SA 014

Cargo Damage due to Water Ingress from Ballast Tanks and Bilge Lines

Incidents resulting in damage to

dry cargo following water ingress
into the holds from ballast tanks
and bilge lines continue to arise.
Such claims are usually costly,
and separating damaged goods
from the rest of the cargo can
often cause delay. Moreover,
when cargo has been damaged by
salt water, the salved value may
be minimal and disposal may be
necessary, adding to the
magnitude of the claim.

Water Ingress from Ballast

Tanks

Water from ballast tanks may

enter adjacent cargo holds via a
number of different routes:

 Damage to the hold structure.
This may be caused by cargo
operations, for example, due to
grab damage to tank top plating
or hold pipework on vessels
carrying dry bulk cargo.
Similarly, container vessel tank
tops may be damaged by
containers which are landed
heavily or if lashing material
becomes trapped between tank
top and the container base.
 Severe corrosion of ballast tank
steelwork. This may involve
plating where localised
corrosion is so severe that
holes have appeared, or ballast
tank air and sounding pipes in
holds where the blind side of
pipework close to the adjacent
steelwork has corroded
This fertilizer cargo was damaged by sea water
migrating from an adjacent holed ballast tank
unchecked due to the difficulty
of examining this area and
removing rust scale. Where
inspection of the pipework
within a hold is problematic this
should be conducted during
each dry docking period.
 Leaking ballast tank manhole
covers. This may be due to
failure of the gaskets or the
presence of debris preventing a
suitable seal when manhole
covers are refitted, or when
manhole cover securing nuts
and bolts have not all been
replaced or properly tightened.
 Cargo hold heavy weather
ballast filling/suction arrange-
ments. This may be due to
valves between the ballast main
and hold or overboard drop
valves not being closed, or
when blanking plates have not
been properly fitted to the
suction/filling arrangements
within the hold when the system
is not in use.
When the Club carries out
condition surveys of dry cargo
vessels, the ballast tanks
surrounding the cargo holds are
tested hydrostatically. The test will
only be conducted when
shipboard operations and local
regulations allow and when the
Cargo Damage due to Water Ingress from Ballast Tanks and Bilge Lines
cargo holds in question are empty.
The ballast tank is overflowed to
deck and the cargo holds adjacent
to the tank inspected for leaks.
However, such a practice only
confirms that the tank is not
leaking at the time of the test. It is
therefore recommended that, as
far as is safe and practicable,
ballasting operations are only
undertaken when the adjacent
cargo holds are empty of cargo,
recognising that this may not
always be possible due to
operational reasons.
If a ballast tank manhole within a
cargo hold has been opened for a
routine inspection, to carry out
maintenance or while in dry-dock,
the manhole cover should be
refitted carefully on completion so
that the tank is ready for use.
Checks should be made to ensure
that sealing arrangements are free
of debris, that the gasket is in
satisfactory condition and
renewed if necessary, and that all
nuts and bolts are in place and
correctly cross-tightened in order
to achieve a watertight seal.
Provided no cargo is present in
the hold, it is recommended that
the tank is then checked by
means of hydrostatic testing at the
earliest opportunity to confirm that
the manhole cover does not leak.
Periodic hydrostatic testing of
ballast tanks should also be
considered as part of a vessel’s
planned maintenance system,
conducted at suitable intervals
when the holds are cargo free. In
addition, if a sounding or remote
monitoring of a ballast tank
reveals an unexpected reduction
or increase in the tank’s contents,
a thorough investigation should be
carried out to ascertain the cause
of the change.
Water Ingress from Cargo Hold
Bilge Lines
Cargo hold bilge systems are
fitted with a non-return valve on
each bilge line, normally within the
bilge well above the strum box/
strainer. The non-return valve can
become blocked, either by cargo
residue or by rust or debris such
as rags, preventing it from closing
properly. Non-return valves can
also seize open or partially open;
a lack of an audible clanking of the
non-return valve in operation bilge line isolation valves
should be investigated. If the reminding crewmembers that they
screw down valve between the should be shut once the pumping
bilge line and the bilge pumping of bilges has been completed.
system/eductor is not closed and
bilge/general service/ballast In order to prevent debris and
pumps are subsequently cargo residues from entering the
operated, sea water may flood bilge line and affecting the
back along the bilge line, past the operation of the non-return valve,
non-return valve and into the a strainer/strum box should be
cargo hold. fitted to the end of the bilge
suction pipe. When carrying dry
It is recommended that the bulk cargo, suitable protective
inspection, maintenance and measures should be taken to
testing of cargo hold bilge line non prevent cargo migrating past the
-return valves are incorporated bilge well plate into the bilge well.
into the vessel’s planned When cleaning holds after the
maintenance system, including discharge of dry bulk cargo, bilge
checks for backflow past the non- well plates should be removed
return valves when bilges have and all traces of cargo residue and
been pumped dry. Non-return debris cleared from the bilge well.
valves and bilge line isolation
screw down valves should also be If bilge high level alarms are fitted,
opened periodically and inspected they should be tested periodically
for obstructions and the build-up to confirm that they will operate
of cargo residues to ensure that correctly if water accumulates in
they remain effective. Where bilge the bilge well. Regardless of such
suction lines pass through ballast alarms, bilge well soundings
tanks, the pipework should be should be taken and recorded
checked for excessive corrosion twice daily as a matter of routine
during routine ballast tank internal as there have been many cases of
inspections. water building up in a hold
undetected due to the sudden and
Crew members engaged in unexpected failure of a bilge high
pumping cargo hold bilges should level alarm. Any activation of a
ensure that all valves isolating the bilge high level alarm or build-up
bilge lines from bilge/general of water in a bilge well should be
service/ballast pumps and investigated immediately.
eductors are closed upon
completion of pumping bilges. Members requiring further
Consideration may be given to guidance should contact the Loss
posting warning notices next to Prevention department.
Photo: Joiner Marine Services, Mobile, AL.
Rust and debris blocking this bilge well non-return valve allowed sea water to
migrate into the hold during ballasting operations, causing cargo damage
Loss Prevention Bulletin
The Carriage of Soya Beans in Bulk
Soya beans are typically carried in bulk and are a frequent source of claims.
Introduction
Soya beans are typically carried in
bulk and are an occasional source of
claims. Although this Loss Prevention
Bulletin has been prepared with the
soya bean trade from South America
to the Far East in mind, the key
provisions also apply to shipments of
soya beans in general.
This cargo must be carried in
accordance with the requirements
of the latest edition of the IMO
International Convention for the Safe
Carriage of Grain in Bulk (the Grain
Code).
Cargo Claims
Soya bean claims arising at the
discharge port often involve allegations
of deterioration and/or contamination.
If correct, the condition of the cargo
may have been affected by:
• Decomposition, self-heating, mould
growth and/or caking due to the beans
having an excessive moisture content
• Contamination with foreign matter
prior to loading
• Contamination with the residues of
previous cargoes, paint flakes and/or
rust from the cargo holds
• Sweat (ie condensation) damage
• Water ingress from non-weathertight
hatch covers, bilge lines and/or leaking
ballast tanks
• Heat damage to cargo in the vicinity
of the engine room bulkhead and/or
tanks containing hot fuel oil
• Insect infestation
Given the potential for damage and
shortage claims, Members may wish to
consider appointing a cargo surveyor
to attend the vessel during loading and
discharge operations to protect their
interests.
Moisture Content and Cargo
Deterioration
Soya beans are normally harvested
after the beans have matured and the
plant foliage has dried. They can be
loaded soon after being harvested
providing they have been dried to a
safe storage moisture content. Soya
beans can be stored for a significant
length of time under appropriate
conditions, although fixtures involving
the carriage of beans harvested in
earlier years should be avoided if
possible to minimise the risk of cargo
deterioration. However, even crops
harvested in the year of shipment may
deteriorate once on board if stored for
a prolonged period beforehand.
The moisture content of the cargo
is one of the most important factors
affecting the carriage of this product.
Although soya beans are hygroscopic
and will absorb moisture, it is unusual
for the average moisture content of the
cargo to change appreciably during the
voyage unless there has been some
specific incidence of wetting such
as water ingress or the development
of sweat inside the cargo holds.
Depending on the circumstances,
moisture migration may also occur due
to temperature gradients established
across the stow as a result of the
heating or cooling of steelwork. These
scenarios will increase the moisture
content of a proportion of the cargo
within the affected area. If the soya
beans had an inherently high moisture
content at the time of loading or are
wetted while on board, the oil within
the beans may start to decompose
during the voyage and cause the cargo
to self-heat, promoting the growth
of mould which can result in caking.
This type of deterioration affects the
quality of the product. The risk of
deterioration increases significantly
if the moisture content of the beans
exceeds 14%. Soya beans with a
moisture content of between 13% and
14% may also deteriorate if exposed to
warm climatic conditions throughout
the voyage. Similarly, deterioration
may occur if the moisture content of
the beans differs widely. Soya beans
with a moisture content below 10% are
Loss Prevention Bulletin
less likely to deteriorate but are more
susceptible to handling damage.
The amount of time that soya beans
can be stored before they start to
deteriorate depends on temperature
as well as the moisture content. The
higher the figures, the less time the
product can be stored without risk
of deterioration. For example, based
on a temperature of 26.7°C (80°F)
it should be possible to store soya
beans with a moisture content of 13%
for approximately 40 days before
they start to deteriorate. At the same
temperature a moisture content of
14% will result in a storage time of
around 20 days, whereas beans with
a moisture content of 12% may be
stored for approximately 70 days. At
a temperature of 15.6°C (60°F) it may
be possible to store soya beans with
a moisture content of 13% for up to
120 days without significant loss of
quality (Source: North Dakota State
University).
Other factors may also affect the
length of time that soya beans can
remain in sound condition while on
board. These include the variety of
soya bean, growing conditions and the
amount of handling and processing
between harvesting and loading.
However, such details and how they
may affect the storage life of the
product will often be unknown to the
carrier.
It is generally accepted that the
moisture content of soya bean
cargoes should not exceed 13%
when presented for loading. Cargo
interests will usually provide a quality
certificate declaring the moisture
content of the soya beans to be 13%or
slightly less, but this is likely to be an
average figure. In practice the actual
moisture content of some of the beans
may be higher, making them more
susceptible to deterioration.
Consequently the surveyor acting for
the vessel should be instructed to
check the moisture content of cargo
samples taken throughout loading.
Properly calibrated moisture meters
may be used for this purpose but
it should be borne in mind that the
accuracy of such devices is usually
around 0.5%. This tolerance should be
taken into account when evaluating the
results. In order to identify any cargo
that may have started to self-heat, the
surveyor should also be instructed to
measure the temperature of the beans
at regular intervals.
Heavy rain can reduce the quality of
the harvest, as may the drying process
between harvesting and shipment.
Since producers often blend superior
beans with inferior product, the overall
quality of soya bean cargoes may
fall during years when the harvest
has been affected by heavy rain and
superior beans are in short supply.
Loading
The cargo holds should be prepared
to the grain clean/high cleanliness
standard. Charterers and/or cargo
interests should also be consulted in
case they have any particular hold
preparation requirements. In all
cases the holds should be thoroughly
cleaned to remove any residues of
previous cargo, loose rust scale, paint
flakes, paint blisters, infestation and
any other foreign matter. The holds
should then be washed, carrying out a
final rinse with fresh water to remove
all traces of chlorides. Prior to loading
the holds should be completely dry
and odour free.
When presented for loading the beans
should be inspected for discolouration,
damp, caking, germination, mould,
shrivelling, contamination, unpleasant
odour and infestation. Any beans
found to be in such condition should
be rejected and replaced with sound
product.
Soya beans are usually yellow or
cream. However, black, purple,
brown, green, mottled (ie black
and brown) and a mixture of these
colours may also be encountered. The
accompanying cargo documentation
will often provide details regarding the
colour of the product and the year of
harvest, for example “Brazilian Yellow
Soybeans, Crop 2015 in Bulk”.
On some occasions receivers at the
discharge port have rejected cargoes
of soya beans on the grounds of them
being an unusual red colour, alleging
that the beans were contaminated
with a fungicide. Any abnormal
colouring should be investigated at
the time of loading, particularly if
it appears to differ from the colour
stated in the cargo documentation.
Depending on the grade and
contractual specification of the soya
beans, a percentage of heat damaged,
broken, split or different coloured
beans may be permitted. There may
 Loss Prevention Bulletin

also be an allowance for a certain

proportion of foreign material such
as stems, stones, shells and other
types of beans. A high proportion of
split beans can raise the likelihood of

Photo courtesy of: Haizheng Marine

mould developing and may increase

Surveyors & Consultants Co., Ltd

the possibility of deterioration.

As far as practicable the surveyor

should be instructed to compare
the properties of the cargo with the
contractual specification throughout
loading. In the event of any quality
concerns the master should issue a
Letter of Protest to cargo interests
drawing attention to the apparent
Caked soya beans
differences observed.

It is recommended that representative
cargo samples are taken from each
hold according to an internationally
recognised sampling procedure,
for example the Federation of Oils,
Seeds and Fats Associations (FOSFA)
sampling rules. Samples should be
sealed in airtight plastic containers
and be labelled with key details
such as date, time and hold number.
The samples should be retained on
board for analysis should the cargo
deteriorate on passage or in the event
of a quality dispute.
The cargo should be protected from
rain at all times and all non-working
hatch covers should be kept closed
during loading operations. If rain
is imminent, cargo work should be
suspended and the working hatches
should be closed without delay.
If the master or the surveyor has any
doubts regarding the condition of the
cargo during loading or its fitness for
carriage, the Club should be contacted
at the earliest opportunity as it may be
agricultural product shipped in bulk,
air will fail to penetrate the body of
the stow regardless of which method
is used.
If it is intended to ventilate the cargo
in accordance with the Three Degree
Rule during the voyage, then the
average temperature of the sub-
surface cargo should be established
after the completion of loading.
On a typical voyage from South
America to the Far East via the Cape of
Good Hope, ship sweat may develop
once the vessel enters the colder
waters off the South African coast. It
is therefore essential that compliance
with best ventilation practice is
fully documented as any signs of
deterioration due to unavoidable
sweat or inherent vice will generally
result in cargo interests claiming that
the vessel failed to ventilate the cargo
correctly, irrespective of the actual
cause.
Detailed temperature records, as well
as the times of starting and stopping
ventilation should be maintained. If it
is not possible to ventilate the cargo
due to fumigation, heavy weather or
any other reason, such details should
also be recorded. In addition to taking
temperature readings and adjusting
the ventilation during the day, the crew
should also follow the same routine
at night. Again, failure to monitor and
record such activities during the hours
of darkness may make it difficult to
defend any allegations of inadequate
ventilation.
Any fuel oil tanks bordering the cargo
holds should not be heated excessively
as the hot steelwork may induce self-
Photo courtesy of: Haizheng Marine Surveyors

necessary to obtain expert advice.

Carriage
Once the cargo has been loaded,
and subject to any fumigation
requirements, the holds should be
ventilated in accordance with the
& Consultants Co., Ltd

Club’s Loss Prevention Bulletin on

Cargo Ventilation and Precautions to
Minimise Sweat.

Mechanical rather than natural

ventilation of the holds is generally
preferable for achieving efficient air Caking due to cargo being next to a heated double bottom fuel oil tank
circulation. However, as with any
Loss Prevention Bulletin
heating and, over time, scorch the
beans in that area or trigger moisture
migration. The fuel should only be
heated to the minimum temperature
necessary for use. Similarly, fuel
which is overly hot should not be
transferred to such tanks. In addition,
the temperature of the engine room
bulkhead should be considered as this
may also result in heat damage and
moisture migration.
Soya beans continue to respire
after harvesting. The respiration
process may result in less oxygen
within the cargo holds and elevated
levels of carbon dioxide, making the
atmosphere unsafe to breathe. Deck
houses may also be affected if they
contain hold access hatches which are
not gas tight. Enclosed space entry
procedures should always be followed
if it is necessary for anyone to enter
such compartments.
All crew members should be briefed
about these hazards and the necessary
precautionary measures prior to
The West of England Ship Owners Mutual Insurance Association (Luxembourg)
UK office One Creechurch Place, Creechurch Lane, London EC3A 5AF
Tel +44 20 7716 6000 Email mail@westpandi.com www.westpandi.com
loading, particularly the oxygen to investigate the cause. The Club
depletion risks. Ideally all cargo hold should also be contacted immediately
access hatches should be locked shut as it may be necessary to appoint a
and suitable warning notices posted. surveyor to investigate further.
It is recommended that representative
Discharge
samples of the cargo are taken from
All interested parties should be invited each hold during discharge, following
to attend the vessel when the hatch the same process employed when
covers are opened to inspect the loading. Again, these may be useful
surface of the stow. The condition in the event of a subsequent quality
of the cargo should be recorded and dispute.
photographed, paying particular
The cargo should only be discharged in
attention to any areas which appear to
favourable weather conditions and the
be damaged.
hatch covers of all non-working holds
Further photographs should be should remain shut. If rain is imminent,
taken at regular intervals throughout cargo operations should be suspended
discharge and the vessel should and the working hatches promptly
maintain written records throughout. closed.
The records should include remarks
on how the cargo was handled and Cargo Shortage
details of all spillages.
In common with many dry bulk
If any cargo damage is observed during cargoes, shortage claims may arise.
discharge, the pattern, type and extent Draft surveys should therefore be
of the damage should be documented carried out by the vessel at all load and
to assist those who may be appointed discharge ports. However, if the vessel
is due to discharge at particular ports
where shortage claims are endemic, it
may be prudent to delegate this task
to reputable independent surveyors.
Members may also consider sealing
and unsealing holds under survey at
the load and discharge ports, inviting
Photo courtesy of: Haizheng Marine Surveyors
cargo interests to attend in each case.
Arrangements should also be made to
have empty hold certificates issued
upon completion of discharge.
It should not be assumed that a fixed
trade allowance for cargo shortages
will always apply. In some countries
& Consultants Co., Ltd
the courts may not permit such a
defence, and in others the trade
allowance may vary depending on the
province in which the discharge port is
situated.
Members requiring further guidance
should contact the Loss Prevention
Department.
The Club would like to thank CWA
International for assisting with the
LPB-COSBIB-GBR-19-V2
preparation of this Bulletin.
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 Safety Alert

Coal Cargoes – Know the Dangers

Introduction
Coal is a potentially hazardous
cargo and serious incidents
continue to arise. In some
instances it would appear that
those on board were not entirely
familiar with the risks, and on
other occasions the coal was not
carried in accordance with
regulatory requirements or best
practice.

