International Seminar on Tanker Safety, Pollution Prevention & Spill Preparedness

International Seminar on Tanker Safety, Pollution Prevention & Spill Preparedness, Shanghai, December 2005

“Tanker Safety and Pollution Prevention”

PORT ENTRY ISSUES

Peter M Swift

Managing Director, INTERTANKO (1)

INTERTANKO members operate approximately 80% of the world’s deep-sea oil, chemical and gas fleet. They are committed to continuous improvement in performance and to cooperation with their partners and stakeholders across all of the shipping industry. Their goals are zero fatalities, zero pollution and zero detentions.

Introduction- Improving performance

More than 60% of all the oil consumed around the globe is transported by sea. Thus the world’s economies are highly dependent upon the reliable, efficient and cost-effective services provided by tanker shipping. Safety and sound environmental performance are of paramount performance to the tanker industry and its record is one of continuing improvement. A steady reduction in the number of oil spills, the amount of oil spilled and the number of serious incidents bear testimony to this.

But the industry is not complacent and is committed to maintaining and developing further initiatives aimed at improving safety performance and environmental protection. One such initiative is INTERTANKO’s “Poseidon Challenge”, which is an invitation to all participants in the Chain of Responsibility to work alongside INTERTANKO members in reinforcing a sustained commitment to continuous improvement.Based on the principle that the industry’s goals can best be achieved by voluntary, cooperative and self-motivated efforts, the Challenge stresses the importance of cooperation and emphasises that every link in the Chain is vital and must perform to the same high standard for society’s goals to be achieved, and to move our industry forward to be the best it can be.

Information sharing and analysis–Improved learning

It is widely recognised that there exists a wealth of information within the industry (and its databases) which if better reported, recorded, analysed and/or shared could be beneficially used to enhance tanker safety and pollution prevention. Regrettably however, despite the greater transparency now exhibited across much of the industry, various impediments, such as legal or commercial constraints, professional jealousy or the like frequently restrict the free exchange of such information.

INTERTANKO has therefore welcomed the participation of leading government agencies in industry’s campaign to utilise Port State Control (PSC) deficiencies and detentions records to analyse and identify particular safety and related issues. This includes the analysis of trends and the highlighting of specific factors, such as flag, classification society, cargoes, ship size and age, etc.

INTERTANKO also supports the efforts of the International Group of P&I clubs to access the inspection reports and records of classification societies, PSC and commercial vetting organisations and is currently exploring ways of making the latter more readily available. This information will undoubtedly assist underwriters in their aim of identifying poorly performing ships and operators, and in establishing economic disincentives for the substandard performers. Concurrently this should have the additional advantage of reducing the number of inspections of better quality tonnage.

In a similar vein, tanker owners have long supported the development and introduction of appropriate feedback mechanisms for ships in service to provide designers, shipbuilders (as well as classification societies) with operational experience of structures, machinery, equipment and systems. The recent support for this idea by the CESS(2) committeeof the international shipbuilders’ association JECKU(3)has therefore been welcomed, and further discussions on appropriate means of achieving this are continuing through the industry’s Tripartite dialogue between owners, shipbuilders and classification societies.

The industry is also demonstrating its ability to find solutions to safety issues through the sharing and analysing of information with the establishment of an Inter-Industry Group (IIG)(4) to investigate a number of fires and explosions that have occurred on chemical and smaller product tankers over past years. From a data base of such incidents a Working Group identified 35 that involved fires and explosions in cargo areas on tankers. It then set itself the task of identifying the root causes and establishing whether there were any common factors, with the objective of identifying corrective actions which would prevent any further such incidents. The Steering Committee of the IIG is currently evaluating the findings of the various task groups with a view to submitting a paper containing conclusions and recommendations to the IMO Maritime Safety Committee 81 for its meeting in March 2006.

