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Transcript of Risk Watch Vol 15 No 3
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Regulatory update8 Brazilian coastal trade foreign crews beware
Navigationand Seamanship
1 Ballastblacklist dismissed byinvestigators as a cause for bulkergrounding
3 Apparent misuse of inshoretraffic zones
3 X-Band, S-Band
Containers and Cargoes6 Problems loading hot cement clinker
in bulk
7 More cement cargo problems
7 Beware bankrupt cargo interest
Miscellaneous8 Publications
Volume 15: Number 3
August 2008
The Britannia Steam Ship
Insurance Association LimitedRISK WATCH
Safety5 Fire onboard poor ship board practices
result in uncertainty and delay in dealingwith a fire in the cargo hold
5 Rescuers continue to die in significantnumbers
The May 2008 edition of Risk Watch dealt
with the grounding of the PASHA BULKER
in detail as recounted by the State
investigation into the incident.The Federal
Department responsible for investigations
(The Australian Transport Safety Bureau
ATSB) has now published its report, which
largely reflects the findings of the State
report on the actions of the Master of thePASHA BULKER.The report goes into a little
more detail on the part played by the coal
terminals ballasting requirements in the
grounding,and, at the same time, has some
interesting criticism of the Port Authority
albeit not in regard to any possible
ballasting blacklist.
Ballastblacklist
Dismissed by investigators as a causefor bulker grounding.
Whereas the summary of the report
states that initiatives by the coal terminal
operators, relating to improving the
performance of ships with regard to their
de-ballasting time, may have influenced the
decisions of some Masters not to ballast
their ships for heavy weather, the report
did not find that these measures were a
contributing factor to the casualties.
Whilst the report is critical of those vessels
which did not take heavy weather ballast, it
also points to the results of a questionnaire
of all vessels at the anchorage, in which only
three of the Masters who responded cited
concerns about ballast within the terminals
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Ballast blacklist continued
2 Britannia RISK WATCH Volume 15: Number 3: August 2008
vessel suitability list (the so called blacklist).The
report notes that; The vessel suitability
initiative may have heightened concerns of
some Masters at the time of the incident
because their ships being assessed as
unsuitable for loading would effectively
penalise their ships. Nevertheless,the report
agreed with the berth operators that they do
not penalise the vessels but rather operate an
approval process based on ship performance.
Although the ATSB acknowledge that the
existence of the vessel suitability list would
result in pressure on the Master and the crew
to provide explanations about an unsuitable
assessment of their ship, the report however
states that this was a problem of perception.
The evidence does not confirm that, at the
time of the incident, there were any compelling
reasons why the terminals ballasting
requirements would prevent Masters from
taking heavy weather ballast.
In support they refer to the example of those
3 ships whose berthing schedule on the 7/8
June coincided with the deteriorating weather.
None of the Masters of these three ships
indicated concerns about ballasting and all put
out to sea in good time. Further, the evidence
does not confirm with certainty that ships whichgot into difficulty on the 8 June, including
PASHA BULKER, were not appropriately ballasted
for heavy weather because of concerns about
the berth operators ballasting requirements.
The ATSB was clear in stating that; In any
case,the responsibility for ensuring a ship is
appropriately and safely ballasted at all times
rests with its Master.
Although the ATSB declined to criticise the coal
terminal operators, it did recommend that the
port authority and the Vessel Traffic Information
Centre (VTIC) take measures to address ten
safety issues.
The issues identified included:
the advisory role of the VTIC was not properly
understood by the Masters of a number of ships,
the port authoritys incident control system
was not activated early enough,
offers of help to the PASHA BULKER by the
VTIC were made at a late stage in extreme
weather conditions,
VTIC advice was limited to Masters of only those
ships that were dragging their anchors, and
VTIC did not cancel the scheduled berthing of
any ship even after the weather conditions hadbecome severe.
For its part the port authority has undertaken
to provide Masters of ships at Newcastle
anchorage with regular weather broadcasts
when a Bureau of Meteorology weather
warning is in place.