One example involved a crew

member who was using a rotary
wire brush on deck to remove
patches of rust from the hatch
coaming of a closed hold
containing coal, possibly creating

Photo Courtesy of Crius Marine Surveyor

a source of ignition. While
operating the equipment an
explosion took place inside an
adjacent hold, blowing the hatch
covers upwards and propelling
the crew member over the ship’s
rail into the sea. He suffered
serious injuries as a result.

In another case a vessel with a cargo of Indonesian coal on IMSBC Code

board saw smoke rising from one of the holds while anchored
The International Maritime Solid Bulk Cargoes (IMSBC) Code
outside the discharge port. The vessel had been asked to
contains a detailed schedule regarding the carriage of coal,
ventilate the holds just prior to berthing. However, in the
describing the particular hazards associated with this cargo
absence of firm orders the vessel’s crew decided to ventilate
and specifying the precautionary measures to be taken. The
the holds anyway in case they were instructed to berth at short
IMSBC Code classifies coal as Group B (ie cargoes which
notice. The vessel did not berth until several days later during
possess a chemical hazard which could give rise to a
which time the cargo in several holds began to self-heat.
dangerous situation on a ship). Additionally, the IMSBC Code
On another occasion a deck rating on board a vessel carrying classifies coal as Group A (ie cargoes which may liquefy if
coal was asked to take samples from inside a cargo hold and shipped at a moisture content in excess of their transportable
collapsed at the base of a vertical ladder leading from the main moisture limit) if 75% or more of the material consists of fine
deck. Another deck rating entered the hold to assist him but particles under 5mm in size.
collapsed in the same location, as did two more crew
The requirements of the IMSBC Code schedule for coal should
members in succession. Although all four crew members were
be read, understood and closely followed.
eventually rescued, one lost his life and the others required
hospital treatment for respiratory injuries.
Cargo Declaration
The shipper’s cargo declaration should be scrutinised carefully
to determine which hazards are associated with the coal to be
loaded. However, in some parts of the world it should be borne
in mind that the cargo declaration may not necessarily be
accurate. For example, declarations regarding coal cargoes
from Kalimantan province, Indonesia, often state incorrectly
that there is no self-heating risk. All coal cargoes from
Kalimantan should be treated as being liable to self-heat. In
the event of doubt, Members may forward a copy of the cargo
declaration to the Managers for comment.
Potential Hazards
Methane (CH4)
Some coal cargoes produce methane, a non-toxic gas which
is flammable at concentrations of between 5% and 16% in air.
Ventilation should be carried out to ensure that the methane
content of the atmosphere inside the cargo holds is always
less than 20% of the Lower Explosive Limit (LEL) for methane.
If coal with a methane hazard is to be loaded, all sources of
ignition (eg smoking, hot work, naked flames, activities that
may produce sparks) should be prohibited on deck, within the
cargo spaces and inside enclosed spaces adjacent to the
cargo holds. Since methane is lighter than air, it should also
be remembered that methane gas may build up inside deck
houses and other compartments if they contain access
hatches or other cargo hold openings which are not gas tight.
Self-Heating, Oxygen Depletion and Carbon Monoxide
(CO)
Some coal cargoes may self-heat due to oxidation. This
process produces carbon monoxide, an extremely toxic,
odourless and colourless gas which also depletes the amount
of oxygen in the atmosphere. Since introducing fresh air into
the cargo spaces will increase the risk of combustion, self-
heating coal should be ventilated only if it becomes necessary
to dissipate the accumulation of methane gas. Any ventilation
carried out in such circumstances should therefore be kept to
a minimum.
If self-heating coal reaches a temperature of 55°C or over it
may spontaneously combust. Temperature probes
(thermocouples) may be placed within the body of the cargo
to aid the early detection of self-heating but their limitations
need to be understood. Self-heating is often localised and a
temperature probe may not detect cargo nearby which has
begun to self-heat as coal is thermally insulating. The Club
occasionally encounters situations where crew members are
over-reliant on temperature probes and assume that all is well
if the readings are less than 55°C which may not necessarily
be the case. Monitoring the level of carbon monoxide as
required by the IMSBC Code is a far more accurate means of
detecting self-heating at an early stage.
Coal should only be accepted for shipment if the temperature
of the cargo is less than 55°C. Additional information can be
found in the Club’s Loss Prevention Bulletin on the Monitoring
of Self-Heating Coal Cargoes Prior to Loading. Once a cargo
hold has been loaded and the hatch covers have been closed,
the amount of carbon monoxide inside the compartment
should be monitored closely to determine whether or not self-
heating is taking place. If the level of carbon monoxide in any
cargo space reaches 50 ppm or exhibits a steady rise over
three consecutive days, a self-heating condition may be
developing. Should such a situation arise the IMSBC Code
lists the action to be taken thereafter.
Breathing air with an oxygen content of less than 12% can
lead to unconsciousness. Less than 6% may result in death.
The speed with which personnel may be overcome by oxygen
depletion can be rapid, to the extent that they may collapse
before they realise what is happening. Although exposure to
carbon monoxide gas can be fatal even at low concentrations,
it is often the lack of oxygen that is the main cause of such
incidents.
As with methane, carbon monoxide is lighter than air and may
accumulate inside enclosed spaces such as deck houses with
cargo hold access arrangements inside which are not gas
tight. No one should be permitted to enter the cargo holds or
adjacent compartments until the atmosphere has been tested
and found to be safe. Enclosed space entry procedures
should always be followed.
 Safety Alert

Given the importance of monitoring gas levels in cargo holds

and adjacent enclosed spaces, it is essential that the vessel’s
gas detectors are in full working order, calibrated correctly and
not overdue for servicing. Any crew member responsible for
operating such equipment should be fully trained and familiar
with its use.

Photo Courtesy of Crius Marine Surveyor

In the event of potential hazards such as the presence of toxic
or flammable gas or reduced oxygen levels, the entrances to
cargo holds and adjacent enclosed spaces should be locked
shut and warning notices prohibiting access should be posted.

Liquefaction

If the shipper’s cargo declaration states that the coal is Group

A in addition to Group B, the accompanying certification and
test reports providing the moisture content and transportable
moisture limit (TML) of the cargo should be checked carefully
to verify that the moisture content is less than the TML. The
IMSBC Code requires the shippers to arrange for the moisture
content to be determined not more than seven days prior to
loading, repeating the test if significant precipitation is
experienced between the time of testing and loading. The
shippers are also required to ascertain the TML not more than
six months prior to loading, or earlier if the composition or
characteristics of the cargo change in the interim.
The vessel should also carry out regular “can” tests throughout
loading in accordance with the guidance set out in Section 8.4
of the IMSBC Code. As an additional precaution it may also
be prudent to carry out “can” tests even if the coal has not
been declared as Group A, particularly if it appears to be wet
or damp or if the proportion of fine particles seems to be high.
If a “can” test results in the appearance of free moisture or fluid
conditions, the Managers should be contacted immediately as
further laboratory tests and expert advice may be required.
Sulphur
the sulphur content of the cargo, therefore they should be
asked to provide such information if they fail to do so. In order
to monitor the possible corrosive effects of carrying high
sulphur coal, the vessel should be provided with a means of
measuring the pH value of cargo hold bilge water from outside
the cargo spaces.
Conclusions
If coal is to be loaded, the shipper’s cargo declaration should
be examined in detail to identify the properties of the cargo
and the associated hazards. It should also be remembered
that some cargo declarations may not be entirely accurate.
All crew members should be informed about the possible risks
before loading, perhaps during a shipboard safety meeting
prior to arrival. The hazards and precautions may also be
discussed when carrying out risk assessments or holding
toolbox talks.
Members requiring further guidance are advised to contact the
Loss Prevention department.

Coal from certain locations may have a high sulphur content.

If the coal or the cargo holds are wet, the sulphur and water
may react to produce sulphurous acid which is corrosive and
may damage hold steelwork, particularly if the coatings are not
in good condition. The reaction also produces toxic gas and
hydrogen. The IMSBC Code requires the shippers to declare

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Loss Prevention Dept: T: +(44) (0)20 7716 6106 F: +(44) (0)20 7716 6061 E: loss.prevention@westpandi.com W: www.westpandi.com
Loss Prevention Bulletin
Coal Cargoes - Measuring Methane Gas
Levels in Cargo Holds
Introduction
Some coal cargoes can produce
methane (CH4). Since methane is
a flammable gas, the International
Maritime Solid Bulk Cargoes (IMSBC)
Code requires vessels loaded with
coal to monitor the concentration of
methane inside the cargo holds via
external sampling points. Portable
gas detectors are carried for this
purpose. However, in the Club’s recent
experience it would appear that some
crewmembers may not be aware
that the readings for methane may
be incorrect if the amount of oxygen
inside the hold is low.
Portable Gas Detectors
Portable gas detectors used at sea are
typically fitted with flammable gas
catalytic sensors. If the coal begins to
oxidise and self-heat, the amount of
oxygen within the hold will decrease.
If the level of oxygen falls to 10% or
less, the flammable gas readings
produced by the catalytic sensor may
not be accurate.
Catalytic sensors may also produce
false flammable gas readings if
the amount of methane in the hold
atmosphere exceeds 100% of its Upper
Explosive Limit (UEL).
Dilution Sampling
To obtain accurate flammable gas
readings from a catalytic sensor in
such circumstances, dilution sampling
is required. This involves adding a
controlled quantity of external air to
the sample drawn from the cargo hold
to ensure that there is sufficient oxygen
present for the flammable gas readings
to be correct.
Dilution sampling requires a special
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attachment to be fitted either to the
sample inlet port of the gas detector or
to the sampling line. The fitting has a
small hole in the side to draw air from
the atmosphere, diluting the sample
drawn from the hold with external air
at a controlled rate so that the detector
can give an accurate flammable gas
reading. Alternatively, a T piece
equipped with a separate pipe to
draw air from the atmosphere may be
inserted into the sampling line.
Dilution sampling should only be
carried out after the gas detector
has been calibrated correctly for
methane without the dilution fitting
in place. Attaching the dilution fitting
thereafter will draw equal quantities
of cargo hold air and external air into
the gas detector. This process reduces
the flammable gas reading by 50%,
therefore the gas detector reading
must be doubled in order to determine
the true figure.
Some dilution fittings may be designed
to sample cargo hold air and external
air in unequal amounts, meaning
that the flammable gas readings will
need to be increased by a factor
which corresponds to the different
proportions. Consequently it is
essential that the design ratio of the
dilution fitting is checked before it is
used.
The air in the cargo hold should be at
atmospheric pressure when readings
are taken, otherwise the flow balance
in the dilution fitting may be disturbed.
If there is a vacuum inside the hold, the
amount of external air drawn though
the device will increase. Conversely,
if the hold is pressurised, the quantity
of external air will decrease. Both
scenarios may result in flammable
gas readings which are inaccurate. It
should also be noted that variations in
air temperature may give rise to a slight
vacuum inside a cargo hold. Since
temperature variations are more likely
during the day, as far as practicable
readings should be timed to avoid this
possibility.
Dilution fittings should only be used
to determine the concentration of
flammable gas if the level of oxygen
inside a cargo hold is low. At all other
times the dilution fitting should be
removed. It is also important to ensure
that all crew members required to
operate gas detectors are entirely
familiar with the use of dilution
fittings, in particular the dilution ratio
of the fitting and how the quantity of
flammable gas in the hold should be
calculated once the readings have
been obtained.
For further information on the type
and use of dilution fittings applicable
to a particular make and model
of gas detector, the instrument’s
manufacturer should be contacted.
Infrared Gas Detectors
As an alternative to using catalytic
sensors and dilution fittings, an
infrared gas detector may be used
to measure the amount of methane
inside a cargo hold regardless of the
oxygen level. Infrared gas detectors
can also measure flammable gas
concentrations above the UEL.
All gas detectors should be regularly
serviced and calibrated in accordance
with the manufacturer’s instructions.
Crew members required to take gas
LPB-CCMMG-GBR-19-V1
readings should be trained in, and
thoroughly familiar with the use of the
gas detectors onboard.
Members requiring further guidance
should contact the Loss Prevention
department.
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 Loss Prevention Bulletin
Cargo Hold Cleaning
When cargo holds are presented for loading cargoes in bulk
and they are not sufficiently clean for the intended cargo,
delays, off-hire and charter party disputes can arise.
Insufficient cleaning can also cause cargo contamination and
infestation, leading to cargo damage claims from cargo
receivers.
Due to the importance of the preparation and cleaning of
cargo holds prior to loading, personnel on vessels involved in
preparing cargo holds, and also those ashore involved in fixing
and operating vessels, should be familiar with the various
issues surrounding the cleaning of holds in order to prevent
the possibility of delays, disputes and claims. Operational
guidance addressing the preparation and cleaning of holds
between cargoes should be available to both seagoing and
shore based staff.
The extent of the cleaning operation and the steps required
Photo courtesy of: Wilhelmsen Ships Service
between two dissimilar cargoes will depend on the properties
of the previous cargo. When a break bulk cargo such as steel
coils has been discharged, the cleaning task may be limited
to the removal of old dunnage and lashing materials and a final
sweep of the cargo spaces. If a petroleum coke (petcoke)
cargo has been carried, the subsequent cleaning operation
will be conversely lengthy and involved due to the “dirty” and
possibly oily nature of this cargo. External factors beyond the
control of the vessel may also limit and hinder a cleaning
operation and these will need to be allowed for; there may be
a requirement to ballast a hold at the discharge port, or limited
time prior to loading the next cargo, or washing down may not
be possible due to freezing temperatures.
In general terms holds should be cleaned so that there are no
residues of previous cargoes, no loose rust scale, paint flakes
or blistering of paint coatings, no evidence of insect or rodent
infestation when foodstuffs are to be carried and no odours
 present, including those from cleaning chemicals and paint.
Holds should be thoroughly dried prior to loading though some
cargoes may be loaded damp from open stockpiles possibly
negating this requirement.

Photo courtesy of: CR Cox & Associates

Photo courtesy of: CR Cox & Associates

Flaking of paint coatings.

Cargo residues remaining on the framework

 Loss Prevention Bulletin

Cargo Hold Inspection and Maintenance

Some cargo contamination issues and the failure of holds by
surveyors stem from insufficient hold and hatch cover
maintenance. It is recommended that regular inspections and
preventative maintenance of cargo holds and hatch covers be
carried out as part of a documented planned maintenance
system, ideally following the discharge of each cargo.

The periodic inspections should be carried out by a

responsible officer, ideally the Chief Officer, and cover all
structures, surfaces and fixtures and fittings within the holds.
The scope of the hold inspection should include underdeck
framing, pipework and guards, access ladders and supporting
framework, manhole covers, bilges as well as bulkheads,
stools, side framing and tanktops. Similarly, hatchcovers,
coamings and associated fixtures and fittings should be
periodically inspected and repaired as necessary to maintain
weathertightness. Areas of loose rust scale which can be
removed without chipping should be eliminated. Areas of
flaking paint and paint blisters should also be attended to
promptly and made good. Consideration should be given to
the chipping or high pressure sandblasting of hard rust scale
on the tanktop; thick rust scale can be dislodged by the
buckets and tracks of bulldozers etc. during discharge, leading
to cargo contamination. If the vessel is principally engaged in
the carriage of clean cargoes the paintwork should, so far as
possible, be kept fully intact.

Where pipework is found corroded and holed it should be

cropped and replaced, as temporary repairs will not be
accepted by some surveyors. Holed handrails on access
ladders and platforms can retain residues of previous cargoes
and should also be cropped and renewed.

It should be borne in mind that the type of paint applied may

affect the ease with which the holds can be cleaned and epoxy
Photo courtesy of: CR Cox & Associates

paints are easier to clean than alkyd based paints. Cosmetic

touch-up of paintwork over rust may appear an easy short
term solution but this is not recommended and may lead to
holds being rejected by some hold surveyors as the paint may
have, or appear to have, been applied over loose scale. When
steel fixtures and fittings within cargo holds are damaged
during cargo operations, these should be promptly repaired.
In addition to any safety considerations, contamination claims
due to pieces of steel from the hold structure coming loose Hold components and pipework heavily corroded.
and being found within the cargo may be encountered.

