Tanker Vetting Tanker Operator s perspective

Transcription

1 Tanker Vetting Tanker Operator s perspective Tanker Safety Forum Jørn Andresen General Manager DS Norden A/S Technical Department DPA, Head of QA Section

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 More Examples of SIRE Remarks for self study

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: Marstal Navigationsskole E-Learning

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 performance of our vessels

5 TSF - Facts TSF members are subject to 740 SIRE inspections annually ( ) 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 TSF - Members

7 Infamous accidents Leading to legislative measures

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

9 Torrey Canyon Isles of Scilly, UK Oilspill: t Initiated drafting of MARPOL

10 Exxon Valdez Prince Williams Sound, Alaska Oilspill: t Initiated drafting of OPA90 First time a charter shared the responsibility for the accident.

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

12 Prestige Off shore, Spain Oilspill: 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 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 attention of any Owner and any crew.

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 Every inspection must hit the target of SAFETY

15 TSF - Benchmarking 9,00 8,00 7,00 6,00 5,00 4,00 3,00 2,00 1,00 0,00 Oil Majors average # of observations per inspection 11Q1 11Q2 11Q3 11Q4 12Q1 12Q2 12Q3 12Q4 13Q1 13Q2 13Q3 13Q4 14Q1 BP SHELL TOTAL LUKOIL SIS3 Others ALL

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 FAIR as opposed to petty and formalistic

17 The poor Sire inspection The key to erode the vetting system Goal Process ASSUMED to be understood 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 eyes have seen it and no need for a closing meeting.

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 precisely what the oil major really stands for

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 inspections at the opening meeting

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. Examples of officers feeling intimidated by the SIRE inspector.

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: Fact: The reports were not in the ESP File, and were difficult to locate in the other file. 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. The ESP was adequately maintained.

23 SIRE inspection - subjective and/or factually incorrect observations VIQ 4.9: Does the operator provide guidance on minimum under keel clearance and squat? Inspector s observation: Fact: 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. 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.

24 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 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.

25 SIRE inspection - subjective and/or factually incorrect observations VIQ 11.49: Has the emergency steering gear been tested within the past three months and are the results recorded? Inspector s observation: Fact: The last two Emergency steering drills were completed in interval exceeding three months. It was the last done on 9 January and 24 April 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.

26 SIRE inspection - subjective and/or factually incorrect observations 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.

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 vetting system and make it truly sustainable.

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 complaints on his behavior, but the commercial risk is too high.

29 Additional examples for self study Sire inspection subjective and/or factually incorrect observations

30 Q&A

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 issue is solved.

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 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. The VIQ is only requiring procedures to be in place.

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 The wording used is Tested Emergency Release Device, Job Order in Consultas The inspector did not agree on the wording and raised the observation.

35 Sire inspection subjective and/or factually incorrect observations VIQ 2.3 Does the Operator s representative visit the vessel at least biannually? Inspector s observation: the last technical inspection was dated October 10 th 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 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.

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 MARPOL Annex V effective JAN 2013

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 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.