TANKER DAMAGE STABILITY

Paul Coley & Nick Quarmby Maritime & Coastguard Agency

Background
The UK first became concerned over the issue of damage stability verification on tank vessels in 2005 as a result of problems highlighted during flag in of tank vessels, port state control inspection and a survey of UK tank ship operators

Issues identified at Flag in

Low or zero margins on stability in worst case of

damage Damage cases missing from the damage stability evaluation, particularly lesser cases Insufficient consideration given to slack or partially filled tanks Insufficient consideration given to use of deck tanks Approvals based upon unrealistic conditions of loading

Of eleven LPG and chemical tanker stability approvals considered for endorsement by the UK at this time, seven were found to be incorrectly based and to omit critical elements to the verification.
This is a rejection rate of 63%.

Port State Control Observations

Vessels loading alternate conditions from
those in the approved stability book Vessels appraising loading conditions using longitudinal strength computer with additional intact stability assessment Masters endorsing loading conditions clearly marked not valid for damage

Survey of UK tanker operators

How many vessels operated including
foreign flag vessels in their fleets Do they load alternate conditions from the SIB Do they operate with empty or slack tanks Do they verify stability prior to departure Do they verify using intact or damage stability assessment

Survey Results
Total of 76 ships operated 59 vessels (77%) load alternate conditions 43 vessels (56%) regularly operate with slack
or empty tanks 69 vessels (90%) are fitted with stability assessment programs 30 vessels (39%) only assess intact stability

Conclusions
Insufficient pre-departure checks are being made
on tank vessels to ensure compliance with statutory damage stability requirements.

Existing stability approvals for these vessels may

not always ensure that these requirements are met

There is a compelling need for enforcement action

to be undertaken to ensure that existing international instruments are being complied with

UK Response
To publicise the issue amongst UK operators, IACS and

international tanker operators associations To consult other flag states on the issue and to consider proposals for co-ordinated enforcement of existing international instruments With others, to draw attention of this issue to IMO through MSC 83/25/14, proposing development of a common interpretation for these instruments to enable consistent enforcement action to be taken To propose that guidelines be developed for tank ship stability approval in the expectation these will be taken up by IACS under the umbrella of URL5.

IACS Unified Requirement URL5

IACS has introduced a new requirement relating to stability computation under URL5 This makes it mandatory for loading computers fitted to any IACS class vessel contracted after 1 July 2005, which incorporate a stability element, to be approved to verify all aspects of stability which apply to that vessel, including damage requirements.

Enforcement
Guidelines for a common interpretation of the

international instruments are necessary to ensure consistent enforcement action However, the need for enforcement action is clear and is not dependent upon such guidelines being developed As a flag and port state administration the UK will seek to pursue co-ordinated enforcement action if guidelines cannot be agreed within an acceptable timescale

Enforcement
Enforcement action shall apply only to those
vessels which do not operate according to their existing stability approval Vessels which adhere closely to their approved loading conditions will not be required to provide direct means of verification A definition of what constitutes closely loaded is required to verify loading is in accordance with the approved conditions

Enforcement
Where alternate conditions of loading are
employed, verification by means of critical KG or GM data is acceptable subject to any parameters fixed to determine the critical data being verified as met It is the opinion of the UK that such verifications should be made using a URL5 type 2 stability program to provide an auditable record for PSC inspection

Enforcement
It is the opinion of the UK and its cosponsors that where vessels load alternate conditions significantly different from those in the approved stability book, these should be verified on board using a URL5 type 3 stability program

Enforcement - Proposal
Inspection campaign to identify where vessels

are loading to alternate conditions without acceptable damage verification In such cases an operational (ISM) defect to be raised against the ship and letter of warning to be issued Should further cases of loading alternate conditions become apparent at subsequent inspections, detention or banning to be considered

Enforcement - Conclusion
During any forthcoming inspection and enforcement campaign, operators must ensure that crews can produce records on board to demonstrate that damage stability has been verified.

UK strongly recommends the provision of

damage stability programs for this purpose on any existing vessel where adherence to the approved conditions is not practicable.

