GROWTH IN CHEAP TOWAGE APPROVAL ALIGNED WITH AN INCREASE IN SERIOUS INCIDENTS

Times Marine Survey staff have issued a warning following a surge in requests for ‘on the cheap’ desktop towage approvals, which they say are a false economy and fraught with potential problems.

“We believe there is a correlation between this trend and the increase in the number of incidents involving tug/barge tows and subsequent heavy financial losses and painful time-consuming claims,” says Michelle Megson, TMS general manager.

“Although we are not unsympathetic to the commercial pressures faced by owners and operators, we will not cut corners by agreeing to do this. In fact many P&I Clubs ask us to conduct damage surveys and investigations relating to tows gone wrong, largely as a result of ‘on the cheap’ approvals made elsewhere.”

In one such case, towage approval was issued by an inexperienced surveyor, chosen on a low fee basis, who did not realize that the tug was not fit for the job. Not long after departure, due to the short tow line and brake failure, the line became disconnected from the drum and the barge went adrift, later to run aground on the rocks of a nearby shore.

On another occasion, a desktop towage approval certificate was issued by an experienced and qualified surveyor for a barge, the hull and deck of which were in poor condition The towing equipment was in apparent good condition with in-date certification and the tug suitable for the tow. However, the barge’s deck and man hole covers, between the side shell and cargo wall, were heavily corroded and partly wasted/holed. As a result, in inclement weather sea water infiltrated the STBD void spaces, the barge listed, the starboard side cargo wall collapsed and the cargo being carried was lost overboard.

Both these incidents may have been prevented if proper towage approval surveys had been carried out physically and by a qualified and experienced surveyor following the guidelines of national and international recognised authorities.

In 2017, the Federal Transport Authority 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. Times Marine Survey LLC is one of only eight companies on that panel, which is a testament to its good standing and the quality services provided.

E-CERTIFICATES FOR THE DIGITAL AGE

In the old days of ship surveying, the only way to see all original certificates that a ship is required to have onboard – allowing her to trade worldwide – was to be onboard yourself.

In the early days it went something like this: "Fetch the big black binder marker SHIP CERTIFICATES for this gentleman and you must stand with him while he reviews these papers. They must not leave the ship as without them we cannot do business. These are the original certificates and cannot be easily replaced", Captain Smith says to Pocahontas.

Until very recently it went something like this: "Captain Smith, please let me see your Ship Certificates File. I will be able to see all valid class and trading certificates and verify to the buyer that everything is up to date onboard," says the Aalmar Surveyor.

How times are changing! Original Class and Trading Certificates no longer need be sent to the ship and updated by resending the revised certificates to the ship. Certificates can now be an electronic version with copies printed out onboard and put in the SHIP CERTIFICATES binder. Classification Societies and Flag States are allowing the use of E-Certificates as permitted by the IMO.

DNV GL says shipping can make significant efficiency gains by the introduction of electronic class and statutory certificates, reducing administrative burdens, processing time and document handling costs. It is introducing IMO-compliant electronic class and statutory certificates to vessels following tests and pilot projects with several owners and flag administrations.

Almost 50 flag state administrations have granted DNV GL the authority to issue electronic statutory certificates on their behalf. DNV GL expects more acceptances in the near future.

The electronic certificates are secured with a digital signature and a unique tracking number, which can be checked online, assuring their validity and authenticity. DNV GL’s clients can share access to these certificates with stakeholders such as charterers, ports, flag administrations and insurers, by using temporary access codes.

ABS offers certificate automation, or electronic certificate compliance (ECC), speeding up digital certificate delivery, improving accuracy and ensuring users have all needed documentation on demand. ABS electronic certificates are always available, verifiable digital equivalents of traditional ABS paper certificates.

Fully compliant with IMO Guidelines, ABS E-Certificates will reduce administrative burdens, lessen onboard clutter and simplify flag state validation.

Henceforth, a ship survey begins at the laptop and continues as the Aalmar Surveyor walks up the gangway.

BWTP AMENDMENTS IMPROVE FITMENT CLARITY

Confusion over the timings for fitting ballast water treatment plants (BWTP) may finally be over.

In April this year, the IMO adopted amendments to the BWM Convention for the fitting of a BWTP to comply with D-2 of the convention. The amendments will enter into force on 13 October 2019.

To summarise: For all new ships, built after 8 September 2017, a BWTP will need to be fitted by the time the ship is in service. For all ships built before 8 September 2017, the new compliance date is the vessel’s IOPP renewal in the five year period between 8 September 2019 and 8 September 2024.

It also appears that the USCG is issuing extensions that almost comply with these new IMO compliance dates, even though they refer to it as “the next scheduled drydocking …”

The only varying factor is when the vessel goes into dry dock for the Intermediate Survey, whereby the treatment plant may have to be fitted two to three years earlier than the IOPP renewal date.

Either way you look at it, the industry now has the fixed deadline where all ships should have a ballast water treatment plant fitted by 8 September 2024.

In February this year, US Coast Guard issued a letter outlining Guidelines for evaluating Potential Courses of Action When a Vessel Bound for Port in the United States has an Inoperable BWM System. See this link for a copy:https://www.ballast-water-treatment.com/sites/ default/files/ressources/uscg-guidelines.pdf

USCG still only have six approved ballast water treatment systems. Further manufacturers have applied for approval but their applications are pending due to testing by US Authorities.

“The IMO basic approval list is a little more extensive with 42 systems making use of active substances which received final approval from IMO in August 2017,” says Carole Bryer, Aalmar Surveys managing director. “There are more with ‘basic approval’ but this list is also evolving.

“What we as surveyors can hope for is that this means less mud in the ballast tanks and therefore better pictures of the bottom plating and turn of the bilges for you, our clients!”

For the last few years, the talk has been about the cost of installing BWTP – and since the first systems have been installed and more type approval systems are on the market, there has been a reduction in costs.

“We are starting to see BWTP fitted on board and this now poses the question, are the crew trained in operating the new machinery to comply with the maximum number of organisms?” says Carole. “The current IMO regulations to comply with D-2 has a fixed number of organisms per 100 millilitres.”

Now that D-2 of the convention is being implemented, Port State Control (PSC) inspectors will now be taking samples of ballast water as a part of their inspections. The severity of deficiencies and the length of any grace periods will soon become clear, but they represent another thing to look for and learn about.