Fixed hold air sampling fire detection systems and fixed CO2 task included in the planned maintenance system, so that any
systems should be periodically blown through with debris is blown out and the pipes remain clear for their
compressed air when the holds are free of cargo as a routine intended purpose and debris cannot migrate into the hold.
Hold Cleanliness Standards and Requirements
Cleaning commences at the discharge port. All cargo residues
should be removed so all that remains are those residues
which cannot be recovered using normal methods for
unloading which comply with MARPOL Annex V requirements
and any local regulatory requirements governing the disposal
of cargo residues. Since cargo receivers will normally want a
maximum outturn of their cargo it is anticipated that a vessel
will usually be re-delivered swept clean, rather than shovel
clean. However, in some ports the stevedores may need
reminding and encouraging to remove as much of the cargo
residues as possible.
The cleaning regime to then be used in preparing for the next
cargo will depend on a number of factors:
a) The nature of the previous cargo
The previous cargo may be incompatible with the next cargo
and which will necessitate particular care when cleaning the
holds. Manganese ore, for example, is rendered worthless by
the presence of chrome ore, and even small traces of sugar
can affect the properties of subsequent cement cargoes.
b) Shipper’s and / or Charterer’s cargo hold
cleanliness requirements / contractual
hold cleanliness requirements, as specified
in the voyage instructions / charter party
Shippers and / or charterers may specify their hold cleanliness
requirements or the cleaning regime to be employed to
prepare the holds for the next cargo in their voyage
instructions / orders. Requirements may also be included in
the charter party and it may well be that reference is made to
one of a number of industry standard cleanliness
requirements, such as:
1. Load on Top
When the same cargo is to be carried on a successive voyage,
it may be possible for the next shipment to be “loaded on top”
of the cargo residues remaining in the holds following a grab
discharge, provided the charterers are happy with this
arrangement. Although loading on top will save considerable
cleaning time and effort, the presence of cargo residues in the
holds will not permit a thorough inspection of the hold
steelwork for damage. Efforts should therefore be made to
move the residues to one side so that the hold structures can
be inspected. When load on top is utilised, it may still be
worthwhile periodically cleaning the holds after a number of
cargoes to prevent staining of paintwork (e.g. by coal), or the
build-up of hardened residues (e.g. cement), which will make
the cleaning process more demanding the longer they are left.
2. Shovel Clean
Typically, the cargo will be removed by grab with the
assistance of a bulldozer / wheel loader / bobcat and shovels,
and several tonnes of cargo may remain in each hold requiring
the crew to dispose of these residues. However, since the
need to comply with MARPOL Annex V limits the scope for
the discharge of cargo residues overboard, this cleanliness
requirement has become less common.
3. Normal Clean
In the event of no specific requirements being advised by the
charterer or contained within the charter party, it is
recommended that the following steps be taken, as a
minimum:
• Cargo residues be removed
• Double sweep the holds clean
• Seawater wash down
• Fresh water rinse
• Allow the holds to thoroughly dry
Typical bulk cargoes requiring normal cleaned holds may
include:
• Bauxite
• Coal
• Iron ore
• Petcoke
• Salt
4. Grain Clean / High Cleanliness
This is the most commonly required standard of cleanliness
with the holds free of all traces of previous cargo residues and
transferable stains, free of loose rust scale, loose paint flakes,
paint blisters and any other contaminants, thoroughly dry and
without any trace of infestation or strong odour.
Typical bulk cargoes requiring grain clean holds may include:

• Cement
• Fertilizer
• Grain (corn/maize, barley, soybeans, wheat etc.)
• Mineral concentrates
• Seed cake
• Sugar
• Sulphur
5. Hospital Clean / Stringent Cleanliness
The cleaning regime is the same as for grain clean, with the
added requirement that the holds have fully intact paintwork
on all hold and hatch cover surfaces, including the tank top,
and on all fixtures and fittings within the hold. Some inspection
regimes may permit a small percentage of the total hold
surface area with a non-intact paint coating.
Typical bulk cargoes requiring hospital clean holds may
include:
• Barytes
• Chrome ore
• Fertilizer
• Fluorspar
• Mineral sands
• Rice in bulk
• Soda ash
• Wood pulp
c) Exporting / importing country mandatory
requirements
Some exporting and importing countries have detailed hold
cleanliness requirements for certain commodities. Australia
has particularly strict requirements for the inspection and
cleanliness of holds prior to loading fertilizer, as any foreign
pests or diseases affecting the cargo could be directly
introduced when the fertilizer is applied to the soil. If a single
grain of a foreign cargo is found in the fertilizer at an Australian
discharge port, this could be sufficient for the entire shipment
of fertilizer to be condemned and an order imposed that it be
re-exported.
Loss Prevention Bulletin
d) International Maritime Solid Bulk Cargo
(IMSBC) Code “Hold Cleanliness”
requirements
When determining the cleaning requirements for the next
cargo the “Hold cleanliness” requirements in the applicable
IMSBC Code schedule should also be considered, as
compliance with IMSBC Code requirements is mandatory
under SOLAS. Many cargo schedules either specify “No
special requirements” or “Clean and dry as relevant to the
hazards of the cargo”. However, some cargoes have more
detailed cleanliness requirements, for example holds being
prepared for sulphur UN1350 should be “Clean and dry as
relevant to the hazards of the cargo and should be thoroughly
clean and washed with fresh water”, and for Direct Reduced
Iron (A) the Code advises “The cargo spaces shall be clean,
dry and free from salt and residues of previous cargoes” and
“Prior to loading, wooden fixtures such as battens, loose
dunnage, debris and combustible materials shall be removed”.
Cleaning Regime
The steps taken on the ballast voyage to clean the holds will
depend on the foregoing cleanliness standards and
requirements. The cleaning requirements should be realistic,
as, for example, it will take considerable time, effort and
resources to prepare a bulk carrier that has been employed in
the log trade ready to load a cargo of mineral sand. Where a
Master is any doubt as to the capability of the vessel to
prepare the holds to the required standard in the timescale
available, they should contact their managers at the earliest
opportunity.
Cargo hold cleaning will normally consist of one or more of the
following steps:
1. Removal of dunnage, lashing material and / or cargo
residues
2. Holds swept down
3. Holds swept down a second time (double swept)
4. Cargo residues that have set hard removed
5. Cleaning chemicals applied to hold surfaces and allowed
to penetrate / react with stains prior to being washed off
6. Holds sea water washed down
7. Holds washed down with detergents mixed in fresh water
8. Holds fresh water rinsed to remove all traces of chlorides
and detergents
9. Bilge wells and plates / strainers cleaned
10. Holds air dried
11. Loose paint flakes, loose rust scale and paint blisters
removed
12. Paintwork touched-up
13. The application of a barrier coat
Some vessels are equipped with fixed cargo hold washing
machines, however, these vessels are in a minority and most
vessels carrying solid bulk cargoes will need to manually wash
the cargo holds. Where fixed washing machines are used,
manual cleaning of shadow sectors within the holds may still
be required.
Whilst carrying out the foregoing cleaning tasks, the following
points should be considered:
a) Cleaning Equipment
1. Sufficient stocks of manual cleaning tools, including
shovels, trowels / hand shovels, brushes, bamboo or
Cherry pickers for access to the upper reaches of the hold.
aluminium poles to dislodge residues, squeegees and
mops should be maintained on board.
2. A mucking davit and winch should be provided to lower
tools into the holds and to remove sweepings and debris.
Containers should not be overloaded and the use of the
davit and winch should be safely managed.
3. On smaller vessels, or where not especially dirty cargo
residues are to be removed, the water pressure available
from the deck fire main may be sufficient for hold washing
duties. However, only dedicated washing hoses and
nozzles should be used, on no account should firefighting
appliances be used for washing down.
4. For larger vessels, high pressure washing guns / nozzles
powered by compressed air are available. With a throw
sufficient to reach the upper areas of the holds, the use of
this equipment often removes the need for means of direct
access to the upper reaches of a hold. These guns, usually
mounted on a tripod, can deliver wash water at
considerable pressure and have the option of drawing in
cleaning chemicals / detergents into the wash water via a
Photo courtesy of: CR Cox & Associates

cargo hold cleaning lance, used in conjunction with a foam
nozzle to ensure sufficient soaking time of the wash
solution on the cargo hold steelwork.
5. Suitable access equipment; ladders, scaffold towers,
scissor lifts and / or cherry pickers should be made
available for access to the upper reaches of the hold,
where necessary. Working at height operations should be
safely managed under the auspices of the vessel’s Safety
Management System as many means of access to the
upper reaches of holds can only be used safely when
alongside. If crane baskets are used, then the cranes
should be certified for man-riding. Permits to work, where
specified for certain activities, should be completed prior
to work commencing.
b) Cleaning Chemicals and Detergents
1. Where cleaning chemicals or detergents are to be used,
then sufficient quantities should be available on-board prior
to operations commencing.
Photo courtesy of: Wilhelmsen Ships Service
Cleaning chemicals and application equipment.
Loss Prevention Bulletin
2. It should be ensured that the vessel is provided with
sufficient equipment for applying chemicals and barrier
coatings, including lances, spray guns and foaming
applicators as applicable.
3. All cleaning chemicals and detergents should only be used
after the Material Safety Data Sheet (MSDS) has been
carefully read and the hazards fully understood. Personnel
Protective Equipment (PPE) should be used as required.
4. Cleaning chemicals and detergents that are disposed of
overboard with cargo hold wash water must not be
harmful to the marine environment, in accordance with the
requirements of MARPOL Annex V. The ship will need to
maintain records showing that any cleaning chemical or
detergent used was not harmful to the marine
environment. The IMO recommends that the supplier
provides a signed and dated statement to this effect, either
as part of a MSDS or as a stand-alone document.
5. Manufacturers’ instructions with regard to the method of
application of cleaning chemicals and detergents, their
dilution, the pressure of water jets and the duration of
cleaning should be closely followed.
6. To avoid likeliness of white stains created by chlorides left
on surface it is important to rinse surfaces with freshwater
after chemical cleaning and sea water washing.
7. Cleaning chemicals applied neat in line with
manufacturers’ instructions should not be left on hold
surfaces so long that they are allowed to dry, as removal
may then be problematic.
c) Hold Cleaning Guidance
1. Prior to conducting hold cleaning it is recommended that
a risk assessment is carried out, areas of risk identified and
precautionary measures implemented to reduce the
residual risk to an acceptable level.
2. Just prior to cleaning commencing, a tool box talk should
be carried out to discuss the work with all involved parties
in attendance.
3. All debris, dunnage, lashing materials and cargo residues
and detergents contained in hold wash water should be
removed from the holds and disposed of in line with
MARPOL Annex V requirements and any local regulatory
requirements that may be applicable.
4. The discharge of petcoke residues, if permitted by
MARPOL Annex V, should be carefully managed as the
requirements of MARPOL Annex I may apply, depending
on their composition.
5. During stops in cargo operations, crew members may be
able to access the top of the cargo to brush and dislodge
cargo in the upper reaches of a hold. However, this should
only take place where permitted by the port authorities /
berth operator and it is found to be safe and practical do
so following a risk assessment.
6. Cleaning of hatch covers and adjacent areas on deck
should ideally commence prior to departure after the hold
concerned has been emptied. The possibility of water
migrating into adjacent holds via open hatch lids should
be considered and managed, and any local regulatory
requirements concerning wash water and cargo residue
run off from the main deck complied with; onerous
requirements are rigorously enforced in some port states
with the imposition of fines and possible delays not being
uncommon.
7. Coaming drain channels should be swept out, drains
checked to ensure they are clear of debris and coamings
swept clean prior to washing down. Compressed air
should not be used to blow debris from channels and off
coamings. Ideally the hatches should be opened and
closed a couple of times to ensure all previous cargo
residues and any loose rust has been shaken off.
8. Areas adjacent to the hatches should be cleaned as
necessary, including mast houses, cranes, the main deck,
and even accommodation ladders, to prevent the
migration of the residues of previous cargos into holds by
wind action or by being trod in by personnel who
subsequently enter the holds.
9. Care should be taken when holds are to be washed while
cargo remains on-board in other holds. The migration of
wash water into holds containing cargo via the cargo hold
bilge system needs to be considered and bilge lines to
holds containing cargo should be isolated.
10. Chemical/Detergent washing, as per most cleaning
manufacturers recommendations, should be conducting
from bottom to top, commencing with the bilges and
tanktops first, moving to the lower hoppers, side shell
plating, the upper hoppers and the bulkheads, with the
underdeck area, hatchcovers and coamings washed last.
The advantage of the bottom to top method is that
residues streaking on the vertical surfaces and their
redepositing, which is potentially difficult to remove, can
be avoided. Additionally, the detergent’s contact time is
maximized being a key factor in achieving an optimal
cleaning result. The rinsing down of the detergent-soaked
surface with water is performed in the same manner as
the washing processes allowing for the achievement of
maximum detergent contact time and the prevention of
early dilution.
11. Conventional water washing should be conducted from
the top down commencing with the hatchcovers and
coamings, moving on to the underdeck area, then the
bulkheads along with the upper hoppers, side shell plating
and lower hoppers, prior to washing the tanktop and
finishing with the bilges.
12. It should be checked that cleaning chemicals are
compatible with the paint system in the holds and the next
cargo to be carried. The usage of chemicals containing
bleach (sodium hypochlorite), classified as harmful to the
marine environment, may damage paint coatings which
makes it easier for cargo residues to adhere to the cargo
hold surfaces. It should also be verified that the hold
coatings are compatible with the next cargo. Cargo
interests and / or hold surveyors may request to see
certification stating the paint system is compatible with
foodstuff cargoes.
13. If available, hot or warm water will make the cleaning task
easier and should make cleaning chemicals / detergents
more effective.
14. When using, fixed cargo hold bilge systems to pump wash
water overboard, it needs to be considered that the bilge
system (pumps / valves / eductors) may be affected by the
nature, size or abrasive properties (sands and cargoes
containing fine particles) of the cargo residues entrained
in the wash water.
15. Where cargo residues are particularly abrasive, large or
problematic, consideration should be given to using air
driven double diaphragm pumps to remove wash water
from the holds and pump it overboard in line with
MARPOL Annex V requirements, Cement, for example,
should ideally never be pumped via the fixed bilge system
due to the possibility of it settling and hardening.
16. Direct contact of the water jet with all parts of the hold
surface is desirable, including both sides of framing, and
nozzles and washing guns should be moved around the

hold as required. Where direct application of the water jet
to parts of the hold is not physically possible, then it should
be ensured that any shadow sectors are washed by the
flushing / splash back effect of the jet of water hitting
adjacent steelwork.
17. All surfaces within the holds should be cleaned, including
hard to reach areas at the top of the hold including framing
and brackets on the underside of deck plating and around
the hatch coaming. Particular care should be taken of
cleaning the blind side of pipework, pipe guards, access
ladders, platforms and their supporting brackets, manhole
covers and plates. The underside of hatch covers, the
inside of vent shafts and hold accesses trunking should
not be overlooked and should be cleaned to the required
standard.
18. Sufficient fresh water should be available to enable a final
thorough fresh water rinse of all holds to remove all traces
of chlorides. Salt water residues may lead to failure of the
hold cleanliness inspection, contaminate subsequent
cargoes either through direct contact or by dripping salt
laden sweat, and lead to coating breakdown and
corrosion. Where cargo has deteriorated on passage the
presence of chlorides detected during silver nitrate tests
of moisture in the hold can lead to receivers alleging sea
water ingress, making defending the vessel’s position
more problematic. A complete fresh water rinse is
therefore important. Many bulk carriers carry large
quantities of fresh water in the aft peak ballast tank for this
purpose. The fresh water wash should ideally be carried
out before the holds have dried following the sea water
wash, to make the removal of salt residues easier. It should
be remembered that the fixed water lines will initially
contain salt water, which should be flushed out with fresh
water prior to commencing the fresh water rinse. In some
cases, cargo interests / charterers may advise that a fresh
water wash is not necessary.
19. Where manhole lid cover plates are fitted, these should be
taken off, all cargo residues removed from the recess and
then the recess and lid cleaned to the same standard as
the rest of the hold structure.
20. Cargo hold bilge sounding pipes and pipes for the
placement of thermocouples should not be neglected from
the cleaning regime. These should be blown through either
with water or compressed air from main deck level.
21. So far as practical, all puddles of water remaining on the
tanktop and in the bilges, should be squeegeed and
Loss Prevention Bulletin
mopped out. Care should be taken to remove pockets of
water remaining in small indentations in the tanktop.
22. Holds and bilge wells should be thoroughly dried prior to
commencing loading. Opening the hatch covers, where
weather permits and it is safe and practicable to do so,
should be considered to aid drying. Hatches opened while
underway should be suitably secured, with additional
securing devices such as chain blocks utilised where
necessary. Hatches should not be opened when the
vessel is rolling or moving in a seaway. The use of
mechanical ventilators, where fitted, may help speed up
the drying process.
23. When loose paint, loose rust scale or paint blisters are
removed and paintwork touched-up, the steelwork should
be prepared and the paint applied in line with the
requirements of the vessel’s paint schedule. All new paint
should be fully dried and all paint odours removed from
the hold prior to loading commencing. It should be
considered that the paint may take several days to cure,
and if it has not fully hardened by the time the holds are
inspected, the holds may be rejected.
24. Once cleaning is completed, all the holds should be
inspected by a responsible officer in good time prior to the
arrival of the shipper’s hold surveyor, so that any areas of
concern can be re-cleaned and delays and possibly time
off-hire avoided. The scope of the survey should include a
visual inspection of all surfaces, ladders and fixtures and
fittings in the holds, so far as safe and practicable, with a
powerful torch and binoculars as necessary. Any areas of
concern should be attended to in good time.
25. If there is a delay between completion of hold cleaning and
loading; the condition of the holds should be periodically
checked as ship sweat may form, rust blisters may weep
and the residues of previous cargoes may vibrate from
their hiding places at the top of the hold and appear on
the tank top.
26. Consideration should be given to providing a cleaning
report, including photos to the managers / charterers prior
to arrival for their review and evaluation as to whether the
holds are sufficiently clean for the intended cargo.
27. Once cleaning is completed an entry should be made in
the deck log book including a brief description of the
cleaning regime used.
 a) Bilges
1. Once discharge from a hold is completed, inspect the
bilge wells and if cargo is found this should be removed
and discharged ashore.

2. While washing down keep bilge plates / strainers in place

and Strum / Rose boxes around bilge line suctions. These
should be periodically cleaned as required during breaks
in the cleaning operation.

3. Bilge wells should be cleaned last with bilge plates,

strainers and Strum / Rose boxes cleaned of all residues;
and the bilge wells thoroughly washed out. If cement wash
is applied to the inside of bilge wells, this should be
touched up where necessary with a mix of Portland
cement and water, made to the consistency of porridge.
Where foodstuffs are to be carried the bilge wells and the
fixtures and fittings therein should be disinfected.

4. Once holds and bilges are dry, the bilge plates should be
covered with hessian / burlap (sacking) as necessary to
prevent cargo ingress into the bilge well. The material
should be wrapped around the bilge plate and the gap
between the bilge plate and surrounding steel sealed with
duct tape, Ram-nek tape or the plate can be cemented in
place, as long as cement is compatible with the next
cargo. The bilge plates should be level with the
surrounding tanktop to prevent them being inadvertently
dislodged by bulldozers, bobcats etc. during discharge.

5. When the fixed cargo hold bilge system has been used to
discharge wash water containing cargo residues, the bilge
line non-return and isolation valves should subsequently
be inspected as cargo residues may remain in valve seats
holding valves open and allowing water to inadvertently
migrate into the cargo holds when the bilge system is in
use.
Photo courtesy of: Wilhelmsen Ships Service

Hold cleaning with chemicals.
Barrier Coatings
When carrying, cargoes considered dirty (e.g. green delayed
petcoke, and to a lesser degree, calcined petcoke, coal and
coke), or corrosive (e.g. sulphur and salt), a barrier coating can
be applied to the hold steelwork. The coating is applied to a
height just above that calculated as the maximum height of
the planned cargo in a given hold based on the stowage
factor, forming a temporary physical barrier between the cargo
and the hold structure that can later be washed off.