As part of its efforts to better understand and subsequently help avoid tanker accidents INTERTANKO records and analyses serious incidents, as publicly reported, involving tankers. While casualty investigations can provide useful information on the causes of major accidents and hopefully lead to appropriate remedial measures to prevent re-occurrence, it is perhaps even more valuable to undertake systematic analysis of serious incidents any one of which had the potential to develop in to a significant ship casualty or environmental disaster. It is therefore unfortunate that, in the same way that there is a widespread failure of flag states and others to meet their legal responsibilities to carry out (and ideally report publicly) on casualty investigations, there is no effective industry-wide recording and analysis of serious incidents. Ideally, of course, this would extend to the (confidential) near-miss reporting of any incident within the industry which has the potential for serious consequences, as is already practised within many leading companies.

INTERTANKO’s own analysis of serious incidents involving tankers last year indicates that approximately 30% involved fires, explosions and other events such as bunkering mishaps, while approximately 20% involved hull, machinery and equipment failures. Interestingly, further analysis indicates that machinery and auxiliary machinery failure and bunker quality issues appear today to represent a greater threat to environmental safety than do hull structural failures. Collisions (including contacts with piers and docks) and groundings represent approximately 50% of all serious incidents and inevitably most of these occur at or near the berth or during port entry/departure. Thus the tanker shipping industry is putting even more focus on its inter-relationships with port service providers – for example pilots, tug operators, traffic monitoring systems, terminal operators, bunker suppliers, etc .- as well as with local maritime safety agencies.

Other Port Entry Issues

While there exist general concerns about the relatively large number of collisions, contacts and groundings involving takers, in certain parts of the world there are also specific concerns such as the relatively unregulated navigation of smaller ships and coastal craft, which routinely fail to observe standard international practices (e.g. collision regulations), language difficulties and more general communication failures with local authorities. In many ports there are also specific problems with chart accuracy, terminal facilities and operations, and inadequate reception facilities, which routinely feature in the list of port entry issues identified by tanker owners in their drive to improve the safety and environmental performance of tanker shipping.

Terminal operations and terminal vetting– safety alongside

Several years ago, following from an update of its comprehensive Port and Terminal Safety Study, INTERTANKO took the initiative to expand its terminal reporting system into an interactive Terminal Vetting Database. This database now contains over 7,000 reports and is growing rapidly, with the support of leading oil companies and other terminal operators. The purpose of this activity is to enhance overall safety and efficiency both in general and at those terminals where specific problems are encountered, as well as to reduce operator downtime. Success is achieved through the systematic identification of issues of concern, and constructive dialogue and mutual cooperation with the particular terminals.

Reception facilities

A major contribution to the reduction of marine pollution, including the avoidance of many illegal discharges, would be the provision of proper waste reception facilities – adequate in capacity and scope, affordable and readily accessible.

In this regard, INTERTANKO receives a steady flow of reports (via its Reception Facility Feedback Form) and actively follows up all on those cases (ports and/or terminals) which give most concern, frequently also sending a note to the flag administration and the regional and/or national administration,

INTERTANKO is also responsible for the development and administration of the Industry Reception Facility Forum, which enjoys wide-ranging support from the international shipping associations, as well as port authority associations and individual; ports, reception facility providers, the IMO and EMSA (European Maritime Safety Agency). Now in its second year, the Forum has been successful in ensuring that the IMO continues its focus on the issue of inadequate reception facilities and has led to the development of the IMO’s Action Plan on reception facilities. This stemmed from the more practical approach which the Forum has developed and which has resulted in more attention on practical and technical problems associated with inadequate reception facilities. In a European context the industry has welcomed the implementation of the European Directive on Reception Facilities but has growing concerns over its implementation by EU member states, noting considerable shortcomings in the detail of the Directive and its interpretation by member states.

Inspection overload

One of the major port-interface issues for many owners is the large and excessive number of inspections that tankers, in particular, are subject to – not least because of the additional burden (and consequential fatigue) they create for senior ship staff and the distractions they often cause during times of critical cargo operations. When compounded by further new pressures such as compliance with security and administrative requirements, these inspections are potentially more likely to jeopardise rather than enhance safety.