Operational Considerations

Basic Pre-Departure Checks

Longitudinal Strength - Load Line Intact Stability - Load Line Damage Stability

Oil Tankers - Marpol Annex 1, reg 25 Gas Tankers - IGC Code, Chapter 2 Chemical Tankers - IBC Code, Chapter 2

Documentation on Board
Approved Stability Information
Intact loading Conditions Damage Calculations

Certification

Oil Tankers IOPP Certificate and Form B Gas Tankers Certificate of Fitness Chemical Tankers Certificate of Fitness

IOPP Form B
5.7 Subdivision and Stability (regulation 25)

5.7.1 The ship is required to be constructed according to, and complies with, the requirements of regulation 25
5.7.2 Information and data required under regulation 25(5) have been supplied to the ship in an approved form

IGC and IBC Certificates of Fitness

5 That the ship must be loaded:
.1 in accordance with the loading conditions provided in the approved loading manual, stamped and dated ............................................................. and signed by a responsible officer of the Administration, or of an organization recognized by the Administration; or .2 in accordance with the loading limitations appended to this Certificate. Where it is required to load the ship other than in accordance with the above instruction, then the necessary calculations to justify the proposed loading conditions should be communicated to the certifying Administration who may authorize in writing the adoption of the proposed loading condition.

Masters and Owners Responsibilities

International Safety Management (ISM)

Paragraph 1.2.3.1 The company should establish a

safety and environmental policy which ensures compliance with mandatory rules and regulations

Paragraph 7 - The Company should establish procedures

for the preparation of plans and instructions, including checklists as appropriate, for key shipboard operations concerning the safety of the ship and the prevention of pollution. The various tasks involved should be defined and assigned to qualified personnel.

Stability Considerations

Typical Stability Approval at Build

Intact stability information booklet
Contains sample intact loading conditions. On approval, these intact loading conditions are themselves deemed to be approved for use.

Damage stability appraisal

Usually a separate submission Demonstrates only that the approved intact loading conditions will survive the extent of damage required by the applicable Convention or Code, and achieve the minimum residual stability standard.

In this approach damage is applied directly to the approved loading conditions on a case by case basis. The results, and the approval, is therefore conditional upon the assumption that the following parameters remain unchanged in the loaded vessel, otherwise damage results may be adversely affected :

Cargo SG Draught and or Trim Empty/Part Filled Cargo Tanks Cargo or Ballast Distribution Use of Deck Tanks

Variation in Loading
The ability to load a vessel is restricted where approval is granted on the basis of damage appraisal of approved intact loading conditions. This may be of little consequence on a large deep sea vessel fulfilling a long term charter. But it is likely to prove problematic for a small coastal parcel tanker. It is often considered that alternate loading conditions are acceptable, particularly where these do not deviate significantly from the approved intact loading conditions, but there is no safe basis for this conclusion.

Significant Variation
It is the opinion of the UK and its co-sponsors that the concept of a significant deviation from an approved loading condition requires to be defined. We are presently proposing that a loading condition should be considered to deviate significantly from an approved condition if the following limits are exceeded

Content of cargo and ballast tanks : 1% by weight Overall condition KG or GM (corrected for FS) : 2cm

Critical KG data

Typical tanker cross section

Loaded with low SG cargo

Heels toward damage

Loaded with high SG cargo

Heels away from damage

Vessel at deep draught

Heels toward damage

Vessel at light draught

Heels away from damage

Full tanks

Heels away after damage

Slack tanks

Heels toward damage

Empty tanks

Severe heel toward damage

Typical tanker layout

Typical single SG loading pattern

Typical alternate SG loading pattern

Significant variation ?

Significant variation ?

Typical Condition ?

Consider variation in cargo SG

Cargo and condition KG both rise

Typical Cargo Distributions (Departure)

SG 0.630 0.740 0.835 0.850 1.180 1.400 1.530 1.830 1.830 1.900 1.900 #1 100 100 100 87 88 66 50 50 70 50 83 #2 100 100 100 100 100 100 100 50 50 50 #3 100 100 100 100 25 44 37 50 50 50 80 #4 100 100 100 100 100 30 15 #5 100 100 100 100 10 100 100 50 50 50 67 #6 100 100 100 100 100 31 30 #7 100 100 100 100 10 100 100 50 100 50 80 #8 #9 Slop 100 100 100 100 100 100 100 Dk 100 GM 1.479 1.326 1.359 1.367 1.299 1.423 1.439 1.713 1.488 1.365 1.348 100 100 100 100 100 100 100 100 100 100 24 100 100 50 50 92 50 50 85 Margin Damaged 0.078 0.016 0.030 0.042 0.053 0.259 0.284 0.171 0.162 0.005 0.006

Vessel is not at its marks at SG 0.63 or SG 0.74

Questions ?