When a “dirty” cargo is to be carried, a number of
manufacturers offer hold coating options variously described
or marketed under the names of slip-coat or slip coat plus,
hold-block or barrier coats. These coatings can protect
paintwork and are more easily removed with the aid of
dedicated cleaning chemicals / detergents than the residues
and cargo stains that would normally remain post discharge.
All barrier coatings should be applied and removed in line with
the manufacturers’ instructions. Care should be taken that
areas where paintwork has broken down, and the tanktop in
particular are well coated with the barrier coating, it should
also be ensured that fixtures and fittings within the holds are
also fully coated.
Sulphur and salt are both aggressive commodities that can
corrode the vessel’s steelwork where paintwork is not intact.
In addition sulphur can be contaminated by the black residues
of the reaction between the cargo, rust and moisture, and hard
rust can stain salt. In order to protect vessels from these
corrosive cargoes lime wash has traditionally been applied as
a barrier coating to protect both the vessel and also the cargo.
The quantity of lime used should be in line with manufacturers’
instructions, but will typically be in the region of 60kg of lime
(calcium hydroxide) to 200 litres of warm fresh water. The
thicker the lime wash is applied the more protection provided;
however, the more difficult it will be to remove. Granulated
sugar can be added to the mix, (approximately 2.5kg to 200
litres of fresh water), to make the lime wash easier to remove.
Having intact paint coatings will help minimise the quantity of
lime wash required, as it can be more sparingly applied in
these areas, whereas bare steel will require a much thicker
coat to ensure adequate protection. The lime wash should be
applied no higher in the hold than absolutely necessary to limit
the magnitude of the removal task.
When limewash is utilised as a barrier coating consideration
should be given to challenges which can arise in relation to
removal, as strong acidic products may need to be applied
which can increase the risk to crew when handling such heavy
acid based cleaners.
All barrier coatings should be allowed to thoroughly dry prior
to loading commencing.
Hold Inspection
The scope of the hold inspection will depend on the
cleanliness requirements for the proposed cargo. Prior to
Loss Prevention Bulletin
starting the inspection a surveyor may require a list of the
previous three or more cargoes carried, and this should be
prepared in advance. The surveyor may be acting on behalf of
cargo interests and / or may represent a National
Administration for the country of export and / or import;
therefore the parties for who the surveyor is working should
be ascertained prior to starting the inspection. Upon
completion of a successful inspection certification may be
issued to the vessel.
Inspections should be carried out in daylight with the hatch
covers open. In some circumstances additional high powered
lighting will need to be provided and arrangements made to
permit access to all parts of the holds. All hold accesses
should be open and bilge plates removed to expedite the
survey.
The hatch covers will probably be required to be partially or
fully closed at some stage of the inspection so their underside
can be thoroughly examined.
Where fixtures or fittings hide areas that need to be inspected,
such as pipe guards, then these may need to be removed to
enable a complete inspection to take place.
A responsible officer, ideally the Chief Officer, along with several
crewmembers equipped with rudimentary cleaning tools, for
example, a dustpan and brush, dog-leg and long handled
scrapers, rags, water and an old paint tin or bucket for
residues, should accompany the surveyor so that spot
cleaning can be carried out as necessary.
In some cases discolouration of paintwork is sufficient for a
hold to fail an inspection, in particular stains remaining after
carrying petcoke or coal as these may blister following the
formation of ship sweat. Any stain remaining that can be wiped
off by a surveyor will normally lead to the hold failing the
inspection.
The presence of only a small number of insects, either dead
or alive, may be sufficient for a hold to be rejected and for
fumigation to be required. The required scope of the
fumigation will depend on the magnitude of the infestation and
will need to be carried out in accordance with the hold
surveyor’s recommendations; local application of insecticide
with a hand sprayer may be sufficient for localised infestation,
however, full hold fumigation may be required where the
problem is more widespread.
Where a hold has failed the inspection, the reasons for the
failure, be it the presence of loose rust scale, flaking paint, or
infestation etc., will normally be detailed by the surveyor in an
inspection report so that targeted remedial action can be taken
prior to a re-inspection.

The guidance contained in this Loss Prevention Bulletin is, by

necessity due to the wide variety of cargoes that can be
carried, of a general nature intended as best practice guidance
for all personnel concerned with and involved in the cleaning
of cargo holds for bulk cargoes.

Members requiring additional guidance should contact the

Loss Prevention department.

The Club would like to thank Product Marketing Manager Jan

Fredrik Bjoerge at Wilhelmsen Ships Service for assisting with
the preparation of this Bulletin.
 Loss Prevention Bulletin

Cargo Hold Cleaning Checklist

Ship Details
Ship’s Name

Date

Previous Cargo

Next Cargo

Charterer’s cleanliness requirements

At the discharge port

1. Ensure that as much cargo residue, lashing material and / or dunnage is removed as possible and
landed ashore.

2. Deckheads, framing and bulkheads should be swept down during discharge where permitted and
safe and practicable.

3. Check bilges are free of cargo, if not, clean the bilge wells and have the cargo residues discharged
ashore.

4. Remove all cargo residues from hatches, coamings and drain channels (do not use an air hose;
drain channels should be swept clean). These should be washed down if permitted, be aware that
some ports having stringent requirements regarding deck water run-off.

Prior to commencing hold cleaning

5. Determine the degree of hold cleaning and preparation required by reviewing voyage instructions,
the charter party and by consulting with the managers / charterers. The hold cleaning requirements
in the IMSBC Code should also be followed. When determining the cleaning requirements the
following points should be considered:

• If the same cargo is to be carried, charterers may require no cleaning / washing and permit loading
on top.

• If clean cargo, such as steel coils have been carried, little or no cleaning / washing may be
necessary.

• Is the next cargo incompatible with the previous cargo necessitating extra cleaning?

• Are cleaning chemicals / detergents required?

• Will a barrier coat need to be applied?

• Are sufficient cleaning tools, fresh water, chemicals, and barrier coatings onboard?

• Does the loadport and / or discharge port have any specific cleanliness requirement, for example,
when carrying foodstuffs or fertiliser?
When the cleaning and washing requirements for the next cargo have been determined, the following points should
be considered when preparing the holds:

6. A risk assessment and tool box talk should be carried out prior to work commencing.

7. When working at height on ladders, scaffold towers or other means of access is required; ensure
all relevant Permits to Work as required by the vessel’s Safety Management System are completed.

8. Sweep up or double sweep the holds to remove any remaining cargo residue, paying attention to
cargo residue in bilges, on the topside of underdeck framing, and the blind side of ladders, stairs,
pipework and fixtures and fittings.

9. Where cargo residue has set hard, this should be removed by chipping or scraping.

10. Dispose of all dry cargo residues, cargo residues in hold wash water, dunnage, lashing materials,
cleaning chemicals and detergents in accordance with the requirements of MARPOL Annex V, and
any applicable local regulatory requirements.

11. Wash down hatch coamings, drain channels and compression bars, if not completed at the
discharge port. Adjacent decks, mast houses and cranes may also need cleaning and must not be
overlooked.

12. Sea water wash all hold surfaces paying particular attention to underdeck framing, the underside
of hatch covers, the blind side or ladders, stairs, pipework and pipe guards.

13. With cargo residue that may set, e.g. cement, ensure copious amounts of wash water are used
and the residues are discharged via portable pumps, rather than via the fixed cargo hold bilge
system.

14. After a sea water wash conduct a thorough fresh water rinse of the holds to remove all traces of
sea water (chlorides); except where advised by charterers that this will not be necessary.

15. Wash / blow through cargo hold bilge sounding pipes and thermometer pipes and ensure they are
clear.

16. Clean and disinfect bilge wells when foodstuffs are to be carried.

17. Mop up / squeegee puddles of water remaining in the holds.

18. Touch up cement wash in bilge wells if required and fit burlap or hessian to bilge plates when a
cargo with fine particles is to be carried.

19. Loose rust scale, loose paint flakes and paint blisters should be removed, in particular for foodstuff
cargoes. Loose rust scale should not be painted over.

20. Allow the holds to dry thoroughly, using mechanical ventilators where fitted and with consideration
given to opening hatches where safe and practicable to do so.

21. Where cargo hold paintwork has been touched up, ensure the paint is compatible with the planned
cargo and painting is completed sufficiently in advance of arrival to allow the paint to thoroughly
cure.

22. When required for the next cargo, apply a barrier coating such as lime wash, hold-block or slip-
coat in accordance with the manufacturers’ instructions; ensuring the coating has fully dried prior
to loading.
 Loss Prevention Bulletin

Remarks

23.

Responsible Officer’s Signature Date

West of England Insurance Services (Luxembourg) S.A., Tower Bridge Court, 226 Tower Bridge Road, London, SE1 2UP
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 Loss Prevention Bulletin
Gangways and Accommodation Ladders
For many people the gangway or accommodation ladder is
the first point of contact with a ship. Initial impressions are
important, and a properly rigged ladder may be the first
indication to a visitor that they are boarding a well run vessel.
However, someone obliged to climb a ladder which is
unsteady, slippery or unsafe may have formed an unfavourable
opinion of the ship and its crew by the time they have reached
the top.
Gangway and Accommodation Ladder
Incidents
Gangways and accommodation ladders may be hazardous if
badly rigged, improperly tended or inadequately maintained. In
spite of the acknowledged dangers, accidents associated with
such shortcomings continue to arise.
In one incident three seamen sustained injuries, one seriously,
after falling to the quay from an accommodation ladder which
they were breaking out. In another, failure to raise the gangway
while warping astern placed undue stress on the top platform
hinge pins which worked loose and caused the gangway to
collapse. Similarly, a number of disembarking personnel were
injured when an aluminium gangway they were using broke in
half. The weakness was traced to a cracked structural
member which had deteriorated unnoticed over a period
of time.
In another case insufficient monitoring caused the inner rail of
an accommodation ladder to become wedged against the
davit arm when the tide fell. While attempting to free and lower
the inner rail on its collapsible stanchions a crewmember,
standing on the upper platform, managed to pull the rail free.
However, the sudden release of the rail caused him to stagger
backwards and he fell over the platform guard rail into the river.
Despite an extensive search his body was never recovered. It
was found that the guard rail ropes on the upper platform were
only 65cm high rather than the recommended 1 metre.
A further recent example concerned the death of a seaman
when the hoist winch gearbox failed while he was rigging the
Inadequate guard rail ropes over which a seaman fell to
his death (Courtesy MAIB)
accommodation ladder. The failure of the gearbox caused the assessment or job safety assessment should also be carried
lower telescopic section of the ladder to descend out beforehand in case additional measures to reduce the risk
uncontrollably. When the ladder reached the end of its travel are necessary before commencing the operation. Suitable
the bolts holding the rollers sheared and the lower section fell protective equipment should be worn as appropriate including
into the water. At the time of the failure the seaman was personal floatation devices fitted with self activating lights,
standing on the lower section rigging stanchions and fell whistles and reflective material, and safety harnesses of the
overboard. He was not wearing a fall prevention device or a arrestor type rather than fall restraints. Fall arrestors should
lifejacket. It was subsequently found that the gearbox had always be attached to suitable securing points fixed to the
been incorrectly re-assembled following maintenance by the ship’s structure.
ship’s crew.
Surveyors carrying out condition surveys for the Club often
Moreover it is not uncommon report occasions where a vessel's gangway or
for the Managers to be accommodation ladder was rigged incorrectly. Safety nets are
notified of injuries sustained often the subject of such observations and are frequently
by crew, stevedores, port found to be secured to each side of the ladder along its entire
officials, contractors or other length. This results in the net hanging uselessly below the
visitors while embarking or steps instead of leading away to the side of the ship to catch
disembarking. Steps, anyone unfortunate enough to fall off.
whether they are part of a
Rope guard rails must be tight if they are to be effective, and
ship's access arrangements
all stanchions must be fitted in place and properly secured.
or a flight of stairs ashore,
Steps, handrails and platforms should be free of oil, grease
The damaged telescopic may increase the chances of
accommodation ladder from which
slips and falls occurring. and ice. When landed on the quay, care should also be taken
a seaman fell to his death when the
hoist winch failed (Courtesy MAIB) Given that gangways and to ensure that the lifting bridle and/or davit arm is kept well

accommodation ladders are above head height or moved clear as necessary.

also susceptible to movement by external factors such as
cargo operations, tidal conditions, swell and other gangway
users, the risks may be magnified.
Rigging
Gangways and accommodation ladders are heavy and
cumbersome pieces of equipment. Operating instructions
should be posted in the vicinity of the boarding arrangements
and it is essential that the personnel required to break out and
rig ladders or operate lifting gear are sufficiently experienced,
As far as practicable the approaches to the ladder both on
deck and on the quay should be free of hazards to allow safe
access and egress to and from the vessel. Close attention
should also be paid to any significant difference in height
between the ends of the ladder and the quay or deck. This
may mean placing and securing a portable step or steps in
such locations to minimise the risk of slips and falls. Warning
notices should be posted in such cases.
When gangways are placed on top of bulwarks, a suitable
bulwark ladder should be used between the deck and the

bearing in mind the possible consequences of a mistake. gangway. It should be adequately secured and all gaps

Anyone unfamiliar with such tasks should be closely
supervised by a responsible person until considered
competent.
If inexperienced crewmembers are required to assist with the
rigging of a gangway or accommodation ladder, a risk
between the top of the bulwark ladder and the gangway
should be fenced off to a height of at least one metre.
Gangways and accommodation ladders should be adequately
illuminated at night, particularly at each end. If there are no
permanent fittings, portable lighting should be rigged.
 Loss Prevention Bulletin

A lifebuoy with a self-activating light plus a separate buoyant
lifeline with a quoit or similar device attached should be
stationed at the point of access ready for immediate use. Many
vessels also place a small box containing a fire plan, stowage
plan, dangerous goods list, stability details, crew list and other
relevant information at the head of the ladder ready for use in
an emergency.
Positioning
Where possible, boarding arrangements should be positioned
away from working areas and places where cargo may pass
overhead. If there appears to be no safe option using the
ship's own equipment, it may be possible to hire a shore
gangway if such facilities are available. It should be
remembered that tending a shore gangway and ensuring it is
rigged safely remains the responsibility of the vessel.
Gangways should never be secured to a ship's guard rails
unless they have been designed for that purpose. If positioned
through an open section of bulwark or railings, any remaining
gaps should be roped off to a height of at least one metre.
Consideration should also be given to the angle of inclination,
making sure that design limits are not exceeded. It may be
necessary to provide alternative arrangements if the means of
access is likely to become excessively steep. National
legislation on this issue may vary, but in the absence of firm
rules it may be prudent to observe UK regulations; a gangway
should not be used if its angle of inclination is more than 30°
above or below the horizontal, similarly for an accommodation
ladder if the angle is more than 55° below the horizontal,
unless designed and constructed for use at angles greater
than these.
Tending
A crewmember should be assigned to monitor the gangway
or accommodation ladder as regular adjustment may be
required due to the movement caused by tidal conditions and
variations in draft and trim.
Regular monitoring is essential as changed circumstances
may lead to a vessel's access arrangements rapidly becoming
difficult to negotiate.
The deck watch should also look out for potential dangers
ashore such as bollards, tracks and cranes bearing in mind
that most ladders are constructed of aluminium alloy and are
easily damaged.

