MARPOL: a brief excursus”“MARPOL: a brief excursus”“MARPOL: a brief excursus”

Environmental Compliance PlanEnvironmental Compliance PlanEnvironmental Compliance PlanEnvironmental Compliance Plan

During previous issues, we briefly de-

scribed the Environmental Compliance Environmental Compliance Environmental Compliance Environmental Compliance

PlanPlanPlanPlan and the effects a Marpol violation

has for US laws.

But how can ship operators can avoid to be embroiled in

this story of fines, prohibition and imprisonment?

The obvious answer would be to negotiate a plea bargain a plea bargain a plea bargain a plea bargain

with the DoJDoJDoJDoJ (Department

of Justice).

Obviously, a signed ECP signed ECP signed ECP signed ECP

(Environmental Compli-

ance Plan) is a condition condition condition condition

to negotiate a plea to negotiate a plea to negotiate a plea to negotiate a plea

agreementagreementagreementagreement.

A close analysis of the

ECPs that have been

negotiated with the DoJ

provides a useful insight

into the best practice

standards required to minimise exposure to prosecution or

provide evidence in mitigation of any fines that are im-

posed.

ECPs are public documents and can be obtained from the

relevant court or from a US law firm which has access to

such records in electronic form.

ECPs forms vary from case to case depending upon the

nature of the ship operating entity and the size of the fleet.

However, all are designed to reflect best practice with re-

gard to waste management on board and the prevention of

pollution. The emphasis is very much on company culturecompany culturecompany culturecompany culture,

management controls management controls management controls management controls and effective verification and audit effective verification and audit effective verification and audit effective verification and audit

procedures.procedures.procedures.procedures.

The ECP addresses the following issues:

• Environmental Management System;Environmental Management System;Environmental Management System;Environmental Management System;

• Organisation and CultureOrganisation and CultureOrganisation and CultureOrganisation and Culture

• Technical RequirementsTechnical RequirementsTechnical RequirementsTechnical Requirements

• AuditingAuditingAuditingAuditing

Below, we start briefly to explain each single issue, which

will be continued with next publications of the Information

Sharing Bulletin.

Environmental Management SystemEnvironmental Management SystemEnvironmental Management SystemEnvironmental Management System

Under the Environmental Management SystemEnvironmental Management SystemEnvironmental Management SystemEnvironmental Management System, following

points will be analysed:

• Planning and Implementation; • Training; • Documentation; • Core values.

The EMS requires an environmental policy statement outlin-

ing compliance with environmental requirements compliance with environmental requirements compliance with environmental requirements compliance with environmental requirements whether

statutory, regulatory or voluntary and a commitment to con-

tinuous improvement in environmental performance.

The EMS must contain time frames for achieving compli-

ance with environmental requirements and reducing the risk

of potential pollution from all waste stream, and must be

updated as requirements change.

Planning and implementationPlanning and implementationPlanning and implementationPlanning and implementation

Sufficient resources must be applied to meet the objectives meet the objectives meet the objectives meet the objectives

and targets setand targets setand targets setand targets set, and the EMS will have to describe the re-

sponsibilities of the ship’s crew and shoreside personnel

together with third-party service providers.

Procedures must be established for receiving and address-

ing concerns raised by employees regarding environmental

performance and compliance.

All shipboard operations that may have an impact on envi-

ronmental compliance should be identified and managed

with the view to achieving the EMS targets.

Any occurrence that may affect the ship operator’s ability to

achieve these targets should be documented and ad-

dressed, including accident or emergency situations.

Finally, there should be testing and evaluation of the emer-

gency procedures.

Selected by P. Linari

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Premuda, founded in 1907, is one of the most expe-

rienced shipping Company with the mission of tran-

sporting oil and dry-bulk cargoes.

The Company operates also in the FPSO market.

Premuda holds the most qualified certifications in

Safety, Environmental protection, Quality and Secu-

rity standards.

Premuda S.p.A

Via Fieschi 3/21

I—16121, Genova

Tel.: +39 010 5444.421

Fax: +39 010 5444.313

E-mail: [email protected]

There are no shortcuts to

safety, and everyone has to

contribute