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(1)

Tanker Vetting

Tanker Operator’s perspective

Tanker Safety Forum

Jørn Andresen

General Manager DS Norden A/S

(2)

Content

 Introduction of Tanker Safety Forum (TSF)

SIRE Inspection – the moment of truth

Minimum criteria to meet under a SIRE inspection

 ”Gotcha”! – Remarks and summary

(3)

TSF - History

 2008:

 Tanker vetting e-course working group

5 tanker operators cooperating

On conclusion: Decision to continue meeting regularly

Aim: Information sharing, networking, facilitation of new projects

 2009 Official Name Adopted:

Tanker Safety Forum - TSF

 Secretariat:

(4)

TSF - Background

 All Tanker Owners and Operators with a connection to Denmark may participate

 New members and observers are accepted by consensus.

 TSF members currently operate more than 340 vessels

 TSF fully support the SIRE vetting and inspection regime as a contributor to the continuous improvement of the safety and the environmental

(5)

TSF - Facts

 TSF members are subject to 740 SIRE inspections annually (2012 + 2013)

 TSF members have an average of 4,6 observations per SIRE inspection (2013Q3 – 2014Q1)

 The individual owner/manager has exactly the same interest in elimination of risk as the individual oil major

(6)
(7)

Infamous

accidents

Leading to legislative

measures

(8)

1912 - Titanic

South of New Foundland Loss of life: > 1500 people Initiated drafting of SOLAS

(9)

1967 - Torrey Canyon

Isles of Scilly, UK Oilspill: 110.000 t Initiated drafting of MARPOL

(10)

1989 - Exxon Valdez

Prince Williams Sound, Alaska Oilspill: 41.000 t Initiated drafting of OPA90

(11)

1999 - Erika

Bay of Biscay, France Oilspill: 31.000 t 3 legislation packages in the EU to improve safety of shipping

(12)

2002 - Prestige

Off shore, Spain Oilspill: 77.000 t Initiated identification and assignment of places of refuge

(13)

SIRE background and focus

 An idea for a vetting program created in the wake of the ”Exxon Valdez” (among others incidents)

Exxon Valdez demonstrated need for change to the industry Exxon Valdez was the “smoking gun”.

 SIRE conceived to be a means to enhance and ensure SAFETY

 SIRE programme launched 1993.

 The focus of safety was and still is the common ground

Owners and operators Oil majors

Safety was and is undisputed and undisputable.

The SIRE program’s focus to achieve the target of safety has full support and

(14)

SIRE Risks ahead

 If we gradually allow focus to stray from Safety:

 Commitment amongst stakeholders will dwindle

 Ultimately the SIRE system may become unsustainable.

 Any SIRE inspection, including the good ones, has a downside – crew fatigue!

 The inspection must ensure:

 a sustainable SIRE system and,

 outweigh the downside of an inspection

(15)

TSF - Benchmarking

0,00 1,00 2,00 3,00 4,00 5,00 6,00 7,00 8,00 9,00 11Q1 11Q2 11Q3 11Q4 12Q1 12Q2 12Q3 12Q4 13Q1 13Q2 13Q3 13Q4 14Q1

Oil Majors average # of observations per inspection

(16)

The optimal SIRE inspection

Key to maintain a sustainable vetting system

 Goal

 SAFETY - universally recognized

Process

GOALBASED – scope focused to achieve the mutual goal of safety SYSTEMATIC – but adapted to ships operations and needs

 OBJECTIVE – clear grounds must be demonstrated for each finding

RESPECTFUL – on a level playing field

(17)

The poor Sire inspection

The key to erode the vetting system

 Goal

 ASSUMED to be understood

Process

EXPEDITIOUS – time is money and another inspection is pending

SYSTEMATIC – but adapted mostly to inspectors plan which ship must

accommodate

 OBJECTIVE – but frequent SUBJECTIVE views emerge where clear grounds can not be demonstrated

DISRESPECTFUL – do what I say without hesitation or argument against

findings

Some Oil Majors see challenge of an observation as manipulation of the

SIRE inspection and system

UNFAIR – formalistic focus instead of safety focus, all findings are equal, “my

(18)

Moments of truth

We are judged by what we do more than what we say...