Important points to be considered during the rigging

process:

1. Rope guardrails tight and free of damage and/or

degradation
2. Stanchions free of distortion and all in place
3. Safety net positioned between ladder and ship, free of
damage and/or degradation
4. Hoisting arrangements clear of head height
5. Steps free of oil, grease and ice
6. Bottom platform level (where fitted)
7. Lighting arrangements positioned effectively
8. Base clear of obstructions
9. Lifebuoy fitted with a light and a lifeline with a quoit
available at the point of access

If the position of the ladder is such that cargo residues
accumulate on a ladder and its approaches during a port stay,
then the residues should be cleaned away regularly to prevent
a slip/trip hazard.
To assist those responsible for tending gangways and
accommodation ladders, it may be worthwhile noting the
times of high and low water on the sailing board each day.
Maintenance
It is a SOLAS requirement that inspection and maintenance of
accommodation ladders and gangways be conducted
periodically. Monthly inspection and maintenance should be
included in the planned maintenance system and should
always be carried out by a competent person in accordance
with manufacturers' instructions.
In addition to planned maintenance inspections, further checks
should be made each time the ladder is rigged, looking out for
signs of damage, distortion, cracks and corrosion.
Periodic inspections of accommodation ladders and
gangways should incorporate the following:
• The structure of the ladder should be closely examined for
cracks, distortion, damage and corrosion, and repaired as
necessary.
• If an aluminium ladder has fittings made of mild steel, these
areas should be examined closely. Accelerated corrosion
may occur if the two dissimilar metals come into contact,
and deterioration of the separation material could lead to a
severely weakened structure.
• Bent stanchions should be replaced or repaired, and guard
ropes inspected for wear and renewed where necessary.
• Safety nets should be inspected for damage, actinic
degradation and for the impregnation of grease, paint or
chemicals which may affect their strength.
• Moving parts such as sheaves, tracks, turntables, bearings
and rollers should be free to turn, and greased as
appropriate.
• Lifting equipment should be inspected, tested and
West of England Insurance Services (Luxembourg) S.A., Tower Bridge Court, 226 Tower Bridge Road, London, SE1 2UP
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Loss Prevention Bulletin
maintained according to a planned schedule. The condition
of hoist wires is to be closely monitored for broken wires,
corrosion or distortion, with particular attention paid to areas
passing through sheaves. Damaged wires should be
replaced in line with the company’s wire discard criteria prior
to their condition becoming unacceptable. In any event hoist
wire replacement should never exceed 5 years. Hoist wires
should be provided with a suitable test certificate prior to
fitment and it is recommended that the date the hoist wires
were last renewed is stencilled in the vicinity of the ladder for
easy reference.
• Hoist wires should be periodically treated with a suitable wire
rope dressing over their entire length.
• Arrangements should also be made to examine the
underside of gangways and accommodation ladders at
regular intervals. It is often difficult to gain access to these
areas in the course of normal activities and it may be
necessary to turn the ladder over periodically to perform a
detailed inspection.
• Winch bed plates and supporting structures for sheaves and
turntables should be inspected for cracks, distortion,
damage and corrosion, and repaired as necessary.
• Control levers/buttons and limit switches should be tested
to ensure they are working correctly.
• Operating instructions should be conspicuous, markings on
the accommodation ladder or gangway as required by the
flag state (such as the maximum safe loading by persons
and by total weight) should be legible, and control levers or
buttons should be clearly marked.
All inspections, maintenance work and repairs should be
recorded in the planned maintenance system in order to
provide an accurate detailed history for each appliance.
Checklists
Checklists may be used as an additional safeguard when
rigging gangways and accommodation ladders. Members
may wish to adapt the attached example to suit their own
requirements.
 Loss Prevention Bulletin

Gangways and Accommodation Ladders Checklist

Vessel

Date

Port

No. Checkpoint Yes/No

Preparatory Work:

1. Assemble a sufficient number of experienced personnel

2. Arrange supervision of less experienced personnel
3. Discuss work plan and allocate tasks
4. Conduct a risk assessment if deemed necessary and close out all action points
5. Ensure personal protective equipment including suitable personal floatation devices and fall
arrestors are worn as necessary
6. Check that boarding arrangements will be clear of working areas
7. Check for obstructions likely to impede lowering/positioning
8. Place lifebuoy with light and buoyant line with quoit close by

Rigging:

9. Test and position lighting arrangements

10. Check that ladder is sufficiently stable
11. Check that the angle of inclination is satisfactory
12. Check safety net for wear and defects
13. Fit safety net correctly to span gap between the outboard side of the ladder and the vessel
14. Inspect rope guardrails for wear and ensure ropes are pulled tight
15. Examine stanchions and fixed guardrails for damage and secure in position
16. Ensure bottom platform is level (accommodation ladders, where fitted) and suitably fenced
17. Check boarding arrangements are free of oil, grease and ice
18. Ensure that lifting equipment/bridle does not cause an obstruction
19. Position and secure additional steps if required
20. Post notices warning of additional steps as appropriate
21. Ensure bulwark ladders, where used, are properly secured
22. Rope off any gaps in the bulwark or railings
23. Verify that safe access exists at shore side end of ladder
24. Verify that safe access exists at shipboard end of ladder
25. Examine ladder closely for signs of distortion, cracks or corrosion
26. Examine hoisting wires and equipment for wear and damage
27. Report and record all defects found and equipment replaced
28. Post sailing board
 Loss Prevention Bulletin

No. Checkpoint Yes/No

Tending:

29. Ensure gangway watch is maintained throughout

30. Check regularly whether repositioning is required
31. Check regularly whether safety net/rope guardrails require adjustment
32. Watch out for potential obstructions ashore
33. Keep the access arrangements and approaches clear of ice, oil, grease and cargo residue
34. Carry out regular checks to ensure that safe access is maintained

West of England Insurance Services (Luxembourg) S.A., Tower Bridge Court, 226 Tower Bridge Road, London, SE1 2UP
Loss Prevention Dept: T: +(44) (0)20 7716 6106 F: +(44) (0)20 7716 6061 E: loss.prevention@westpandi.com W: www.westpandi.com
 Loss Prevention Bulletin

The Carriage of Rice

Introduction
Rice is a sensitive cargo and claims arising from the carriage
of rice are not unusual. However, it is equally common for
cargo interests to blame the vessel for any shortages, damage
or deterioration irrespective of the actual cause.
In particular, the reasons why rice may deteriorate on passage
need to be understood so that, where possible, action can be
taken to carry and deliver the cargo in sound condition.
Photo courtesy of: ETIC/Africa P&I Services
Types of Rice
There are many varieties of rice that may be presented for
shipment and their characteristics can differ. However, in
general terms all rice grains or “kernels” are covered with, and
protected by, layers of bran. The bran itself is surrounded by
a hard outer husk or hull which may also be referred to as
chaff.
The description of the rice will largely depend on the degree
of processing. The proportion of broken grains may also be
stated. The most common types of rice are summarised
below:
Paddy rice/raw paddy/rough rice
Rice grains which have not been de-husked.
Brown rice/cargo rice
De-husked rice that has not been milled or “polished”, leaving
most of the bran on the grain.

Parboiled
Rice that has been soaked in hot water or steamed prior to
being dried, de-husked and polished.

Bagged rice cargoes frequently give rise to claims for shortage and / or
damage

Endeavouring to minimise shortages is equally important,

particularly in countries where short delivery may result in
heavy fines.
To minimise the possibility of claims due to quality or quantity
issues, this Loss Prevention Bulletin contains guidance on the
problems associated with the carriage of rice and the
precautionary measures that may help to reduce such losses.
The carriage of bagged rice cargoes from South East Asia to
West Africa gives rise to the majority of incidents experienced
by the Club and claims for shortage and/or damage due to
cargo wetting and deterioration are not uncommon. Although
the guidance in this Bulletin is principally aimed at this trade,
the following precautionary measures should be considered
Parts of a grain of rice
whenever rice is carried regardless of where it is loaded or
discharged.
Traditional dunnaging arrangement
Under-milled/semi-milled/reasonably well milled
De-husked rice which has been polished but where streaks of
bran are still evident.
White rice/milled/over-milled/wholly milled
De-husked rice that has been polished to remove the bran. It
may be glazed with glucose and talcum to improve its
appearance, or coated with a film of oil (eg “Camolino” rice).
Broken rice
White rice damaged during processing comprising of whole
grains together with a percentage of broken grains.
Size of Rice
In addition to the type of rice, the shipment details will usually
state the grain size:
Short grain or round rice
Small, round grains that become glutinous when cooked,
often used to make rice pudding and similar dishes. Grain
length is 5.2 mm or less.
Medium grain rice
Rice between 5.2 mm and 6.0 mm in length considered to be
ideal for making dishes such as risotto and paella.
Long grain rice
Long and slender grains exceeding 6.0 mm in length which
do not stick together during cooking.
Bagged Rice
The most common type of rice shipped by sea is milled white
rice in bags. Brown rice is transported in much smaller
quantities.
Rice is generally packed in 20 kg, 25 kg or 50 kg woven
polypropylene bags. The use of jute bags is now less frequent.
Preparation Prior to Loading
Hold Cleanliness
Prior to arrival the holds should be thoroughly cleaned, washed
and dried. Any traces of previous cargo should be removed and
close attention should be paid to making sure that areas which
are difficult to reach (eg underdeck framing) are free of such
residues. After washing down with seawater, the holds should
be rinsed with fresh water to eradicate all traces of chlorides
from the steelwork. This is particularly important as chlorides
may combine with any sweat (condensation) that may develop
on passage. If a silver nitrate test is subsequently carried out,
the results are likely to be positive and may provide cargo
interests with an opportunity to allege that seawater entered the
holds during the voyage and caused cargo damage.
All loose paint and rust scale should be removed, bearing in
mind that higher, more inaccessible areas of the cargo holds
are at greater risk of developing such problems. The reverse
side of pipework and other structures within the holds should

also be checked for loose paint and scale that may be
concealed.
Since rice is susceptible to taint, all holds should be well
ventilated until they are odour-free. Should any signs of
infestation be found, the services of a specialist pest control
company may be needed. Any particular hold preparation
requirements specified by the charterer or shipper should be
addressed well in advance. Holds which have not been
properly prepared may result in delays and additional expense
if they are rejected by the shipper’s surveyor on arrival.
Pre-Loading Checks
Cargo hold bilge wells should be inspected, cleaned and
tested, ensuring that all bilge well non-return valves are
functioning correctly. Bilge line isolation valves in the machinery
space should always be kept shut when the hold bilge
pumping system is not in use.
It is essential that the checks are made to verify that hatch
covers and the sealing arrangements on hold ventilators and
hold accesses are completely weathertight. Ideally the hatch
covers should be tested using ultrasound equipment, but if
not available a hose test should suffice. In addition to
preventing water ingress, the hatch covers also need to be
weathertight for the purpose of preventing toxic gas from
escaping if the cargo is fumigated on completion of loading.
Hatch coaming drain channels, drain pipes and non-return
valves should be free from cargo residues, rust scale and paint
flakes. Drain pipe non-return valves should be tested to ensure
they are functioning correctly.
The operation of the hatch covers should be checked to
confirm that they can be closed promptly if rain threatens to
interrupt cargo work, rather than finding out at the last minute
that the operating system does not work as intended.
If safe, practicable and permitted by local regulations, the
ballast tanks bordering empty cargo holds should be
hydrostatically tested for water leakage by overflowing them
on deck. However, such a test should not be carried out if an
adjacent hold contains cargo in case of unexpected outflows.
Stowage and Dunnage
Stowage
To avoid the possibility of taint, rice should not be stowed
together with cargoes having a strong odour such as coffee
or fishmeal. Such products should be stowed in another
compartment fitted with a separate ventilation system.
It has long been the custom to build air gaps into the stow to
aid ventilation, typically creating two longitudinal and three
athwartship channels approximately 15 to 20 cms wide. The
athwartships ventilation channels are normally situated under
the centre, forward and aft ends of the hatch square, and the
Loss Prevention Bulletin
Photo courtesy of: ETIC/Africa P&I Services
Typical athwartships ventilation channel. However, experts question whether
ventilation channels are necessary at all
longitudinal channels are usually formed in line with the
ventilators. Single bags are then positioned across the
ventilation channels every fifth tier to key the stow together,
spaced five to ten bags apart. Experts, however, question
whether these channels are necessary at all as there is now
scientific evidence showing them to be ineffective. What limited
air circulation they provide can be counterproductive as
ventilation channels provide a route for warm, moist air to rise to
the top of the hold, increasing the possibility of sweat in that area.
Dunnage
To minimise the risk of costly claims caused by ship sweat it is
essential to prevent contact between the bags and any
adjacent steelwork.
In the absence of cargo battens or spar ceiling, suitable
dunnage should be placed against all frames and plating inside
the cargo holds to protect the bags from ship sweat which, in
addition to forming on vertical surfaces, may trickle
downwards over the lower hoppers and form pools of water
on the tank tops.
The dunnage should be laid so as to allow any sweat that
forms on cold surfaces to run off freely into the bilges without
coming into contact with the adjacent bags. Standard
dunnaging practices have been developed for this purpose,
although the precise arrangements may vary depending on
the port of loading, and the type and availability of dunnage
and other protective materials. Dunnage disposal
arrangements at the discharge port should also be considered
as some countries do not allow certain types of wood,
particularly bamboo, to be removed from the ship.
Traditional Dunnaging Arrangement
Traditionally, bamboo poles are laid fore and aft on the tank
tops in rows not more than 20 cms apart. A second layer of
bamboo poles is then laid on top at right angles and the two

Photo courtesy of: ETIC/Africa P&I Services
Rattan mats used in the traditional dunnaging arrangement
layers are interwoven or tied together to form a grid, making
sure that water can still run towards the bilges unhindered.
Similar bamboo grids should be laid against the lower hoppers
and the side shell plating, but not necessarily against internal
bulkheads as the formation or passage of ship sweat is unlikely
in these areas. The bamboo poles should be inspected to
verify that they are clean and dry. Any young, green bamboo
poles should be rejected as they may be crushed by the
weight of the stow and release moisture which may stain the
bags. Thin bamboo poles may not provide sufficient
separation between the steelwork and the cargo and should
not be used. Insufficient quantities of bamboo poles will
produce large gaps between adjacent poles and may not
prevent bags from touching the hold steelwork. Consequently,
checks should be made before loading to ensure that sufficient
materials of acceptable quality are available for dunnaging
purposes.
Timber may sometimes be used instead of bamboo, laid out
as “double dunnage” in a similar manner to the bamboo poles,
again with the first layer running fore and aft. The wood should
be of sufficient thickness, clean, dry, resin-free and without
damage or odour.
The bamboo dunnage on the tank top, lower hoppers and on
the side shell plating should be covered with reed or rattan
mats, or with kraft paper. Areas of steelwork where the
formation of ship sweat is unlikely (eg bulkheads between
holds), or where sweat migrating to the bilges will not generally
pass, need only be covered with matting or kraft paper when
the bags are loaded to protect against staining, chafing and
minor physical damage.
On completion of loading the entire surface of the stow should
be covered with kraft paper, not just the area within the hatch
square.
Allied Maritime Dunnaging Arrangement
As an alternative to bamboo poles and matting, plastic sheets
and styrofoam boards are sometimes used as a barrier to
prevent the bags from touching the hold steelwork. This is
generally known as the Allied Maritime system which is
becoming more common. At least one layer of kraft paper
should be laid on the tank tops and the lower hoppers
followed by a layer of plastic sheeting. Styrofoam boards are
then placed against the side shell plating and also covered
with plastic sheeting. Although styrofoam boards may be laid
against internal bulkheads, their use in this area is not generally
required as the formation or passage of ship sweat is unlikely.
Internal bulkheads may therefore be covered with plastic
sheeting and kraft paper. Kraft paper or plastic sheeting should
then be laid across the full surface of the stow.
However, there is a fundamental flaw in this dunnaging system
as although this method protects the cargo from any ship
sweat that may form on the shell plating, it does not raise the
bags clear of the tank top or lower hoppers, leaving the bags
at the bottom of the stow susceptible to damage due to sweat
running down the lower hoppers and accumulating on the tank
top. Similarly, the careless use of plastic sheeting or the
presence of creases in the sheets may hamper the drainage
of any sweat that may form during the voyage or bring it into
direct contact with the cargo. Due to the potential for cargo
to come into contact with sweat using this dunnaging
arrangement, its use is not recommended.
General Dunnaging Considerations
As ship sweat does not usually form on internal hold
bulkheads or the engine room bulkhead, the principal purpose
of dunnage in these locations is to provide a barrier between
the cargo and the steelwork to prevent rust staining and to
protect the bags from minor physical damage. The dunnage
may consist of kraft paper, matting or plastic sheets. However,
if the forepeak tank is to be ballasted with cold water, sweat
may form on the forward bulkhead of No 1 hold, requiring
additional dunnaging in this area.
Although kraft paper is used extensively in the dunnaging of
bagged rice cargoes, its limitations need to be recognised.
Kraft paper is used to minimise the possibility of damage due
to rust staining and abrasion but provides little protection
against wetting. Once saturated, kraft paper is easily damaged.
On some occasions the shipper may attempt to save costs by
reducing the quantity of dunnage, for example by providing
only one layer of bamboo poles. In such an event the master
should issue a letter of protest immediately.
 Loss Prevention Bulletin

The Allied Maritime dunnaging arrangement

Photo courtesy of: ETIC/Africa P&I Services

Styrofoam boards and plastic sheeting used in the Allied Maritime dunnaging arrangement
Moisture Content, Temperature and Sampling
Moisture Content
The moisture content of rice is an important factor in its
successful carriage. Rice is a hygroscopic commodity that can
either absorb or release moisture. Excessive amounts of
inherent moisture reduces storage life and increases the risk
of mould, discolouration, decay, malodour and caking (ie when
rice grains stick together). “Moisture migration” from the
warmer to the cooler parts of the cargo may also occur,
possibly causing the cargo to deteriorate in the latter areas. It
is therefore important that the rice is not unduly moist when
presented for shipment and is kept as dry as possible
throughout loading, on passage and during discharge.
When harvested, rice still in its husk will have a moisture
content of up to 30%. The rice will then be dried, either
mechanically or naturally, the former method being more
effective. On completion of drying the rice will generally have
a moisture content of less than 20%. Milling and additional
processing reduces the moisture content still further.
The moisture content of a rice cargo should not exceed 14%
at the time of shipment. Typically the moisture content will be
between 12% and 14%. Since any figure certifying the
moisture content will always be an average amount, it should
be borne in mind that some of the rice may have a moisture
content up to 0.5% higher. Some shippers may attempt to
export rice before it has dried sufficiently for shipment, mixing
it with rice with a lower moisture content to obtain an average
of 14% or less. In such cases the rice with a high moisture
content may still deteriorate and damage other rice in the
immediate vicinity while on board. Rice with a moisture content
of 13% can usually be stored for approximately 12 months.
Since rice is sold by weight, unscrupulous shippers may not
be particularly concerned if the moisture content is
unacceptably high at the time of shipment. They will also be
aware that if the excessive moisture content causes the rice
to deteriorate on passage, the receiver will usually allege that
the vessel failed to ventilate the cargo correctly.
Given the claims-sensitive nature of bagged rice, it is
customary to appoint a local surveyor. The local surveyor will
often be equipped with a portable moisture meter to test and
record the moisture content of the rice prior to and during
loading. Portable moisture meters need to be calibrated
specifically for rice and may only be accurate to +/- 0.5% even
when functioning correctly. It is not unusual to find inaccurate
portable moisture meters being used, therefore the results
obtained from them should be treated with caution.
If the average moisture content of the rice is declared to be
over 14%, or if the portable moisture meter readings taken by
the local surveyor indicate a moisture content approaching this
figure at any stage, the Club should be informed as it may be
necessary to arrange for samples to be taken jointly with cargo
interests and sent to a mutually acceptable laboratory for
accurate analysis. The Club’s local correspondent should be
able to advise which laboratories are suitable.
Temperature
The surveyor should check and record the temperature of the
rice regularly throughout loading. Rice delivered to the vessel
directly from the mill after processing may be significantly
warmer than rice has been stored in a warehouse, possibly
resulting in cargo deterioration or self-heating on passage. If
concerns arise during loading that the temperature of the rice
may be excessive, the Club should be contacted for advice.
Records showing the temperature of the rice during loading
will also be required if the vessel is planning to ventilate the
cargo holds using the “Three Degree Rule”.
Sampling
Representative samples of rice taken periodically during
loading can be of assistance in defending claims if the cargo
deteriorates on passage. However, a full time sampling team
would need to be present throughout the entire loading
process for the samples to be truly representative of the cargo
as a whole.
Rain
Since rice is highly susceptible to water damage, it is good
practice to keep all hatch covers closed during cargo
operations other than the holds being worked. The weather
conditions should be monitored closely throughout, ideally
using the 3 cm radar (if permitted by the port) to provide early
warning of approaching rain so that cargo operations can be
suspended and the hatch covers closed in good time. The use
of tarpaulins or hatch tents over open hatches is not
recommended as they often fail, resulting in water pouring on
to the cargo.
A close eye should be kept on rice arriving by truck or barge,
particularly if not protected by tarpaulins, looking for any signs
that the bags may have been exposed to rain. If wooden
barges are used, checks should be made to confirm that the
bags have not been affected by water leaking through the hull.
On some occasions the charterer may ask the master to load
rice during rain in exchange for a Letter of Indemnity (LOI),
sometimes referred to as a “Rain Letter”. The master should
not agree to such a proposal as the charterer may still maintain
that any subsequent deterioration of the cargo was due to
inadequate ventilation on passage rather than rain damage.
More importantly, and irrespective of a Letter of Indemnity,
intentionally loading rice during rain may prejudice Club cover
on the grounds that such an act was imprudent or improper
contrary to the provisions of Rule 19(1).