Unless the local port authority/VTIC clearly
indicates that they will give prompt and
comprehensive advice as to when the
anchorage becomes unsafe, it would seem
sensible for Masters to assume that no such
advise will be provided, and to act on their
own initiative.
The full article is available on the ATSB website
http://www.atsb.gov.au/publications/investiga
tion_reports/2007/MAIR/pdf/mair243_001.pdf
Navigation and Seamanship
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Apparent misuse of inshore traffic zones the UK Maritime & CoastguardAgency recently published a Mariners Guidance Note (MGN 364) on therouteing of vessels through the English Channel with special attention onthe use, or rather misuse, of inshore traffic zones, (ITZs).
It seems that the coastguard may be taking a
much closer look at vessels misusing the ITZs
in the Dover Strait.
At the same time, the UK Hydrographic Office
has republished BA Chart 5500, Mariners
Routing Guide English Channel and
Southern North Sea.
Navigators will be aware that under Rule 10 of
the International Regulations for Preventing
Collisions at Sea, 1972, the vessel, unless it is
shorter than 20 metres in length, is required
to use the appropriate traffic lane and, by Rule
10(d)(ii), can only use the inshore traffic zone
(ITZ) when en route to or from a port or any
other place situated within the ITZ or to avoid
immediate danger.MGN 364 usefully expands
upon Rule 10(d) by stating that the high traffic
density within a traffic lane is not sufficient
reason to justify the use of an inshore traffic
zone irrespective of the apparent absence of
traffic within that ITZ. Nor is restricted visibility,
with or without high traffic density, sufficient
reason to justify the use of an inshore traffic
zone. However, the guidance note goes on to
say that vessels may use an ITZ where
necessary to seek shelter from weather, but
reminds navigators that in so doing they may
encounter vessels heading in any direction.
Navigators should note that neither the
Channel Navigation Information Service
(CNIS) nor HM Coastguard (Dover) can grant
permission for vessels to use the English ITZ
in contravention of Rule 10(d). If Masters do
decide to use the English ITZ they must report
this fact to CNIS/Dover Coastguard.
MGN 364 reminds navigators that vessels are
tracked and recorded by radar and AIS
through the Dover Strait, and that any vessel
found contravening the Collision Regulations
(impliedly emphasising contravention of Rule
10(d)) will be reported to their Flag State or, if
arriving at a UK port, may be liable to
prosecution. Navigators regularly utilising the
traffic separation schemes in the Dover Strait
and Southern North Sea would find Section 4
of MGN 364 especially useful as it highlights
and clarifies how vessels should navigate in
some of the worlds busiest crossing points and
high traffic concentration areas.
http://www.mcga.gov.uk/c4mca/mcga-
mnotice.htm?textobjid=59809BACB29DBED8
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4 Britannia RISK WATCH Volume 15: Number 3: August 2008
X-Band, S-Band very early in their careers, navigators are instructed onthe difference between X-Band and S-Band radars.The difference is easilyunderstood and fundamental to efficient radar watch-keeping.
The detailed circumstances surrounding a
collision recently suffered by a Britannia Member
illustrates the consequences of navigators failing
to keep the fundamentals of radar watch-
keeping in the forefront of their mind.
The Members fully loaded bulk carrier was
proceeding north-easterly in open water.
An experienced Second-Officer was in charge
of the morning 8-12 watch and reported
variable visibility throughout the watch, being
poor at times with showers and drizzle.
Noticing that the forward mast-head light
appeared scattered and diffused,he estimated
visibility in the region of 1 nautical mile (nm);
this was confirmed by the 12-4 watch.The deck
log book had recorded rough to moderate sea
and swell with overcast sky and, inaccurately,
moderate to good visibility.
Throughout the morning 8-12 watch no vessels
were sighted either visually or by radar. However,
within 5 minutes of the afternoon (12-4) watch-
keeper taking over the watch, the look-out
visually sighted a light on the port side.The light
was diffused and indistinct but it did appear to
be close.The 12-4 watch-keeper immediately
put the vessel on hand steering and started
taking bearings of what now appeared as 2-
mast head lights and a green light, thought to
be side lights, along with deck lights astern.