 A SIRE inspection is a high impact event for any officer and crew member

It takes place in the home of the officer and the crew member and challenges their

competence

It requires the officer and the crew member to do double duty whilst the ship is

doing cargo operations and preparing for the next voyage leg

The company’s tradability and the officer’s and the crew member’s livelihood

depend on the good results

It is fair to assume the officer and the crew member are stressed, which should be

recognized by the SIRE inspector

Because in this moment of truth the SIRE inspector is the embodiment of the oil

major

And the oil major as a company will be judged by the SIRE inspector’s conduct  When the SIRE inspector leave the ship, its crew and its company will know

(19)

Multiple SIRE inspections

Crew fatigue

 Vessel’s on TC to an oil major suffers from double SIRE inspections compared to spot vessels. Examples:

An oil major TC vessel was inspected 20 June, 16 July, 16 August and 12

September in the same year.

An oil major TC vessel inspected 7 March, 19 August and 21 September in the

same year.

 Increased exposure to the existing arbitrary inspection regime i.e. increased risk for:

Commercial availability.

 And worse: A real risk of crew fatigue

 With fatigue, the advantages of even an optimal SIRE inspection is a decrease in safety.

The SIRE inspector should be aware of that fact and ask about recent SIRE

(20)

SIRE inspection

Suggested minimum criteria

 Opening meetings:

 Proper planning in order to plan the vetting in compliance with rest hour requirements.

The Master’s schedule should be respected.

 The recent vetting history of the vessel should also be understood and if fatigue could become an issue, appropriate consideration should be given

The inspector is in some cases requesting a junior officer to be questioned

without the presence of the Master.

The inspectors questioning technique is not always considering cross-culture

differences.

(21)

SIRE inspection

Suggested minimum criteria

 Closing meeting:

 Preferable should all audited officers and crew attend but at least all senior officers should be present.

This should be specifically requested by the inspector.

 The inspector should note any deficiencies that have been rectified during the inspection as an addendum to the observation – after all we are all interested in actual safety.

Any observations must be based on objective evidence and meet minimum criteria

for significance.

 The list of observations agreed with the Master must be final. No observations should be added after leaving the vessel.

(22)

SIRE inspection

- subjective and/or factually incorrect observations VIQ 2.9:

If the vessel is subject to the Enhanced Survey Programme, is the report file adequately maintained?

Inspector’s observation:

 The reports were not in the ESP File, and were difficult to locate in the other file.

Fact:

The location of the survey reports were inside the Class Status Reports file and

not in the ESP file. The Class Status Reports file is kept next to the ESP file. The actual presence on board of the relevant reports should supersede how it is actually filed.

(23)

VIQ 4.9:

Does the operator provide guidance on minimum under keel clearance and squat?

Inspector’s observation:

The company’s UKC policy is expressed in meters and the ship is metric. In the

inspector’s opinion it may cause confusion on board.

 Fact:

 The company has a UKC policy and as the inspector himself notes it is his opinion which is expressed i.e. directly in contradiction with the requirement for objectivity and subjective and/or factual incorrect observations therefore is the observation irrelevant. (And fathom charts still exist and many US ports and pilots still use feet which are routinely overcome by the master and

officers).

Subjective feeling on the part of the inspector. The operator does provide

guidance on UKC.

SIRE inspection

(24)

VIQ 5.49 Is the rescue boat, including its equipment and launching arrangement, in good order?

Inspector’s observation:

The rescue boat’s painter was made of synthetic rope instead of manila. It was

reported rectified before the inspector left the vessel.

According to the LSA code 5.1.2.2.5 must “a painter of sufficient length and

strength” be a part of the rescue boat equipment. There is no requirement for the material of the painter in the LSA code.

Subsequently the observation is irrelevant.

SIRE inspection

(25)

VIQ 11.49:

Has the emergency steering gear been tested within the past three months and are the results recorded?

Inspector’s observation:

 The last two Emergency steering drills were completed in interval exceeding three months. It was the last done on 9 January and 24 April 2013.