Cargo Space Ventilation
Since rice is hygroscopic and readily absorbs and releases
moisture, it is essential that correct ventilation procedures are
followed in order to:
• Remove moist air from the cargo holds, and
• Prevent the formation of ship sweat which may wet and
damage the cargo.
Since these two requirements are interlinked, the principles of
ventilation need to be understood and applied correctly to
ensure that the cargo is discharged in good condition.
Tests and Checks
Prior to loading the entire ventilation system for the cargo holds
should be checked. Where fitted, the hold fans should be
tested to ensure that they are functioning correctly. Mechanical
ventilation rather than natural ventilation tends to be slightly
more effective in achieving sound outturns.
Ventilation Requirements
Ventilation of the cargo spaces should be carried out
according to either the “Dew Point Rule” or the “Three Degree
Rule”. Due to the difficulty of obtaining accurate dew point
measurements from within closed holds, the “Three Degree
Rule” is considered to be a more robust method for
determining when ventilation should be carried out.
Consequently, cargo temperatures should be taken and
recorded throughout loading to enable this rule to be applied.
Detailed guidance on the two ventilation rules can be found in
the Club’s Loss Prevention Bulletin “Cargo Ventilation and
Precautions to Minimise Sweat”.
Photo courtesy of: ETIC/Africa P&I Services
When a bag rests against steel that has been wetted damage will result
Loss Prevention Bulletin
Ventilation needs to be considered whenever the hatch covers
are shut and the holds contain rice, regardless of quantity. This
also includes periods in port if the hatch covers are closed due
to rain, or if the vessel is required to anchor at the discharge
port prior to berthing. However, if the cargo is fumigated on
departure the holds should remain sealed and ventilation
should not take place until the end of the waiting period
specified by the fumigation contractors.
The formation of ship sweat is highly likely when passing
through colder waters regardless of the ventilation method
employed, such as passing South Africa when trading
between South East Asia and West Africa. This reinforces the
need for careful dunnaging to prevent contact between the
cargo and any steelwork on which sweat may form or pool.
In order to defend any claims for cargo damage it is essential
that the vessel maintains a detailed ventilation log, including
temperatures and times of starting and stopping ventilation.
These may be used to demonstrate that the cargo was
properly ventilated in accordance with industry best practice
whilst on board. If it was not possible to ventilate as required
due to the weather conditions, such details should also be
recorded. Similarly, copies of any fumigator’s instructions
regarding the length of time the holds should remain sealed
should be retained as it may be necessary to show that the
vessel could not ventilate at a critical time during the voyage.
When weather and sea conditions permit, and if a full risk
assessment has been carried out and it is deemed safe and
practical to do so, consideration may be given to opening
sliding or folding hatch covers slightly to aid ventilation of the
 cargo when required. This may be beneficial during extended • Prevent stevedores from using equipment that may cause
stays at anchor while awaiting a discharge berth. cargo damage

Bilge Soundings
Cargo hold bilge soundings should be taken and recorded
twice daily. If water is found to be accumulating in the bilges,
the source should be investigated at the earliest opportunity. If
it is necessary to pump out the bilges, a written record should
be maintained of the quantity of water pumped overboard.
Loading Operations
Charterer’s Instructions
In some cases the charterer may provide the vessel with
written instructions regarding the loading, stowage, carriage,
ventilation and discharge of the rice. Reasonable instructions,
including demands for ventilation channels, should always be
followed as evidence of non-compliance may weaken the
vessel’s position if the cargo deteriorates on passage.
• Ensure the cargo is stowed in accordance with industry best
practice
• Arrange for bags to be weighed at random to check that
they are not underweight
• Reject torn bags
• Decline bags which appear to be contaminated (eg water,
oil, foreign matter)
• Refuse any bags exhibiting signs of deterioration (eg damp,
mould, rot, discolouration, unpleasant odour)
• Assist the master to clause the Mate’s Receipts and Bills of
Lading as necessary
When bags have been rejected, a careful watch should be
kept to ensure that no attempt is made to hide the rejected
bags under sound cargo about to be loaded in the hope that
they will not be noticed. This can be a particular problem when
loading from barges.

To avoid possible conflicts of

interest, Members should appoint a
protecting agent rather than relying
on the charterer’s agent. Similarly,
the sharing of surveyors and tally
clerks with cargo interests to save
on costs is not recommended.
Invariably the clerks will be
Photo courtesy of: ETIC/Africa P&I Services

appointed by cargo interests and

the cargo figures will often favour
the appointing party to the
detriment of the owner.

If possible, the master should ask to

The number of bags in each sling should be determined by accurate tallying
Surveyor and Tally Clerks
Members are advised to appoint their own surveyor and tally
clerks at the load port. The surveyor should be instructed to:
• Check the condition of the rice
• Monitor and record the moisture content and temperature
of the rice
• Confirm that all dunnaging material is suitable and properly
laid
see the appointment details of the
surveyors and tally clerks instructed
by cargo interests to ascertain
precisely who they represent.
Subject to crewing levels and compliance with hours of rest
regulations, the vessel should also endeavour to conduct its
own tally, comparing the ship’s figures at the end of each shift
with those produced by other parties. Details of reputable
surveyors and tally clerks may be obtained from the Club’s
local correspondent on request.
Since rice may be pilfered or lost en route to the vessel, the
cargo should be tallied during loading rather than at the
warehouse or barge loading facility prior to delivery.
If it is found that tally clerks are assuming that each sling or

Bags should be carefully slung to avoid damage
net contains a standard number of bags rather than
determining the exact quantity, a letter of protest should be
issued.
Cargo Damage
Any bags presented that are wet, damp, stained, torn,
malodorous or contaminated should be rejected and replaced
with sound cargo. Bags damaged during loading or found with
loose stitching should be returned ashore for repair or
replacement. Stevedores should be warned against using
hand hooks when stowing the cargo to avoid piercing the
bags and spilling the contents. They should also be instructed
to use slings that will not damage the bags. Final stowage of
bagged rice should always be carried out by hand.
If any bags are damaged during loading in spite of such
precautions, for example by the extensive use of hand hooks
contrary to the vessel’s instructions, the Mate’s Receipts
should be claused accordingly. It is essential that any clauses
added to the Mate’s Receipts are accurately reproduced on
the Bills of Lading regardless of whether they are to be signed
by the master or by an authorised third party. Consideration
should be given, where commercially possible, to clausing the
Bills of Lading with the words “London Arbitration and English
law to apply”. This can be useful if cargo interests attempt to
use a legal forum that may be sympathetic to their claim.
Empty bags will normally be provided by the shipper so that
rice spillages during discharge can be re-bagged and landed
Loss Prevention Bulletin
Photo courtesy of: ETIC/Africa P&I Services
ashore for delivery to the receiver. Such bags should be clean,
dry and suitably stowed for the voyage.
Cargo Separation
If the vessel is to discharge at more than one port or if there
are several receivers, it is essential that the different parcels of
rice are separated both horizontally and vertically to minimise
the possibility of the incorrect number of bags being
discharged.
Infestation of Cargo
Rice cargoes are susceptible to infestation, particularly if stored
for several months before shipment. Rice transported to the
vessel aboard barges that have not been properly cleaned
may be exposed to a similar risk. Should the cargo exhibit any
signs of infestation (eg beetles, weevils, moths, rodents), the
Club should be notified immediately as expert advice may be
required.
Cargo Fumigation
It is common for rice cargoes to be fumigated on completion
of loading. The instructions of the fumigation contractors
should be strictly followed, and warning notices should be
placed on all hold access arrangements stating that fumigation
is in progress and that entry is prohibited. Reference should
be made to MSC.1/Circ.1264 “Recommendations on the Safe
Use of Pesticides in Ships Applicable to the Fumigation of
Cargo Holds” as amended. The cargo holds should remain
sealed and ventilation should not resume until the end of the
waiting period specified by the fumigation contractors. It has
been reported that some rice shipments from Thailand,
Myanmar and Vietnam have been fumigated with methyl
bromide while in transit, contrary to IMO recommendations
that methyl bromide should only be used in port with no crew
on board. If cargo interests state that they plan to fumigate the
holds during the voyage using methyl bromide, permission
should not be granted and the Club should be contacted for
advice.
One of the most common fumigants in use is phosphine which
is a colourless and extremely toxic gas, which smells of garlic
at low concentrations. Aluminium phosphide tablets or pellets
are placed on the surface of the cargo and release phosphine
gas after reacting with moisture in the air, leaving behind
deposits of grey-white powder on top of the cargo. Since the
presence of residues may cause difficulties with some
receivers and/or the stevedores at the discharge port, it is
recommended that the fumigation contractors are asked to
use small bags or sachets of aluminium phosphide specially
designed to capture such deposits. It should also be noted
that the United States Environmental Protection Agency does
not permit any processed commodity, such as milled rice, to
come into contact with aluminium phosphide residues.
IMO recommends that fumigated cargo is discharged by
mechanical means only. However, this is practically impossible
in the case of bagged rice.
Sealing Cargo Holds
To minimise the risk of shortage claims it is advisable for the
vessel’s surveyor to seal the hatch covers and hold accesses
upon completion of loading, preferably witnessed by the
surveyor appointed by cargo interests. Prior to closing the
hatches it is recommended that high resolution digital
photographs are taken of the cargo stow and dunnaging
arrangements.
Draft Survey
If the weight of the cargo is to be entered on Bills of Lading
either in place of, or in addition to the number of bags, initial
and final draft surveys should be undertaken at both the load
and discharge ports. Again, the surveyor representing cargo
interests should be invited to attend. Invitations should be in
writing and, if possible, should include a sentence stating
“Please be informed that the findings and results of the draft
survey will be considered joint and binding”.
Records
A comprehensive log of all cargo operations should be
maintained by the vessel including details of any stoppages.
Copies of all cargo documentation (eg cargo quality
certificates if provided, tally reports, statements of fact, cargo
manifests, stowage plans, letters of protest, photographs,
Mate’s Receipts, Bills of Lading) should be retained on board.
Photographs
Ideally, high resolution digital photographs of the dunnaging
arrangements should be taken prior to loading. Photographs
of the stow and the ventilation channels (if built) should also
be taken at regular intervals during loading. All photographs
should be captioned or catalogued so that the hold and the
location within the stow can be identified. Such evidence may
prove to be very useful in helping to defend any claims that
may arise at the discharge port.
Letters of Protest
If it becomes necessary for the master to issue a letter of
protest during loading or discharge, as many details as
possible should be included regardless of the recipient (eg
shipper, receiver, charterer, stevedores, agent). Remarks of a
general nature should be avoided as they may weaken the
owner’s case in the event of a subsequent cargo dispute.
A letter of protest may be warranted in the following
circumstances, but the list is not exhaustive:
• Rice which appears to be visibly wet, mouldy or heated
• Vessel’s crew and/or surveyor prevented from taking rice
samples
• Insufficient dunnaging material provided to the vessel
• Dunnage supplied in a dirty or wet condition
• Poor quality dunnage being used (eg small diameter or
young bamboo poles)
• Dunnage not laid in accordance with standard industry
practice
• Bags damaged by the use of hand hooks or inappropriate
slings
• Cargo not stowed in accordance with industry best practice
• Damaged cargo not replaced with sound cargo
• Signs of cargo infestation
• Signs of cargo deterioration
• Pilferage by stevedores or other parties
• Cargo operations continuing during rain
• Tally clerks using an assumed figure for the number of bags
in each sling or net
• Cargo loaded from or discharged to wet facilities (eg wharf,
trucks, barges)

• Cargo tallied anywhere other than on board or alongside the
vessel (eg warehouse)
• Failure of receiver’s surveyor to sign the vessel’s outturn
reports
If any letters of protest regarding the condition of the cargo are
issued at the load port, the Mate’s Receipts and Bills of Lading
should be claused accordingly.
Discharging Operations
Surveyor and Tally Clerks
To minimise the possibility of shortage or quality claims,
Members are advised to appoint a local surveyor and a tally
company at the discharge port. The local Club correspondent
will be able to provide details of independent local survey and
tally companies that they consider to be reputable and
trustworthy. Since cargo interests will almost certainly make
similar arrangements, the master should record the details of
all surveyors and tally companies appointed and who they
represent. Subject to resources and compliance with hours of
rest requirements, a further tally should be carried out by the
crew to monitor the figures produced by the tally companies
acting for the vessel and cargo interests respectively. It is also
recommended that Members appoint their own protecting
agent rather than the agent acting for the charterer.
Photo courtesy of: ETIC/Africa P&I Services
The large number of bags involved means accurate detailed tallying is necessary
Loss Prevention Bulletin
All tallies should take place on or alongside the vessel.
However, it is not uncommon for receivers to tally the cargo
only when it arrives at their warehouse, increasing the risk of
cargo being lost or pilfered en route. The master should issue
a letter of protest should such a situation arise, making it clear
that the receiver’s tally was not conducted on board.
In the event of a shortage claim that leads to litigation or
arbitration, the methods employed to tally the bags may be
scrutinised. As far as possible the following information
regarding the tallying operation carried out on behalf of the
vessel and by all third parties should be recorded:
• Details and times of any cargo holds discharged
concurrently
• The number of tally men per hold acting for the vessel and
for each third party respectively
• The location of the tally men (eg in the hold, on deck, on the
quay)
• The tallying methods used (eg whether the bags were
counted individually or if it was assumed that each sling or
truck contained a certain number of bags)
• Whether the third party tallies were carried out individually,
or if there appeared to be collusion between them regarding
the number of bags discharged.
 Unsealing Cargo Holds
The surveyor appointed by cargo interests should be invited
to attend when the vessel’s surveyor removes the seals at the
discharge port. Once the hatch covers are opened, high
resolution digital photographs of the cargo surfaces and
coamings in each hold should be taken before the bags are
discharged. Such photographs will provide clear evidence of
the apparent condition of the top of the cargo on arrival and
may help to refute any subsequent allegations of hatch cover
leakage.
With multiple discharge ports it may be worthwhile re-sealing
the holds containing cargo after each intermediate discharge
port as there have been instances in the past where vessels
arriving with unsealed holds have been fined by Customs.
Local port agents should be consulted in this respect.
Cargo Condition
If the top tier of bags or the kraft paper covering the surface
of the stow show signs of water damage or water stains, the
location of the damage in relation to the hatch coamings,
hatch vents and hatch cover cross joints should be recorded
and photographed. Fresh rust stains or streaks on the inside
of the hatch coamings, on the underside of the upper hoppers
or on top of the bags or kraft paper may signify sea water
ingress on passage. Testing for chlorides with silver nitrate will
generally indicate whether or not this was the case.
Any damp or water damaged bags found during discharge
should be recorded and photographed, noting their precise
location within the stow and whether the staining/wetting
Photo courtesy of: ETIC/Africa P&I Services
Moisture found behind plastic sheeting used in the Allied Maritime dunnaging
arrangement
corresponds with possible contact with steelwork. If
surrounded on all sides by sound cargo, the bags may have
been damaged before loading by rain or while on board a wet
barge. Alternatively, cooling at the edges of the stow or
pockets of self-heating may have produced a temperature
differential resulting in moisture migration, or the rice itself may
have been excessively moist on loading resulting in localised
deterioration. Water damage to bags on the tanktop, lower
hoppers and at the ship’s sides is usually indicative of contact
with ship sweat.
If various bags are found to be discoloured or stained brown,
checks should be made to determine whether they were
stowed against a hot surface such as heated fuel oil tanks.
Parboiled rice seems to be more susceptible than others to
this type of damage.
Glazed white rice may be affected by caking if the coating was
not properly applied or was otherwise defective, rather than
due to excessive moisture.
Any evidence of damage or deterioration should always be
photographed, recorded and reported to the company
immediately. The surveyor acting on behalf of the ship should
also investigate the damage to ascertain whether it was
caused by the vessel, a third party or an inherent vice of the
cargo. Depending on the extent, severity and cause of the
damage, it may be necessary to appoint an expert to provide
further advice.
If rice is seen to suffer damage after it has been discharged in
sound condition (eg if bags are left standing on the quay during
Photo courtesy of: ETIC/Africa P&I Services
Kraft paper showing rust spots and signs of having been wetted and then dried

