THE TRUTH ABOUT EXHAUST GAS SCRUBBERS
Does the shipping industry need exhaust gas scrubbers to comply with the 1st January 2020 sulphur limit of 0.50%?
The simple answer is no… but could this cost you either way?
There is no clear winner at this stage between fitting an exhaust gas scrubber and paying the higher fuel costs of purchasing low sulphur compliant fuel oils. Yet both have some hidden potential further issues.
Choosing an exhaust gas scrubber
After your enormous financial input to purchase and fit an exhaust gas scrubber, you may believe you are covered. However, this may not be the case.
Apart from reports of some components corroding quickly, some environmental groups and some ports are concerned with the sulphur being taken out of the air pollution only to be pumped into the water, causing harmful pollution to the local marine environment. If investigations find that the effect of sulphur in the water is also harmful to the environment, you might find that your ship will not actually be allowed to enter the port running your exhaust gas scrubber, especially the open loop type.
No irrefutable conclusions have been made on this topic as investigations are on-going but this is a potential issue if findings are made to argue the point. IMO has encouraged further studies of the impact of exhaust gas scrubbers on the environment.
Continuing to purchase low sulphur compliant fuels
First off, your Port State and Flag State inspections are going to be more involved. IMO are not enforcing the compliance of 0.50% sulphur limit fuels, they are leaving this to Port and Flag States to enforce. This means that when your vessel is boarded for their regular inspection, it will now include them taking samples from every tank on board.
Any tank that is found with a sample over 0.50% sulphur will result in the ship being detained. This will have a knock-on effect with fines, reputations and the possibly ability to insure the vessel. To protect against this, your ship may have to start testing bunker barges before bunker operations begin. More expense, more delays and more paperwork.
Not only are low sulphur emission fuels more cistly than other fuels, the availability of low sulphur compliant fuels around the world is questionable.
What is FONAR?
Fuel Oil Non-Availability Report (FONAR) is the fun new report to complete in the event of low sulphur compliant fuels not being available. This is where you provide evidence of all the attempts you have made to obtain the compliant fuel oil, including attempts made to local alternative sources. After which you notify the administration of the ship, the port of your next destination and ultimately the IMO of the compliant fuel not being available.
So what is the correct decision between installing an exhaust gas scrubber or paying the higher low sulphur compliant fuel oil costs? The answer will probably be more clear in a few years’ time but unfortunately, not very clear now. Short term, there will be less headaches with exhaust gas scrubbers. But there are potentially more headaches to come if they are found to be potentially harmful to the marine environment.
THE SAFE WAY TO BOARD A VESSEL
Boarding a vessel at sea is part of the job for a ship’s crew and any other third party attending the vessel, i.e. authority representatives, contractors, repair teams, surveyors, etc. It can be demanding depending on a series of factors such as the vessel’s location, boarding arrangements and weather conditions.
PPE – every person intending to
board the vessel must wear the
proper safety gear in that respect.
That will include as minimum
helmet, safety clothes, safety boots, gloves and a lifejacket. Safety harnesses have to be at hand if the transfer is done via a personnel transfer basket.
Vessel’s boarding arrangements usually consist of accommodation ladder, pilot ladder or transfer basket. A combination of first two items can be used when the freeboard is higher than 9 m.
It is very important that a visual assessment is to be done for the all boarding means prior to proceeding. If anything doesn’t look in order, the person should not proceed boarding.
Pilot ladders should have the steps intact, they need to be horizontal, the rope needs to be in good condition, spreaders need to have a minimum of 180 cm in order to prevent the ladder from twisting and the pilot ladder has to be in contact with the hull over its entire length.
Unfortunately, surveyors can’t see the main deck securing arrangement from the launch but can ask the crew to ensure that it is properly done. A transfer basket is higher risk solution and that is why extra safety precautions must be taken.
Visual assessment of the main link and the safety (failsafe) loop must be done carefully. If something doesn’t look correct, the boarding must be refused without doubt. A supplementary body harness must be worn so that it can be secured with the basket ropes.
Accommodation ladder must be in good visual condition, provided with a safety net and the first step needs to be horizontal with the sea level.
A launch is generally used to go to the vessel while at sea. The launch should have at least two crew, one master and one crew to be able to assist the boarding personnel. It is highly advisable that the launch moves away from the base of the pilot ladder as soon as the person is securely on the ladder so that if they lose grip and fall, it is into the water and not onto the deck of the launch.
The other important safety factor is timing. The ship and the launch move independently and on different wave oscillations. This means the time to step from the launch’s deck to the pilot ladder must be at the top of the launch’s wave oscillation and at the bottom of the ship’s oscillation. This is to prevent being squashed between both vessels.
Any person boarding the vessel must have the physical fitness level to successfully transfer and climb the vertical ladder in the prevailing conditions.
Boarding the vessel at sea can be very difficult, which is why prior to proceeding, the situation needs to be assessed correctly including the weather and boarding arrangements and go ahead only if you feel safe and entirely confident.
TOWAGE APPROVAL ACTIVITY ON THE RISE IN UAE
Aalmar Group company, Times Marine Survey (TMS) issued a warning last year following a surge in requests for ‘on the cheap’ desktop towage approvals, which are a false economy and fraught with potential problems.
Although this negative trend still persists, its occurrence has diminished as numerous owners, insurance companies and P&I Clubs are aware of the latest UAE / FTA requirements and are seeking to see them imposed on every towage.
Today, the need for Towing Certificate for towage approvals from a select list of surveyors is not only required in UAE but also in KSA, Kuwait & Qatar.
TMS is not aware of any upcoming amendment to the legislation although it is expected that, in time, it will extend to all GCC.
The UAE Federal Transport Authority (FTA) issued a circular in 2017 through which the towing activity in UAE is placed under the guidelines of the MSC Circular no. 884 (dated 21st December 1998) and IMO Guidelines for Safe Ocean Towing.
The FTA introduced a panel of third-party survey companies authorized in UAE to carry out towage approval surveys in the line with the IMO, major class societies and the guidelines of P&I Clubs.
TMS is one of only a handful on that panel and has been there from the outset, while other marine survey companies have disappeared from the panel over time.
“This is a testament to our good standing and the quality services provided,” says Marian Dedu, general manager. “Our surveyors are carrying out towage approval surveys regularly and improvements are clearly being made, although it has recently become apparent that some tug masters are lacking stress and stability as well as ISM knowledge.”
In one case, the main towing line – which appeared almost new – was visibly spooled on its drum, but when checked by unspooling, it was found parted. Even though proper procedures were in place, the master had not checked the condition of the tow line since he relieved the previous master.
In another case, lack of proper adjustment of a main tow line length according to weather conditions had resulted in damage to, and parting of, the line in bad weather. The emergency towing line was also broken. Luckily a second emergency towing arrangement was available (as agreed between managers and surveyor) and the tug master succeeded to carry on with the towage to the closest sheltered port.
Sometimes, towing arrangement component certificates have expired, and TMS has to press for new certificates, which usually is a source of delays and extra expenses.
“Given ongoing projects, the number of towage approvals in UAE waters is going to increase and with it, the risks involved are increasing,” adds Marian. “Although TMS is sympathetic to the commercial pressures faced by owners and operators, the company is focused on procedures and equipment condition and will not cut corners.”