Fact:

All drills are held according to a schedule set out in the company SMS. The

emergency steering drills must be held 4 times a year in January, April, July and October. This ensures compliance with the 3 monthly SOLAS requirement.

SIRE inspection

(26)

VIQ 12.12:

Is deck lighting adequate?

Inspector’s observation:

One flood light observed unlit on foremast (forward facing).

The observation is objectively correct but does not contribute to the safety or the

environmental protection. All other deck lights were fully functional i.e. no suggestion for a systematic issue on board.

SIRE inspection

(27)

Summary

 Poorly conducted SIRE inspections will undermine the noble intention of the system.

Once an observation is in a SIRE report it proves difficult or even impossible to

have it removed no matter how erroneous or subjective it is.

Subsequently: We support and expect our masters to seek full understanding of

the foundation for the issue raised and challenge any questionable observation. We as owner or operator expect objectivity with clear reference to the legislation, the guidelines and best industry practices.

TSF Members will continue to contribute to the improvement and development of

the industry quality and safety standards through our engagement in national and international professional bodies.

Clearly the SIRE inspectors hold the key to unlock the full safety – potential of the

(28)

Commercial impact

An inspector’s performance gives an average of 14 observations per inspection

 The fleet average is 4.15 observations per inspections.

The inspector’s latest performance was 10 observations.

The vessel in question had previously been inspected twice by the same Oil Major

with 2 and 4 raised observations.

The vessel has an average of 3.75 observations on 4 SIRE inspections within the

last 15 months.

The observation number alone following the inspector’s inspections may cause the

vessel to fail third party oil major screenings.

It is acknowledged that the inspector’s attitude on board is professional with no

(29)

Additional examples for self

study

Sire inspection

subjective and/or factually incorrect

observations

(30)
(31)

Sire inspection

subjective and/or factually incorrect observations

VIQ 3.12 Does the operator’s Drug and Alcohol policy meet

OCIMF guidelines?

Inspector’s observation:

On board D&A tests were only carried out on the officers and

ratings.

The company’s drug and alcohol policy and procedures for the

compliance with the policy are in compliance with the OCIMF

guidelines. The entire crew is alcohol tested monthly by the master

witnessed by two crewmembers. This monthly test is initiated by the

company on a randomly picked date with short (1 hour) response time.

Further the officers and two randomly picked ratings drug and alcohol

tested bi-annually by a shore based company.

The combination of the two test systems clearly exceeds the OCIMF

guidelines.

(32)

Sire inspection

subjective and/or factually incorrect observations

6.14 Are means available for dealing with small oil spills?

Inspector’s observation:

The container for storing the oil spill equipment located on

the catwalk of the was found cracked on the top of cover.

However the vessel has a canvas cover to protect it from

water ingress and was used at sea.

The observation is objectively correct but does not

contribute to the safety or the environmental

protection.

The observation should not have been raised as the

(33)

Sire inspection

subjective and/or factually incorrect observations

VIQ 4.1 Is the vessel provided with adequate operator’s navigation

instructions and procedures?

Inspector’s observation:

The 2

nd

officer was unable to explain the difference between ground

stabilized and sea stabilized operation of the radar. On being asked

whether the sea stabilized is to be used for anti-collision or position

fixing, he did not know the difference and mentioned the radars

functions are interchangeable. The company procedures 7.1.16 stand

that calculation of CPA/TCPA the input must be speed through water.

The setting of the radar was in compliance with the company’s procedures

and as such correct. The 2ndofficer correctly explained that it should be in

the sea stabilized position.

(34)

Sire inspection

subjective and/or factually incorrect observations

VIQ 5.14 Are lifeboat and fire drills regularly held?

Inspector’s observation:

Last 3 launchings of free-fall lifeboat (March 2013,

December 2012, September 2012) had been by davit;

SOLAS required that at least one of these should have

been a free-fall launch or simulated launch.

Lifeboat Free Fall Launching or Simulated Launching is

a part of the PMS and latest record is 10th of March

2013. The wording used is “Tested Emergency Release

Device, Job Order in Consultas - 501.023.01.04”.