Traditional dunnaging arrangement with evidence of the passage of moisture over the lower hopper
rain or if bags on trucks or barges are not promptly covered
with tarpaulins during rainfall), the master should issue a letter
of protest as a precaution.
If rice is loaded in very cold conditions (eg Northern China in
winter) and is discharged in a much warmer location, cargo
sweat may form on the bags during discharge or after landing
ashore. Such bags should not be placed into storage until the
sweat has dried off.
Outturn Reports
The tally clerks should be instructed to prepare an outturn
report documenting the number of sound bags and the
number of damaged bags discharged each day. The type of
damage should be specified (eg torn, damp, wet, mouldy,
stained or caked). The records should also state the number
of bags filled with sweepings from the hold, pilfered, lost
overboard during cargo operations, found empty, or gifted by
cargo interests to third parties.
If the master is asked to approve daily outturn reports
produced by tally clerks acting for cargo interests, he should
sign them “for receipt only”. However, if cargo interests are
willing to endorse the vessel’s tally records, the master may
Loss Prevention Bulletin
Photo courtesy of: ETIC/Africa P&I Services
sign such outturn reports, adding any qualifying comments as
necessary. Both sets of tally figures will almost certainly differ
each day. However, this is not necessarily a cause for concern
unless the difference is large. In such an event, or if the figures
are identical, the local Club correspondent should be
contacted for advice.
Cargo Faces
The officer in charge of the cargo watch should ensure that
the stevedores discharge the bags evenly and do not leave
any high, exposed, vertical cargo faces. Unsupported cargo
faces often collapse, resulting in fatalities, injury and cargo
damage.
Cargo Sweepings
When sweepings are re-bagged, the new bags are often over-
filled to the point where they may exceed the weight of a
standard sound bag by a significant margin. If the amount of
sweepings on board is large, this may result in an apparent
shortage. Similarly, counting errors may arise if tally clerks
assume that each sling or net contains a specific number of
bags rather than determining the actual quantity. If either
practice is observed, a letter of protest should be issued.
Photo courtesy of: ETIC/Africa P&I Services
High unsupported cargo faces should be avoided due to the danger of collapse
Pilferage and Theft
The risk of rice being pilfered or stolen in many discharge ports
is well recognised. Typically, stevedores inside the cargo holds
will cut open bags and transfer the contents into small plastic
bags, concealing them under their clothing when they leave
the ship. While one may sympathise with those who take a
small quantity of rice to feed themselves and their families, it
is not uncommon for such a practice to be organised by local
racketeers and for stevedores to make several trips ashore
with pilfered rice during the same shift.
Stevedores who are challenged can be threatening or violent
and may also try to intimidate security personnel so that they
can continue their pilfering activities unhindered. On a
somewhat larger scale there have also been cases where rice
has been discharged directly into trucks operated by thieves
rather than the receiver.
In order to control pilferage it is recommended that Members
appoint their own security guards, preferably with dogs, as a
deterrent. Although it is unlikely that such measures will
eliminate the risk, it is possible that potential thieves may look
for an easier target elsewhere.
Anyone seen inside a cargo hold who does not appear to be
a stevedore should be asked to leave. If pilferage is observed,
those involved should be told to stop and security personnel
should be instructed to escort them ashore and prevent them
from returning. Any holds not being worked should be closed
and accesses locked.
Should pilferage begin to escalate beyond control, the vessel
may threaten to close the hatch covers and suspend cargo
operations until all parties agree an appropriate course of
action. However, such a step should not be taken lightly and
both owners and the local Club correspondent should be
consulted first. If it is necessary to halt cargo operations due
to pilferage, the stoppage should be kept to a minimum as the
port authority may order the vessel to vacate the berth if there
are other vessels waiting to discharge, or may impose a fine
for occupying a berth while idle.
If these measures fail to reduce pilferage, the master should
issue a letter of protest holding cargo interests responsible for
such losses and circulate it to all interested parties.
Records
A comprehensive record of cargo operations should be
maintained by the vessel throughout discharge, including
details of all stoppages.
Photographs
High resolution digital photographs of the cargo and discharge
operations should be taken throughout. However, this may not
be possible in some ports where the stevedores may react
aggressively.

Photo courtesy of: ETIC/Africa P&I Services
Large quantities of sweepings may give rise to an apparent shortage due to overfilling of bags
Rice in Bulk
International Grain Code
The safe carriage of rice in bulk is governed by IMO’s
“International Code for the Safe Carriage of Grain in Bulk”, also
known as the “International Grain Code”. To meet the required
stability requirements, holds are usually filled so that there is
minimal or no free air between the top of the stow and the top
of the hold. In partly filled holds the cargo may be covered with
tarpaulins or similar and either overstowed with bags or other
suitable cargo. In both cases this makes ventilation difficult.
However, standard ventilation procedures should still be
followed and recorded.
Hold Preparation
In addition to ensuring that the cargo holds are cleaned in
accordance with the section on Hold Cleanliness, all steelwork
coatings inside the holds should be in good condition (eg tank
tops, hopper tanks, topside tanks, undersides of hatch covers,
ladder rungs, vent pipes). In addition, the charterer or shipper
should be asked whether they have any specific hold cleaning
requirements to minimise the possibility of delays and
additional expenditure at the load port.
Bilge plates should be covered with burlap (hessian) cloth or
similar to prevent rice from entering the bilge wells.
Loss Prevention Bulletin
Dust
Dust can be produced during loading operations, although
usually less than for bulk grain. However, it may be advisable
to protect sensitive equipment such as radar scanners and for
personnel on deck to wear suitable Personal Protective
Equipment (PPE) such as safety goggles, dust masks and long
sleeved overalls.
Surveyor
In common with rice in bags, rice is equally claims-sensitive
when carried in bulk. Members are again advised to appoint
an independent surveyor and their own agents at the load and
discharge ports to protect their interests. The surveyor should
be instructed to:
• Conduct initial and final draft surveys
• Check the condition of the rice
• Monitor and record the moisture content and temperature
of the rice
• Check for any infestation or contamination of the rice
• Reject any unsound rice
• Provide the vessel with sealed cargo samples taken
throughout loading from all holds
• Seal the cargo holds on completion of loading/unseal the
cargo holds prior to discharge
 Loss Prevention Bulletin

• Assist the master to clause the Mate’s Receipts and Bills of

Lading as necessary

Appointing a single surveyor or port agent to act for both cargo

interests and the vessel is unwise as the surveyor will be
inclined to favour the former. Employing independent security
guards at the discharge port is recommended. Cargo interests
should be invited to attend all draft surveys and the
sealing/unsealing of the holds.

Bagging upon Discharge

Bulk rice will sometimes be bagged on the wharf under the
ship’s hooks. Cargo interests and their surveyors will often
produce daily outturn reports stating the number of bags
discharged. When presented with such reports the master
should add suitable remarks to make it clear that the amount
of cargo discharged was not measured accurately and was
based on a theoretical weight per bag (usually 50 kg).Bagging
machines are notoriously inaccurate and need to be re-
calibrated and the weight of bags rechecked on a regular
basis, ideally at least once an hour. As far as possible,
surveyors should weigh bags produced by bagging machines
at random to check for anomalies.

Records and Photographs

A comprehensive log of all cargo operations should be kept
by shipboard personnel including details of any stoppages. A
photographic record should also be maintained, ideally taking
high resolution digital images of the rice being loaded, the top
of the stow in each hold before the hatch covers are closed,
the condition of the cargo when the hatch covers are opened
at the discharge port and at frequent intervals during discharge.

Members requiring further guidance should contact the Loss

Prevention department.

West of England Insurance Services (Luxembourg) S.A., Tower Bridge Court, 226 Tower Bridge Road, London, SE1 2UP
Loss Prevention Dept: T: +(44) (0)20 7716 6106 F: +(44) (0)20 7716 6061 E: loss.prevention@westpandi.com W: www.westpandi.com
Loss Prevention Bulletin

Bunkering Procedures
Members will be aware that the financial consequences of a pollution
incident during bunkering are becoming increasingly severe.

For example, one recent claim
amounted to US$ 3.6 million. Any
spill, no matter how small, may result
in penalties and costs far outweighing
the apparent gravity of the event.
Costs involved and consequential
reputational losses reinforce the need
for all shipowners to mitigate the risks.
Apart from claims arising as a result
of pollution of the environment,
disputes related to quantity or quality
of fuel delivered on board are far more
frequent. Although not as costly as
pollution claims in monetary terms, such
cases often require time to resolve.
Procedures to be followed during
bunkering operations will be detailed in
a vessel’s Safety Management System.
However, this Bulletin has been written
in order to reiterate best practice and
includes a number of recommendations
regarding the items that should be
checked and verified throughout
the various stages of the operation.
These are summarised in the form of
a loading plan and checklist, either
for direct use by the ship or to assist
Members in reviewing or formulating
their own versions. Utilising a loading
plan and checklist and following a
predetermined routine may minimise
the likelihood of important safeguards
being overlooked.
Members requiring a more
comprehensive account of prudent
procedures relating to bunkering
are referred to the IMO publication
“Manual on Oil Pollution Section
1 - Prevention” and to Singapore
Standards for Bunkering – SS 600 and
SS 524.
Some of the issues to bear in mind are
however as follows:
A senior engineer should always be
appointed to co-ordinate and take
charge of the bunkering operation,
and it is intended that the loading
plan and checklist be used by this
officer. He should first ensure that
all crew members involved in the
exercise are fully conversant with the
specification and quantity of fuel to
be lifted, the ship’s fuelling and tank
sounding arrangements, the alarm
systems and the loading sequence
It is of primary importance that all
personnel on board are made aware
of the intention to bunker so that
the vessel’s emergency response
plan can be activated without
delay in the event of a spill. In
addition, it should be remembered
that the bunkering facility itself
may be the source of a spill, and
the contingency arrangements of
the barge or terminal should be
checked and discussed beforehand.
In case of a pollution incident
originating from the bunkering
facility or if Bunkering Procedures
Loss Prevention Bulletin the source
of the pollution is unclear, the ship
should not automatically assume
their own innocence in the incident.
In any event the crew must take
all necessary measures to prevent
further worsening of the incident

Bunkering operations offshore

should be treated as Ship-to- Ship
(STS) operations and the guidance
contained in the latest edition of the
Oil Companies International Marine
Forum (OCIMF) STS Transfer Guide
should be followed.
Loss Prevention Bulletin
Clear and detailed drawings of the
vessel’s bunkering system must be
available for use by members of the
ship’s bunkering team during the
operation and it is recommended
that a piping diagram be posted in a
suitable location for easy reference
by the bunkering team. As well
as aiding the routine checking of
pipeline configurations, access
to such diagrams may prove
indispensable in an emergency.
In case of any modifications the
pipeline drawings must be updated
accordingly and only the latest
revision used
Receiving tanks and respective
valves should be tagged for easy
identification. Remember the valve
handling rule: Open First – Close
Second
All bunker tank vent heads shall
be marked with the identity of
the tank and proven to be free of
obstructions to allow the escape of
displaced air
Save-alls are to be dry and clean,
and plugs to be fitted in position.
The save-alls should be drained
regularly during rain
When agreeing signalling procedures
with the terminal or barge, Members
are advised to consider using an
audible alarm to supplement an
emergency stop, recognisable by
all parties. This additional defence
may secure a swifter response than
relying entirely on VHF contact or
other methods of signalling.
It is advisable to request from the
supplier to provide your vessel with
a remote emergency stop for the
bunker transfer pumps on board
of the barge
To reduce the chance of
misunderstandings still further,
the key elements of the bunker
plan may be summarised in writing
and signed by both the responsible
bunkering officer and the supplier
as confirmation of mutual agreement
The duty officer should keep in close
contact with the ship’s bunker team
throughout, while the bunker team
should regularly check the agreed
communication channels with the
bunkering facility
Over filling of bunker tanks may
result in spillage and consequently
expose the Member to significant
claims, penalties and clean-up costs
of extraordinary proportions. It is
advisable that the filling level in
bunker tanks is limited to 90-92%
by volume
Moorings should be tended to ensure
that the movement of the vessel is
restricted to a minimum and that the
ship, as far as practicable, is kept
upright and on an even keel
Check the Bunker Delivery Note
(BDN) presented by the barge to make
sure that the delivered fuel complies
with the contractual specification and
statutory requirements. Information
which must be provided in the BDN
can be found here
Take regular soundings of the tanks.
Reduce measurement intervals when
the tank level exceeds 60-70%. If
several tanks are being bunkered,
reduce sounding interval as soon
as the first receiving tank is full and
isolated. Keep an eye on the isolated
tanks as well as on the tanks not
being bunkered in order to make
sure that the level in such tanks
remains constant
Do not exceed the maximum
line pressure

Give a supplier timely warning to
reduce the pumping rate when
“topping up” the tanks. The rate
of delivery must be reduced when
any of the filling valves needs to be
closed. All filling valves must never
be closed before the bunkering
has been completed and the hoses
and the filling pipelines have been
blown through with compressed
air and drained
Any spill during a bunkering
operation must be immediately
reported to the appropriate
authorities and corresponding
measures taken in accordance
with the vessel’s SOPEP / SMPEP
Bunkering operations have to be
entered in the Deck and Engine log
books. Relevant contemporaneous
entries must be made in the Engine
Room Oil Record Book as required.
The importance of keeping accurate
and sufficient records cannot
be overemphasised
The final bunkered volume figures
must be corrected to allow for the
vessel’s trim and list at the end of
the bunkering. The weight of the
bunkered fuel should be calculated
using the standard density figure
provided on the BDN and corrected
to the actual temperature of the
delivered fuel. In case of a significant
difference the BDN (or receipt,
if a separate document) should
be signed “for volume only”
Loss Prevention Bulletin
Fuel surveying companies
use various formats of tank
measurement reports. Useful
abbreviations:
TOV Total Observed Volume
GOV Gross Observed Volume
GSV Gross Standard Volume
GSW Gross Standard Weight
VCF Volume Correction Factor
WCF Weight Conversion Factor
During the course of bunkering,
representative samples must
be taken and retained in line
with company and regulatory
requirements. The MARPOL
sampling procedure has been
published by the IMO in Resolution
MEPC.182(59) – 2009 Guidelines
for the Sampling of Fuel Oil for
Determination of Compliance with
the Revised MARPOL Annex VI
The bunker fuel quality should
be tested by a reputable shore
laboratory and results received
and reviewed prior to using the
fuel. It is recommended that
the laboratory is accredited in
accordance with ISO 17025
Technical aspects of the bunker quality
sampling and disputes are discussed in
the Loss Prevention Bulletin.
If these basic principles of bunkering
are followed, exposure to associated
losses should be reduced.
Loss Prevention Bulletin

Bunkering Loading Plan and Checklist

Vessel Port

Date Supplier

Tank Loading Plan

Tank

Sounding/ullage prior
to bunkering

Volume in tank prior

to bunkering

Volume to be loaded

Sounding/ullage interval
and measurement

Valve id – time
opened/closed

Planned sounding/ullage
on compl.

Planned volume in tank

on compl., 90% of total
tank capacity

Actual sounding/ullage
on compl.

Actual volume in tank on

compl., % of total tank
capacity
 Loss Prevention Bulletin

Tank Loading Plan

To be checked and signed off by the vessel, supplier, or both as appropriate.

No. Checkpoint Vessel Supplier

Prior to Bunkering

1 Ensure all personnel are aware of the intention to bunker and of the
emergency response procedures. Review SOPEP / SMPEP manual
and confirm local contacts in case of pollution incident

2 Ensure all personnel involved in the bunkering operation are wearing

appropriate PPE

3 Discuss bunkering plan and tank sequence with officers involved

and ensure the tank loading plan is completed

4 Establish and check the common communication link between

bunkering station, duty officer and engine room, using intrinsically
safe radios

5 Close and secure all associated overboard discharge valves

6 Close all unused manifold valves and blank off manifold connections
using all securing bolts, properly tightened, with a gasket in place

7 Plug all deck scuppers and make oil/watertight

8 Provide means of draining off any accumulations of water on deck

9 Empty out and plug save-alls for manifolds and bunker tank vents

10 Check all bunker tank air pipes are open and unblocked

11 Reconfirm space remaining in all bunker tanks to be filled

12 Ensure all sounding pipe caps are tight, except when sounding tanks

13 Check that all bunker tank lids are closed and secured

14 Check all bunker tank high level alarms are functioning

15 Ensure designated overflow tank is prepared

16 Take the fuel transfer pump out of AUTO mode and make sure it is OFF

17 Place SOPEP equipment (sawdust, sand, absorbent pads, empty

drums, squeegees, brushes etc.) in key locations ready for use

18 Ensure suitable “no smoking / no naked flame” warning

notices are posted

19 Place firefighting appliances ready for immediate use.

Rig fire hoses fore and aft (if applicable)

20 Ensure all external accommodation superstructure doors and ports/

windows are kept closed

21 Ensure the radars are on standby or switched off and the main radio
aerials have been earthed

22 Check that VHF/AIS units are either switched off if not in use or
operating on low power (1 watt or less).

23 Check that all flag or light signals required by local regulations

are displayed

24 Inform Port Control about start/stop bunkering operation

Loss Prevention Bulletin

No. Checkpoint Vessel Supplier

25 When bunkering from a barge ensure there is sufficient fendering

between vessels so there is no metal to metal contact

26 Ensure there is a safe means of access, adequately illuminated,

in place between the vessels

27 Ensure that the barge is securely moored alongside

28 Check the weight of the bunkering hose including weight of the fuel
inside it does not exceed the SWL of vessel’s lifting gear in case it
will be used

29 Check hose is of such a length that there is sufficient play to allow

for movement, and that it is adequately supported

30 Ensure that the transfer hose if properly rigged, lined up and bolted

31 Inspect hose and couplings for damage

32 Install a fuel sampling device making sure it is clean and fit

33 Place drip trays under hose couplings, flanges and the sampling device

34 Check that Gravity, Viscosity, Flash point, Water content, Sulphur

content and delivery Temperature are correctly* stated in the bunker
delivery note

35 Ensure that Material Safety Data Sheets have been provided

for each grade of fuel being stemmed

36 Discuss bunkering plan with supplier

37 Agree with supplier the quantity of oil to be pumped aboard

38 Agree unit of measurement (cubic metres have to be converted

into metric tons using a proper procedure)

39 Agree maximum pumping rate and pressure. Agree to begin bunkering

at a reduced pumping rate and agree to reduce pumping rate and
pressure when closing off receiving bunker tanks

40 Bunker tank content measurements to be done at regular intervals:

Tanks being filled -------------- interval
Tanks not in use -------------- interval

41 Discuss vessel’s emergency response procedures with supplier

42 Discuss supplier’s own emergency response procedures

43 Establish and check the communication link between vessel and supplier
Primary
Back-up
Emergency stop

44 Agree signaling system with supplier

Commence Pumping
Reduce Pumping Rate
Cease Pumping
Emergency Stop
 Loss Prevention Bulletin

No. Checkpoint Vessel Supplier

45 Request from the supplier to provide your vessel with a remote

emergency stop for the bunker transfer pumps on board the barge

46 Conduct compatibility test, if necessary. Carry out quality analysis

with vessel’s fuel test kit (if carried)

47 Sight, agree and record shore/barge meter readings or tank figures.

Record corresponding temperatures. Inspect the flowmeter if fitted

48 Appoint crewmember to tend mooring lines during bunkering

49 Prepare filling line and open all relevant valves,

ensuing all valves not in use are closed

During Bunkering

50 Ensure a crewmember is stationed at the bunker manifold

throughout the bunkering operation

51 Commence bunkering at minimum pumping rate

52 Start taking sample, adjust sampling device in order to ensure

that the sample runs throughout the entire bunkering operation

53 Monitor supply line pressure

54 Carry out spot analysis with vessel’s fuel test kit (if carried)

55 Examine hose and connections for leakage upon commencing

receiving fuel, and immediately after each increase in delivery rate

56 Ensure soundings/ullages of tanks being filled are closely monitored.

Take soundings to make sure that the correct tanks are being filled.

