Steamship Mutual - Oil cargo claims

Limitations on the use of oil as fuel are dealt with in the International Convention for the Safety of Life at Sea (SOLAS). Although the Convention permits the use of fuel oil with a flash point of less than 60ºC, e.g. crude oil, the arrangements on board would be subject to very rigid requirements and the complete installation must be approved by the Administration. The vast majority of ships are not, however, designed to use low flash point fuel and to do so must be considered a breach of national and international rules and regulations.

The irregular and dangerous practice of transferring cargo to bunker systems is not believed to be widespread. however, accidental contamination of fuel oil can occur and ships' personnel should be alert to such a possibility and take the necessary precautions. A risk could arise,, for example, where fuel oil bunker tanks are adjacent to cargo tanks and where, because of a bulkhead leak, volatile cargo contaminates the fuel oil.

In an accident at a repair yard when an explosion occurred in a ship's engine room killing JO workmen and injuring another 28, investigations revealed that crude oil had leaked from a cargo tank into an adjacent bunker tank where it floated on top of the heavier fuel oil. The crude oil had then been transferred together with the fuel oil into a heavy oil day tank and subsequently into a double bottom tank. Hydrocarbon vapours had escaped into the engine room where they were ignited by an oxy-acetylene torch being used for repair work. The flashpoint of the oil remaining in the double bottom tank after the explosion was found to be 4ºC.

Recommendations on the precautions to be taken to guard against such hazards will be included in the revised edition of the International Safety Guide for Oil Tankers and Terminals (ISGOTT), an extract from which reads as follows:

"In engine and boiler rooms ignition sources such as those arising from boiler operations and electrical equipment cannot be avoided. It is therefore essential to prevent the entry of flammable gases into such compartments. The contamination of bunker fuel by volatile cargo through bulkhead leaks, pipeline admixture or any other cause will introduce an additional danger. 7'he routine checking of bunker spaces for flammability by tanker and terminal personnel is therefore to be encouraged."

It is believed that if seafarers are made fully aware of the possible consequences of either deliberate or accidental contamination of fuel oil, and in particular that their lives and the lives of their shipmates are at risk, they will pay very close attention to the need to prevent such risks.

Shipowners and ship managers are therefore strongly urged to bring this report to the attention of ships personnel.

Subsequently the International Maritime Organisation issued a circular warning of the dangers in the practice whereby low flashpoint oil cargo is transferred to bunker systems for use as fuel oil. The circular referred to the Guidelines on surveys under the 1978 SOLAS protocol, in the following terms: -

The purpose of this circular is to warn member Governments of the possibility of either deliberate or accidental contamination of the bunkers by crude oil cargo with the consequential risk to persons, ships and shore installations.

The Committee recalled that paragraph 3.3.4.1.4 of the Guidelines on surveys under the 1978 SOLAS Protocol (resolution A.413(XI), as amended by resolution A.465 (XII)) requires the examination of cargo and bunker piping systems. Member Governments are urged to advise their nominated surveyors or recognised organisations to give special attention during surveys to the possibility of cross connections between the cargo and bunker piping systems.

Member Governments are also urged to advise shipowners and crew members of the need to carry out routine checks on the flammability of bunker spaces and to further advise shipowners and ship repairers that such a check should always be carried out before any "hot-work" is started in the region of bunker spaces."

As a result of these circulars, port authorities, charterers and cargo receivers are carrying out vigorous investigations of cargo shortage, including inspection of non-cargo designated spaces for traces of low flash point material. Prompt and effective response to such investigations is of great importance to the successful rebuttal of cargo shortage claims and the presence of full and accurate records on board the vessel can very quickly counter unjustified assumptions that claimants may be tempted to pursue.

Members are urged to continue to ensure that their Masters and Officers observe the following procedures;

Accurate and detailed records should be maintained of all operations involving the handling of cargo or bunkers, including cargo loading and discharging, ballasting and deballasting, and tank washing and cleaning programmes.

Tanker oil transfer books should be carried on board and be properly maintained.

Properly sealed and identified cargo and bunker samples should be retained for all voyages to provide a consistent record of the quality and characteristics of all oils taken on board, whether as bunkers or cargo.

No unrecorded oil transfers should be made any time during the voyage, however, legitimate may be the reason for these transfers.

Accurate and detailed records should be maintained of all maintenance and damage repair programmes, particularly in relation to cargo and bunker handling equipment including lines, pumps, valves and cargo measurement instrumentation.

Whenever new claims arise, the Association's Managers should be immediately advised either by contact with the Association's local representatives or with the Managers representatives in London.

Needless to say, the conversion of cargo for use as bunkers would constitute a breach of Club Rules.

Oil cargo claims - prevention

December 1985

(Sea Venture Volume 9)

TANKER CASUALTY REPORT