The inspector did not agree on the wording and raised

(35)

Sire inspection

subjective and/or factually incorrect observations

VIQ 2.3 Does the Operator’s representative visit the vessel at least

bi-annually?

Inspector’s observation:

the last technical inspection was dated October 10

th

2012.

As per company policy is the vessel visited at least twice annually.

The vessel has been visited 10 October 2012 by a technical

superintendent, 19 January 2013 by a QA manager (marine

superintendent), 15 July 2013 by a QA manager and 22 July 2013 by

a QA manager. This was demonstrated to the inspector but for

unknown reasons only the technical visit was recorded in the

observation list which caused the inspector to maintain the

observation.

The observation is irrelevant as the requirement for bi-annual visit

is complied with.

(36)

Sire inspection

subjective and/or factually incorrect observations

VIQ 5.49 Is the rescue boat, including its equipment and

launching arrangement, in good order?

Inspector’s observation:

The rescue boat’s painter was made of synthetic rope

instead of manila. It was reported rectified before the

inspector left the vessel.

According to the LSA code 5.1.2.2.5 must “

a painter of

sufficient length and strength

” be a part of the rescue

boat equipment. There is no requirement for the

material of the painter in the LSA code.

(37)

Sire inspection

subjective and/or factually incorrect observations

VIQ 6.41 Has the Garbage Record Book been correctly completed?

Inspector’s observation:

The whole row of entries for incineration had been filled in both at the

start and the end of incineration i.e. double entries, double quantities,

potential confusion with authorities etc. (the sort of thing that goes

down well in certain ports where authorities are looking for an excuse

to create difficulties).

The garbage record book (example next slide) has a column labeled

“estimated amount discharged or incinerated”, then the columns

“to sea”, “to reception facility” and “incineration”. As it is

interpreted here and confirmed by the flag state the total amount

must be entered in the first column and how it is

discharged/incinerated in the three other columns. If all the

garbage e.g. has been incinerated the amount in column one and

four will be the same i.e. the sum of the three latter columns must

be equal to the amount stated the first column.

(38)

Example of garbage record book

(39)

Sire inspection

subjective and/or factually incorrect observations

VIQ 8.27 Are the remote and local temperature and pressure

sensors and gauges in good order and is there recorded

evidence of regular testing?

Inspector’s observation:

There were 3 levels of temperature sensors in the cargo tanks.

The records of the sensor comparisons showed an average figure of the sensor readings, compared against the UTI tape. 

The temperature sensors are checked against the UTI which

is calibrated annually. The position of the vapour lock does

not make it possible to have the UTI probe lowered in the

vicinity of the temperature sensors horizontally. During the

checks is the UTI probe lowered to the centre vertically and

compared to the average of the 3 sensors and if the

difference is less than 1 deg. C it is anticipated as OK.

The observation is irrelevant as the requirement for check

of the temperature sensors is complied with.

(40)

Sire inspection

subjective and/or factually incorrect observations

VIQ 8.77 Are the manifolds in good order?

Inspector’s observation:

The manifold system was not in compliance with the OCIMF

recommendations as the aft vapour return connection was not the

aftermost connection, there was the diesel oil bunker connection

aft of the vapour return connection.

Reading “OCIMF Recommendation for oil tanker manifolds and

associated equipment” section 9.6 “Other connections” the diesel

oil connection should only be “... in close proximity of the cargo and

bunker manifolds ...” i.e. it is interpreted not to be a part of the

manifold in the definition of the mentioned publication and

subsequently there is no specific requirement to that the vapour

line must be the aft of the “other lines”.

(41)

Sire inspection

subjective and/or factually incorrect observations

VIQ 11.11 Does the operator subscribe to a fuel, lubricating

and hydraulic oil testing programme, and is there a procedure

in place to take into account the results?

Inspector’s observation:

Steering gear and Diesel generator lube oil analysis was showing

caution and vessel had taken mitigation measures by a near

miss report.

The observation is objectively correct but does not

contribute to the safety or the environmental protection.

The observation should not have been raised as procedure

is in place to take into account the results and complied

with as the inspector observes.

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