A huge crude oil slick washing up on the beaches of Brazil has been blamed on secretive STS operations off the coast of Venezuela, begging the question, is enough being done to monitor such actions?
The slick of crude oil that washed up on hundreds of Brazilian beaches earlier this year was first spotted by satellite in July 2019. It is one of the largest of a series of oil slicks that have arrived on Brazilian beaches since August 2019. The tides currents suggest the source is from Venezuelan waters.
Indeed, Brazilian state-owned oil company Petrobras has now identified the crude oil as from one of three Venezuelan oil fields. It is unlikely that a crude oil tanker would deliberately dump valuable cargo, so from where do it originate? Fingers are now being pointed at the increase in ship-to-ship (STS) operations off the coast of Venezuela, and the possibility that one or more STS operations have gone wrong, resulting in the accidental spillage. The increase in STS operations is believed to be due to tanker owners and operators who do not wish to be identified loading Venezuelan crude oil in defiance of current US sanctions (or ahead of further sanctions the US may impose on Venezuela). Those taking part in these operations are operating on the margins of legality and are unlikely to be working in line with STS rules and regulations, which are fairly clear.
Marpol mandates and regulates the existing guidance for essential STS equipment, the qualification of personnel and the definition of procedures. The requirements of STS under the ISM include, among other things, the assessment of objective evidence towards ensuring that all identified hazards in STS are met, in line with risk-based analysis. The collection, assessment, expertise and resources needed for prudent exercise of due diligence create a burden on the tanker operator which requires substantial financial support in order to remain compliant, according to DYNAMARINe’s chief executive Dr Alexandros Glykas.
If the master rejects any aspect of an STS provider or operation that causes a delay, he or she needs to have reasonable grounds to do so. The financial consequences fall on the vessel’s technical operator, commercial operator, owner and/or charterer.
This leads to considerable commercial pressure being applied to the master and the management company of the tanker.
In the case study below, there was no over-riding regulation requiring the port authority or the charterer to provide a specific set of equipment. A significant part of the responsibility for ensuring the STS operation could take place at all fell to the third-party provider for the provision of experience from similar cases.
DYNAMARINe played an important role in providing advice to enable the Chittagong STS to take place, but Dr Glykas is quick to point out that the company is not an STS provider. It does not own STS hoses and fenders and provided an advisory role to BSM. DYNAMARINe does provide an auditing service of STS providers for a number of clients and has established www.onlinests.net as a way of providing a one-stop shop of STS information, with transparency and consistent procedures, including a useful FAQ on STS with Clyde & Co. DYNAMARINe also has tools for assessing weather for STS operations and a database with assessments of STS elements.
The Chittagong STS case study also highlights the requirement that training needs to include the specific conditions in the area that the STS is to take place. The increase in shuttle tanker STS operations off Brazil and the need to train and assess the suitability of candidates for the positions of captain and chief mate was the driving force behind the tanker company Knutsen and oil company Equinor approaching Simsea Real Operations of Norway to develop a specific shuttle tanker STS simulation course. The course includes how the master and senior bridge officers communicate with the mooring master, the bridge team and the advice being given from the mooring master, who may be from a third-party provider. The sea-state off the coast of Brazil is often calm-looking and the height of the swell well within the 3 m limit for STS, but shuttle tankers undertaking STS in the region have had contact and near misses.
The culprit is a powerfully deceptive swell. With everything else that is taking place on the bridge during STS operations, this factor can be overlooked. According to Simsea’s chief executive officer A Rune Johansen, the assessment of the human factor is important in STS when there are so many inputs on the master. A Simsea human factors specialist and professor in psychology at University of Bergen, Sturle Danielsen Tvedt, notes that senior shuttle tanker officers need to develop their non-technical skills, such as situation awareness of loading conditions, and an awareness of local conditions and complex weather.
STS transfer is regulated by IMO under Marpol and the ongoing development of safety rules within STS is driven by OCIMF, supported by stakeholders. SafeSTS’ chief executive Capt. Bob Gilchrist, who is co-chair representing the STS providers on the STS Regional Forum (Europe, Middle East, Africa), says it is important to note that the forums that support OCIMF are designed around the requirement for confidential communication, where possible conflicting commercial interests are excluded. Trends in incidents are shared and common threads of concern are thoroughly investigated and, as appropriate, passed up the chain to OCIMF and on to IMO. Shipowners, insurers, industry bodies, regulatory manufacturers and government officials are often invited and/or requested to attend the meetings, increasing transparency.
An STS case study in risk awareness
The following case study highlights the risks that can arise when charterers expect ad hoc STS operations in a new environment. The case study was presented at the IFSTS 2019, organised by DYNAMARINe in Athens Greece.
The tanker had been fixed to discharge 15,000 tonnes of palm oil in Chittagong, Bangladesh, but no method of discharge was listed. This was later changed to lightering via barges. Bernhard Schulte Shipmanagement (BSM) was the shipmanager of the vessel and immediately commenced a screening process as per its company policy. This revealed that:
There followed a series of discussions between the time charterers and the cargo receivers to provide the necessary documentation. This included the alternative of the finding of a suitable jetty for the discharge of the palm oil. The situation was not resolved and BSM engaged the STS assurance organisation DYNAMARINe to assess the STS location, the available equipment, and to highlight areas of concern and advise the master on possible risk mitigation.
The DYNAMARINe representative found the local fenders were not ISO 17357 compliant, as mentioned in the documentation and were in poor condition, not safely stored and there was evidence of lack of maintenance. The representative also found the inspection date did not tally with the physical condition of the fenders. The proposed fenders did not comply and did not satisfy the requirements of Marpol and (ICS/SIGTTO/OCIMF/CDI, 2013) section 9.
Eventually, sufficient arrangements were made for the STS operation to commence. During the actual STS operation, alternative pneumatic fenders were used on the tanker. The receiving vessels were using truck tyres as fenders. It was also found that the fairleads of the receiving vessels were in poor condition and the mooring pattern used conformed to OCIMF and MEG4 guidelines, subject to assessment that the weather conditions would allow the STS operation to proceed.
The STS area had not been assessed in the past (as there was no area in the port of Chittagong assigned for STS). The strong current and commercial traffic in the area made an emergency casting off a causal factor for increased risk. These and other issues, such as crew experience, were the subject of several meetings between the master, DYNAMARINe and the charterers’ representative who both provided their support.
Considerable commercial pressure was brought to bear to complete the STS operation “as is”. This required strong pushback with those concerned reminded of:
The STS operation proceeded with delays but without incident. The lessons learnt from this STS operation are to be aware if:
If any or all of these flags are raised, the managers should undertake STS assessment in-line with existing industry tools and practices available within (ICS/SIGTTO/OCIMF/CDI, 2013). They should always have total control (100%) over safety aspects and should not delegate their responsibility to third parties.
The importance of a POAC
One element of STS that outsiders often find confusing is the role of the Person in Overall Advisory Control (POAC). However, the qualification requirements and required operational inputs are very clearly defined within Marpol.
The appointed PAOC is often from the STS provider, which is the company providing the hoses, fenders and expertise, it may also be the Master of one of the two vessels. As Capt Gilchrist explains: “The vast majority of vessel masters do not have, nor do they pretend to have, the skills to undertake the necessary manoeuvres to berth two vessels in the open ocean, keep the vessels safely moored throughout the cargo transfer and then unmoor without incident. Although the attendance of a POAC does not in any way relieve the masters of their statutory obligations for the safety of their vessels, the effective integration of the POAC into the bridge team is absolutely key to the success of the operation.”