57 Periodically check the quantity of fuel in bunker tanks that are not
being loaded, or have completed loading

58 Reduce pumping rate and/or open next tank before topping off

59 Close valves as each tank is completed, ensuring that the loading hose
is not subjected to excessive back pressure. Prior to closing valves
request to reduce pumping rate / pressure if necessary

60 Ensure sufficient ullage in the final tank for hose draining/line blowing

61 Notify supplier on reaching final tank

62 Give supplier timely warning to reduce pumping rate

63 Give supplier timely warning to stop pumping

Loss Prevention Bulletin

No. Checkpoint Vessel Supplier

On Completion of Bunkering

64 Drain hoses on completion of bunkering, blow with air only

once at the end of the bunkering and close all filling valves

65 Ensure all hoses are fully drained

66 Close manifold valve and blank off manifold connection

using all securing bolts, properly tightened, with a gasket in place

67 Blank off disconnected hose couplings using all securing bolts,

properly tightened, with a gasket in place

68 Reconfirm all bunker line and tank filling valves are closed

69 Reconfirm all bunker tank soundings. Confirm bunker temperature

70 Ensure all sounding pipe caps are securely fitted and all sounding pipe
automatic closure devices, where fitted, are not open

71 Sight, agree and record shore/barge meter readings or tank figures.

Take measurements twice if possible

72 Verify all bunker receipt details are correct and sign

73 Witness, date, jointly countersign and retain sealed bunker samples

in line with company and regulatory requirements

74 Complete entry in Oil Record Book, Engine Log book

and Deck Log Book

75 Preserve the fuel samples. Send the sample ashore

for the quality analysis

* In accordance with appendix V to MARPOL Annex VI the Bunker Delivery Note is to contain at least: name and IMO number of receiving ship, port, date
of commencement of delivery, name, address and telephone number of marine fuel oil supplier, product name(s), quantity (metric tons), density at 15°C
(kg/m3), sulphur content (%) and a declaration signed and certified by the fuel oil supplier’s representative that the fuel oil supplied is in conformity with
regulation 14.1 or 14.4 and regulation 18.3 of MARPOL Annex VI.

Signed for ship Signed for supplier

Rank: Designation:
LPB-BP-GBR-19-V1

The West of England Ship Owners Mutual Insurance Association (Luxembourg)

UK office One Creechurch Place, Creechurch Lane, London EC3A 5AF
Tel +44 20 7716 6000 Email mail@westpandi.com www.westpandi.com Follow us on
Loss Prevention Bulletin

Inaccuracies in Draught Surveys

The Club regularly receives claims arising from alleged shortages of
cargo as a result of discrepancies between draught survey results.

Draught surveys by their very nature As an example, an error of two Density

are not an exact science, and the
accuracy of the calculated cargo figure
may vary typically by between 0.5 and
1.0%. However, there are occasions
when considerable differences in the
cargo figures derived from the draught
surveys are obtained. The purpose
of this Loss Prevention Bulletin is to
remind deck officers of the principal
sources of errors which may affect the
survey results, such that they can be
taken into account when shortages in
the cargo are found.
Draughts
It is imperative that the draught
marks are read as accurately as
possible. Ideally this should be done
from a boat so that the marks can
be approached closely and read.
However, poorly painted, rusty, or
draught marks covered with marine
growth make reading the draught
accurately problematic, therefore it
must be ensured, so far as possible,
that the draught marks are kept in
a readable condition. The presence
of wind waves on the water surface
will necessitate an estimation of the
average draught by observation of
the peaks and troughs of the waves
against the hull. Darkness and
shadows also make accurate reading
difficult; therefore good lighting will be
required at night. The turn of the hull
around the stern leading to elongation
of draught marks being viewed from
an oblique angle, especially when this
has to be done from an adjacent wharf
at a higher level, can lead to difficulty
in accurately determining the draught.
centimetres in the mean draught would
lead to an error in the displacement of
approximately:
68t – Handysize Bulk Carrier (10,000
– 35,000t deadweight)
90t – Handymax Bulk Carrier
(35,000 – 59,000t deadweight)
112t – Panamax Bulk Carrier (60,000
– 80,000t deadweight)
300t – Capesize Bulk Carrier (>
80,000t deadweight)
It is therefore advised to ensure that
the inspection and maintenance of the
draught marks be included in
the planned maintenance system
on a vessel.
Although there are numerous possible
causes of inaccurate dock water
density, it must first be confirmed that
the hydrometer being used is of the
correct type. There are two types of
hydrometer in use, the load line survey
hydrometer, and the draught survey
hydrometer, the latter being used in
this case.
A draught survey hydrometer,
calibrated in air, measures the
apparent density of the water and
is used for determining the weight
of the cargo on board. A load line
hydrometer, calibrated in a vacuum,
is used to determine the relative
density of the water and determine the
displacement of the vessel at a given
load line.
A dock water density reading taken
with a draught survey hydrometer
showing 1.015 t/m3, would show
1.017 t/m3 when taken with a load
line hydrometer, both are correct,
the difference between the two of
0.002 is known as the “air buoyancy
correction”, however as we want to
determine the weight of the cargo
on the vessel the density read from
the draught survey hydrometer
will be used. The draught survey
hydrometer is calibrated at a standard
temperature. Any deviation from
the standard temperature does not
require a temperature correction,
as the changes in the volume of
the vessel and the hydrometer will
generally cancel each other out.
It must also be ensured that the
hydrometer is calibrated regularly
Loss Prevention Bulletin
to ensure its accuracy, as they can
become chipped, damaged and /
or contaminated with a film on their
surface during use, altering their mass.
Hydrometer manufacturers generally
recommend they are calibrated after
one year, and then every two or three
years thereafter.
When determining the dock water
density a sample of the dock water
should be taken beneath the surface
of the water, clear of overboard
discharges and deck runoff. In order
to ensure an accurate reading the
receptacle used to sample the dock
water, and the hydrometer, must be
clean. When taking the reading the
hydrometer must not touch the side
of the receptacle and be gently spun
to break the surface meniscus of the
water. The density reading is then read
from the hydrometer stem at the bottom
of the remaining meniscus. A number
of readings should be taken from each
sample, with the average of the readings
determined. A number of separate dock
water samples should be taken from
around the vessel and measured, with
the mean of all the average densities
used for the draught survey.
If an error is made when determining
the dock water density, using a density
lower than the actual density will lead
to an apparent cargo shortage, with an
apparent cargo surplus when a density
higher than the actual density is used.
Ballast
A number of errors can occur when
determining the ballast on board.
The tank soundings themselves may
be incorrect due to difficulties in
obtaining accurate soundings when
using a sounding rod and rope, with
the inherent possibility of reading
incorrect depths from the rope due to
a lack of markings and the wetness of
the rope. When using a metal sounding
tape it may be difficult to determine
the actual water level from the metal
tape. Further, inaccurate soundings
may be obtained when the doubler
plate at the bottom of the sounding
pipe is corroded and worn, increasing
the sounding and hence the apparent
weight of water in the tank.
Often, particularly on older vessels,
sounding rods and brass bobs may
remain in the sounding pipe, giving
readings less than true, as will be
the case if the sounding pipe has
become blocked with rust scale or
other debris, such as rags left in the
tank during maintenance or dry-
docking. The presence of sediment
in the tank covering sounding rods
and tapes can also lead to erroneous
readings. The figures for the ballast
extracted from the sounding book
may be in error due to inaccuracies in
interpolation or not allowing for the
trim or list of the vessel, further, the
figures may be calculated assuming
an incorrect ballast water density, and
it is recommended that ballast tanks
are overflowed for a length of time
such that a truly representative ballast
water sample can be obtained
for density determination.
As an example:
If we assume a single ballast
tank with a 500m3 capacity.
On arrival prior to loading the
tank is overflowed and full
of seawater.
Therefore the assumed weight
of water =
500m3 x 1.025 t/m3 = 512.5t.
However, there is 40m3 of mud
in the tank.
Therefore the true picture of the
tank’s contents is as follows:
Water: 460m3 x 1.025 t/m3 =
471.5t
Mud: 40m3 x 1.9 t/m3 = 76t
Total weight of tank contents =
471.5t + 76t = 547.5t
Unfactored Weights
Often weights are not deducted
or allowed for when determining
the cargo quantity, the commonly
forgotten weights are:
Bilge water present in the cargo
holds, machinery spaces, duct keel,
void spaces and the chain lockers.
Swimming pool water.
Anchor and anchor cable on the
seabed, either when at anchor or
alongside and an anchor has been
deployed as part of the mooring
arrangement.
Silt and mud can accumulate in the
double bottom tanks of vessels
regularly ballasting in rivers or
estuaries. The extra weight can
give rise to an apparent increase
in the cargo loaded.
 Loss Prevention Bulletin

As 512.5t is assumed to be the weight

of ballast in the tank, the remaining
35t will appear in the constant.

On completion of loading it is assumed

the tank is empty. However, 76t
of mud remains, only 35t of which
is in the constant, the remaining 41t
will appear to be cargo loaded.

Squat
As most mariners know, squat is
the bodily sinkage and trimming of
a vessel making way with limited
underkeel clearance. However, a
vessel alongside a river berth may also
be susceptible to squat, leading to
inaccurate draught readings.

Squat will occur when there is limited

space for the water to flow between
the vessel and the river bed. In order
for the river water to pass between
the flat bottom and the river bed
there will be an increase in velocity of
the water flowing past the hull, and
consequently a decrease in the water
pressure. The decrease in pressure
leads to the ship bodily sinking and
also a change of trim. The magnitude
of the bodily sinkage and change of
trim is difficult to quantify, however,
it will be a function of the underkeel
clearance, speed of the water, the
cross section of the hull in relation to
the cross section of the river (blockage
factor) and the shape of the hull (full
form vessels are affected more).
Generally full form vessels will trim
by the head, and fine line vessels will
trim by the stern. If a vessel is passing
at the time that the draughts are being
read, this may exacerbate the error
due to the increased blockage of the
river and consequently the vessel
may trim and sink more than normal.
Further Factors
Other areas that can lead to errors in
the draught survey calculation include
the following:
The hydrostatic data and tank
sounding tables may not be accurate
due to changes to the ship’s structure.
On most vessels the ballast tanks
suctions are located at the aft end of
the tanks, as the normal convention
is for a vessel to be trimmed by the
stern. However, when trimmed by
the head, although a ballast pump
may have lost suction indicating
that the tank is empty, there may be
un-pumpable ballast pooled in the
forward part of the tank. In addition,
if the sounding pipe is towards the
aft end of the tank and the vessel
is trimmed by the head, then the
sounding may also show the tank
to be empty, when that is not the case.
Loss Prevention Bulletin
Leaking tank valves – when a tank has
been sounded and found to be empty,
subsequent ballasting / de-ballasting
operations could lead to water leaking
into the tank, similarly, when ballast
tanks are overflowed during discharge
operations to show that they are full,
water could leak out of the tank prior
to the draught survey taking place.
Whilst on passage, depending on
the nature of the cargo, water could
migrate from the cargo to the cargo
hold bilges and be subsequently
pumped overboard. If water is found
to be accumulating in the bilges
while at sea, accurate records of
the quantity of bilge water pumped
overboard should be kept to help
counter any subsequent cargo
shortage claim.
Some vessels are susceptible to
unsymmetrical hull deflection, this
particularly affects smaller vessels
due to their larger engine room in
relation to their size which pushes
the location of maximum sag forward
of amidships, leading to inaccurate
draught readings.
On older vessels in particular,
problems can be encountered
due to set in shell plating between
the upper wing and double bottom
ballast tanks.
The West of England Ship Owners Mutual Insurance Association (Luxembourg)
UK office One Creechurch Place, Creechurch Lane, London EC3A 5AF
Tel +44 20 7716 6000 Email mail@westpandi.com www.westpandi.com
This can lead to actual displacements In the event of a cargo discrepancy
less than shown in the hydrostatic arising as a result of a draught survey,
data for a given load draught, deck officers are advised to consider
therefore there can be less cargo the possibility that one or more
on board than expected. of the foregoing factors may have
contributed to the difference.
The position of the hatchcovers can
In particular any substantial change
affect the deflection of the hull,
in the constant should be viewed
particularly on smaller vessels when
with suspicion and investigated.
the open hatch covers may be stowed
at one or both ends of a single hold. Members requiring further
For draught surveys on all vessels information should contact
it is recommended that the hatches the Loss Prevention department.
remain closed to ensure consistency.
Whilst alongside any bunkering,
taking of potable water, and discharge
of sludge or oily water should be
considered when completing
the final draught survey.
Where there is any notable difference
in the constant between loading and
discharge, then this is an indicator that
there is an error somewhere in the
draught survey, and this should
be thoroughly investigated.
Throughout a cargo voyage, the
constant should be, as the name
suggests, fairly constant.
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Loss Prevention Bulletin

Loading of Coal that has

Exhibited Signs of Self-Heating
Members are reminded that self-heating of coal is more likely when
the coal is low rank, geologically immature material sourced from
open cast mines such as that commonly shipped from Kalimantan in
Indonesia. The IMSBC Code sets out that, for self-heating coals, the
temperature of the cargo shall be monitored prior to loading and cargo
shall only be accepted for loading when the temperature of the cargo is
not higher than 55°C.

The Club has previously published
advice on this issue in our Loss
Prevention Bulletin Monitoring of
Self-Heating Coal Cargoes Prior
to Loading.
Methods used in an attempt to cool
cargo are varied but include:
Turning the cargo over with a
payloader or using grabs
Spraying with fresh or, more
frequently, salt water
Spraying with chemicals which
are designed to inhibit the
oxidation reaction.
In the Club’s experience none of these
remedial actions are very effective.
Although some localised cooling
may be measured, coal is thermally
insulating and any action that can be
taken on a barge will not deal with
the fundamental problem of the bulk
of the coal being too hot.
The only reliable method to cool
coal that has started to self-heat is
to unload it ashore onto a wharf or
similar, and then spread it out in a
relatively thin layer which will allow
it to cool and stabilise.
Crushing of the coal with a roller
and dousing with fresh water can
accelerate this cooling process,
although clearly none of these
methods are practicable or
achievable on a barge.

In most cases, coal loaded in

Kalimantan is from barges and the
Club has noticed a growing trend of
increased pressure from shippers
to load cargo from barges where
temperatures in excess of 55°C
have been recorded.

Shippers are either pressing for cargo

to be loaded from areas on the barge
where no excessive temperatures have
been recorded, or after “cooling“ of
the cargo on the barge.

Turning hot coal over on a barge to try and cool it.

Loss Prevention Bulletin
Spraying coal with oxidation inhibiting chemical solution – note this does not penetrate into
the bulk of the cargo and will treat the surface layer only.
In two recent cases we have seen
cooler cargo (taken from an area of the
barge where no temperatures in excess
of 55°C were recorded, although
temperatures above 55°C were found
in other areas on the same barge), or
cooled cargo (initially found to have
a temperature in excess of 55°C, but
after treatment on the barge was then
found to be below 55°C) loaded into
cargo holds. Within the cargo holds
this cargo then continued to self-heat
to temperatures in excess of 55°C,
as well as giving off smoke/steam.
If cargo already loaded is seen to be
smoking/steaming or the temperature
is found to be greater than 55°C, then
no further cargo should be loaded
in these hold(s). The affected cargo
hold(s) should be closed without
delay with no ventilation, and gas
monitoring as per the IMSBC Code
instigated. Expert advice should then
be obtained.
The West of England Ship Owners Mutual Insurance Association (Luxembourg)
UK office One Creechurch Place, Creechurch Lane, London EC3A 5AF
Tel +44 20 7716 6000 Email mail@westpandi.com www.westpandi.com
Coal on a barge measured to be below 55°C
but clearly self-heating as evidenced by the
smoke/steam.
Although there is nothing in the
IMSBC Code to prevent loading of
cooler or cooled coal, the Club’s
recommendation remains that if just
one of the temperature readings is
found to exceed 55˚C, the entire barge
should be rejected even if all other
readings are satisfactory. Similarly,
even if all readings are satisfactory
coal should not be loaded if seen to be
smoking or steaming, or exhibiting any
other signs of self-heating.
Given the pressure being applied by
shippers we would recommend that
when fixing, the charter party includes
a provision that acceptance of cargo
for loading is always to be at the
absolute discretion and final control
of the Master.
With regard to fixing vessel for coal
cargoes, the Club often sees allowable
cargo described within the charter
party as “harmless lawful coal in bulk
only” or similar.
Given that the IMSBC Code
categorises coal as Group B (“cargoes
which possess a chemical hazard
which could give rise to a dangerous
situation on a ship”), and possibly
Group A (“cargoes which may liquefy
if shipped at a moisture content in
excess of their transportable moisture
limit”), and also considering the
guidance in the Club’s Loss Prevention
Safety Alert Coal Cargoes – Know the
Dangers, coal can never be harmless
and a better description that could be
considered would be “coal that is not
liable to emit methane or self-heat”.
Coal self-heating in the cargo hold despite
being cooled below 55°C on the barge prior
to loading.
Members requiring further guidance
should contact the Loss Prevention
department.
LPB-LCESSH-GBR-20-V1
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