Conditions of Class, Recommendations and the Vetting Process · Conditions of Class,...

Conditions of Class, Recommendations and the Vetting Process

Vince JenkinsGlobal Marine Risk AdvisorLloyd’s Register

Intertanko Vetting SeminarLondon, 29th March 2011

Presenter

Presentation Notes

Introduction

• Shared objectives & background• Effects of using CoC’s in vetting regime• Action taken• Intertanko membership survey results

Different roles – common interest• ..the promotion of safety and

prevention of pollution from tankers and at oil terminals

• … in serving the world with the safe, environmentally sound and efficient seaborne transportation of oil, gas and chemical products

• Safeguard Life, Property and the Environment

• … for the purpose of enhancing the safety of life and property at sea, on land and in the air

• …promoting security of life, property and the natural environment

Since 1970

Since 1970

Since 1864

Since 1760

Since 1862

Condition of Class or Outstanding Recommendation Definition (IACS PR35):• “Recommendations” and “Conditions of Class” are to be understood

as being different terms used for the same thing, i.e. requirements to the effect that specific measures, repairs, surveys are to be carried out within a specific time limit in order to retain Classification.

Examples:• Repairs and/or renewals related damage that affect Classification

(e.g. from a grounding, structural damage, machinery damages, localized wastage over the allowable limits, etc.)

• Temporary repairs

Any deficiency that, in the opinion of the surveyor, will need rectification and which is not dealt with upon completion of the survey will be recorded as a condition of class. The time permitted for rectification will reflect the criticality of the defect

A ship with a CoC• They are evaluated as requiring rectification, but the surveyor considers

they do not have a material affect on the vessel’s safety provided rectification takes place within a specified time, dependent upon the severity of the condition

• Due date for rectification will vary depending on the severity of the defect e.g.:

• Before leaving port• At next port of call• Before next cargo voyage • In connection with first scheduled dry-docking for minor items • Typical due dates are in the range 1-3 months

Assessment of the criticality is done by a surveyor trained and qualified to do this • Decision is based on applicable Rules and Instructions/Guidelines• May be supported by reference to more experienced survey staff within the organisation for guidance

Effects of CoC / Recommendations within Vetting

• Intertanko / Owner / Operator• Reduced repair / dry dock planning• ‘Repair now’ through to ‘not declaring the condition’• The Intertanko survey findings reveal more

• Class• Erosion of one of the principal mechanisms which ensures

the classed fleet is maintained to the appropriate standard

Imagine the scenario - An owner has an oil release incident. Subsequent investigation reveals that the owner hid what would have been a CoC, which may or may not have contributed to the incident. When asked why they hid

the condition, they respond that it was due to the use of CoC’s within the vetting regime and the commercial implications. The media spot light will then

turn on those involved in vetting and assuring safety.

Initial activity

Jan 2010 – 6 actions1. Provide a revised form of CoC

wording for the SIRE Committee2. Present to the OCIMG GPC what

CoC are, how they are used & impact of vetting use

3. Explore the OCIMF data for links between use of CoC in vetting and increasing CoC use

4. Explore the Intertanko data for any link between use of CoC in vetting and increasing CoC use

5. Reduce the ambiguity in how Class report CoC

6. Provide training to vetting staff on CoC

May 2010 - 3 actions7. Provide an information paper to

OCIMF GPC which should include quantitative data

8. Provide quantitative data from Intertanko members on the effect of using CoC within vetting

9. Provide quantitative data from Class on the effect of using CoC within vetting

Examples February 2011

A observation has been raised due to a memorandum, which broadly states ‘….due to the % carbon of the rudder stock, class should be consulted if the

need arises for any welding to be undertaken on the stock…….’

An owners vessel has had an observation made by the vetting inspector associated with an emergency generator quick closing valve, which is a

requirement of SOLAS introduced in 2002. The vessel was built in 1996 and does not have to comply with the 2002 requirement.

Intertanko survey

• Undertaken in response to OCIMF asking for an evaluated understanding of response to the use of CoC’s within vetting

• Undertaken 30th July – 24th August 2010• Anonymous on line survey of Intertanko membership• 133 responses ~ 53% of membership • Questions focused on:

• Background; Clarity; Attitudes; Impact

Intertanko survey response - background

0% 10% 20% 30% 40% 50% 60%

Q1> 2011-200-10

How many tankers do you manage?

0% 10% 20% 30% 40% 50%

Q2> 10 yrs6-10 yrs3-5 yrs0-2 yrs

How long have you been a superintendent?

0% 10% 20% 30% 40% 50%

Q3>10 yrs6-10 yrs3-5 yrs0-2 yrs

How long have you been employed by your current employer?

Results from Intertanko membership survey August 2010

Intertanko survey response - clarity

0% 10% 20% 30% 40% 50% 60% 70%

Q4 NoYes

Do you believe the definition of a condition of class is clear?

0% 10% 20% 30% 40% 50% 60%

Q5SometimesNoYes

When a CoC has been imposed do you generally believe they are technically justified?


Intertanko survey response - attitudes

0% 10% 20% 30% 40% 50% 60% 70%

Q6 NoYes

0% 10% 20% 30% 40% 50% 60% 70%

Q7 NoYes

Do you think charterers attitude towards CoC has changed in the last 5 yrs?

0% 20% 40% 60% 80% 100%

Q8SometimesNoYes

Do you think charterers see a CoC as negative?

Has your attitude towards CoC changed in the last 5 yrs?