There are fundamentally three reasons for ships to be inspected - to verify the seaworthiness of the vessel, to check for compliance with statutory requirements for the ship and its manning, and to confirm the suitability of the ship for its intended commercial operation. Unfortunately however, while for most ships these inspections now involveFlag State, Port State, Classification Society, ISM and P&I, for tankers there are frequently additional inspections by OCIMF-SIRE and/or CDI, the Terminals, USCG – TVEL/LOC, PSC (extra targeting), and for older vessels by Flag State (Condition Assessment Scheme) and P&I, and frequently by class (Condition Assessment Programme).

While INTERTANKO therefore welcomes the recent proposals of the Paris MoU/EU Commission to improve the targeting of Port State Control, and to relieve better quality ships of excessive inspections, and while SIRE and CDI have adopted a degree of rationalisation to reduce the unnecessary overlap, these amount to only a small improvement.However, the introduction of the OCIMF-TMSA (Tanker Management & Self Assessment) scheme, which INTERTANKO supports, offers the prospect of some further reduction in the number of commercial inspections. Nevertheless, in the view of many, more rationalisation and greater trust between the parties and a further reduction in the number of inspections of better ships and operators coupled with more attention on the substandard, could actually result in improvements in overall safety.

International Regulation – environmental benefits

Along with the other principal shipping associations, INTERTANKO routinely argues for consistency in the governance of the global shipping industry – at the IMO, FlagState, Port and CoastalState and Classification Society Level. In particular the Association supports the introduction and prompt, uniform implementation of effective international legislation, which is “fit for purpose”, properly considered and consistent with international law.

In respect of port and coastal considerations INTERTANKO, together with others, has supported key IMO Conventions, which will enhance protection of the marine environment, in particular the Anti Fouling Convention and the Annex VI Protocol on Air Pollution and has encouraged their early entry in to force and ratification by all member states. It all supports the practical application of the Ballast Water ManagementConvention.

INTERTANKO has also voiced its fullest support for the international conventions to compensate the victims of oil, chemical and bunker spills through the IOPC Conventions and Protocols and the ratification of the HNS (Hazardous and Noxious Substances) and Bunkers Conventions

Conclusions

Tanker owners believe that port entry issues, such as highlighted above merit more attention than they routinely receive.Responsible owners and operators are committed to continuous improvement in overall safety and in the reduction of pollutionand are “striving for zero” – zero fatalities, zero pollution and zero detentions! To achieve these goals the industry has developed and implemented a series of initiatives and is embarking on others.However for these shared goals to be attained fully,it is equally important for allindustry partners to be similarly committed to continuous improvement in the performance of their respective roles.

“Working together we can make a difference.”

1.INTERTANKO = International Association of Independent Tanker Owners

INTERTANKO represents the interests of more than 240 oil and chemical tanker owners and a further 300 associate members from related companies, which meet the associations’ strict membership criteria. INTERTANKO has produced more than one hundred guides on best practice, as well as general information on the tanker industry. These include Cargo Loss, Charter Party Clauses, Charter Party Commentaries, Charter Party forms, CleanerSeas / Environmental Performance, Emergency Management and Crisis Communications, General Information and facts about the tanker industry, Port Information, Shuttle Tankers, Tanker Design and Construction, Tanker Inspection, Tanker Market and Worldscale.The Association has consultative status at the IMO, IOPC Funds and UNCTAD, and participates in the work of the OECD and IEA.

2. CESS = Committee for Expertise of Shipbuilding Specifics

3.JECKU = Shipbuilders representatives from Japan, Europe, China, Korea and the U.S.A

4.IIG =CEFIC, IACS, IAPH, ICS, INTERTANKO, IPTA, OCIMF (plus the IG of P&I in the Working Group)

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