0% 10% 20% 30% 40% 50%

Q9SometimesNoYes

0% 10% 20% 30% 40% 50%

Q10SometimesNoYes

Do you think your company see a CoC as negative?

Do you personally see a CoC as negative?


Intertanko survey response - impacts

0% 20% 40% 60% 80% 100%

Q11 NoYes

Have you experienced any commercial pressure to not have a CoC imposed?

0% 10% 20% 30% 40% 50% 60%

Q12NeverRarelyFrequentlyAlways

Are there times you do not report issues to Class due to concerns that it could lead to a CoC

0% 10% 20% 30% 40% 50% 60% 70%

Q13 NoYes

Have you ever tried to persuade a Class surveyor to not impose a CoC due to commercial pressure

0% 10% 20% 30% 40% 50% 60% 70%

Q14

Internal SMS reporting Internally through management structureClass Society FlagNot at all

If you find a deficiency that you think may lead to a CoC how is it reported?

0% 20% 40% 60% 80%

Q15 NoYes

Do you ever plan your surveys towards the end of a survey window due to a concern that a CoC may be imposed on a known issue?


Free text response to Q6 ‘Do you think charterers attitude towards CoC has changed in the last 5 yrs?’ 80 Yes (60%); 53 No (40%)

• 80 responses• 31 (39%)Responses stating that CoC is simply rejected• 32 (40%) Responses stating that there is no

interpretation / differentiation / understanding of the CoC by the vetting inspector / oil major

• 6 (8%) Responses stating that vetting inspector / oil major has an alternative view to the class surveyor

• 11 (13%) Miscellaneous responses ~ commercial; media sensitivity; others


Free text response to Q6 ‘ Do you think charterers attitude towards CoC has changed in the last 5 yrs?’ 80 Yes (60%); 53 No (40%)

• 80 responses• 31 (39%) Responses stating that CoC is simply rejected

• Vessels are rejected by oil majors because of CoC• Due to vetting and the fact that CoC is NOT

acceptable

Verbatim text from Intertanko membership survey August 2010

Free text response to Q6 ‘ Do you think charterers attitude towards CoC has changed in the last 5 yrs?’ 80 Yes (60%); 53 No (40%)• 80 responses

• 32 (40%) Responses stating that there is no interpretation / differentiation / understanding of the CoC by the vetting inspector / oil major

• They are very apprehensive about CoC as terminals and Oil Majors view it as potential hazard. For instance, one of our vessels had a connecting rod failure in one of the three generators and, as a prudent owner we informed class and took CoC and currently under process of rebuilding the damaged generator. We are unable to carry out Oil Major inspection because their criteria clearly mention vessel with CoC will not be accepted. Frankly, such poor technical view of Oil Major leads to superintendent and in case certain owners hiding facts due to losing oil major acceptance and failure to secure or lose a charter and that can have dangerous consequences. I feel such things are arising more because of poor competency and experience and creation of safety hype by dominant oil majors, without realizing the after effects.

• There appears to be little understanding from Charterers what a Condition of Class represents. There is a blanket non acceptance as their perception of risk management does not evaluate circumstances on a case by case basis. Conditions of Class are understood by Owners, Managers and Classification Societies. Charterers are trying to use these to police the market without recognising the actual requirement for the condition of class.


Free text response to Q7 ‘Has your attitude towards CoC changed in the last 5 yrs? 48 Yes (36%); 85 No (64%)

• 48 Responses• 18 (38%) Simply stating used to penalise the vessel• 19 (40%) Close out / do not want a CoC due to vetting

implications• 4 (8%) Comments on class• 7 (14%) Miscellaneous others



• 48 Responses• 18 (38%) Simply stating used to penalise the vessel

• They give a more negative view to charterers, therefore have become more of a problem to owners.

• I try to avoid more than before



• 48 Responses• 19 (40%) Close out / do not want a CoC due to vetting

implications• This depends on what cargoes you load and the customer you carry cargo for. It is

hard to justify urgent repairs of non critical equipment just for the case of a non understanding inspector. This again result in less available funds for normal and proper maintenance

• Concerns have increased due to the way Oil Major, Terminal Inspector and Charterers view it. That in practicality has increased stress level with superintendents and cost and off-hires are increased to get it cleared at earliest. I do believe in certain CoC which can be cause of safety concerns should be done without delays but certain items where redundancy is available can be carried out properly and cost effectively.


Conclusions

• Objectives of both Oil Majors, Intertanko & Class are the sameHigh quality tonnage

• The effects of using Condition of Class & Recommendations with in the vetting regime are:

Giving Charterers tonnage without CoC’s, but alsoErosion of one of the principal mechanisms which ensures classedfleet is maintained to the appropriate standardDissuading operators from planning for repair / dry dockInappropriately reprioritising ship operators spending Implications for industry if operators decide to hide a material state which would lead to a CoC which is later found out after an incident

• Intertanko survey results OCIMF GPC 12/13th April 2011 China

Different roles – common interest• ..the promotion of safety and

prevention of pollution from tankers and at oil terminals

• … in serving the world with the safe, environmentally sound and efficient seaborne transportation of oil, gas and chemical products

• Safeguard Life, Property and the Environment

• … for the purpose of enhancing the safety of life and property at sea, on land and in the air

• …promoting security of life, property and the natural environment

Since 1970

Since 1970

Since 1864

Since 1760

Since 1862

Conditions of Class, Recommendations and the Vetting Process · Conditions of Class,...

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