The 12-4 watch-keeper assessed that there was
no time to take a series of bearings and
ordered starboard helm followed shortly by
hard to starboard the duty officer was then
disturbed by a call from the duty engineer
asking why an increased load had come on to
the main engine.The watch-keeper ended that
call abruptly and attempted to call the Master
but mistakenly called the Chief Officer and
reported the close quarters situation.
The watch-keeper then went to the port side of
the bridge and flashed the approaching vessel
with an Aldis signal lamp and then tried to raise
the vessel on channel 16 VHF. There was no
response.As his own vessel began to swing tostarboard, both vessels approached very close
and subsequently were parallel.The watch-
keeper assessed that it was necessary to go
hard to port in order to swing the stern away
from the other vessel.Unfortunately, this order
was given too late and contact was made
midships. A second contact was made further
aft.The contacts were thought to be slight.
Soon after,VHF contact was made with the
other vessel and details were exchanged.
Significant fault could be attached to the other
vessel, especially as it appeared that the other
vessels total lack of action to avoid the collision
resulted from the watch-keeper being asleep,
(a fact admitted by the radio officer in
exchanges with our Members vessel.) It is
however useful to address the faults of the 8-12
watch-keeper on board the Members vessel.
The 8-12 watch-keeper, when questioned, was
clearly aware of the advantages of S-Band radar
during conditions of rain and similarly was
familiar with the proper use of rain clutter and
sea clutter adjustments. However,only the
X-Band radar was turned on throughout thewatch and there is evidence that the rain and
sea clutter were not adjusted appropriately for
the prevailing conditions.The other vessel was
relatively large at 449 grt and 43m in length.The
steel construction of the other vessel should
have made an easily distinguishable target on
the S-Band radar if the rain and sea clutter were
adjusted appropriately. It is perhaps worth
noting that the X-Band radar was fitted with
ARPA and therefore was perhaps favoured
during ocean passage, when only one radar was
usually utilised.The usefulness of the ARPA
function perhaps led to the advantages of the
S-Band radar being overshadowed by the
convenience of the X-Band radar.There was no
explanation for the watch-keepers failure to
adjust the clutter appropriately and simple
oversight is presumed.
It should be noted that the 12-4 watch-keeper
did adjust the X-Band radar for sea and rain
clutter immediately upon taking over the
watch, but still did not observe the fishing
vessel.He did not utilise the S-Band radar but
in any event had no time to do so. It appears
that the S-Band radar was the only means by
which the vessel could have been located by
radar. It was not switched on however.
Navigators are reminded of Rule 5 of the
Collision Regulations (COLREGs);proper look-
outby all available means
During periods of rain and drizzle the 12-4
watch-keeper had correctly assessed the
visibility to be in the region of 1 nm.The
Masters standing orders clearly stated that he
should be called in the event of visibility falling
to 3 nm. This was not done.If it had been then
the possibility exists that the Master would havecome to the bridge and checked that the
correct radar were being utilised and that
clutter adjustments had been made. Masters
should be aware of a possible reluctance in
junior officers to call the Master irrespective of
standing orders.Masters should encourage
junior officers to call them even if this,
ultimately, proves to be unnecessary.
One further point. None of the watch-keepers
seemed to have considered the need for
sound signals, in accordance with COLREGs
Rules 34-36.
Navigation and Seamanship
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5
Fire on board poor ship board practices resultin uncertainty and delay in dealing with a fire inthe cargo hold.
The Australian Transport Safety Bureau (ASTB)
has recently issued a report into the fire on
board the BBC ISLANDER whilst off Dampier in
August 2007.The report highlighted that
failures in onboard safety management and
training can result particularly in the event ofan emergency in potentially dire
consequences.
The BBC ISLANDER is a general cargo ship that
had previously loaded deck cargo requiring
brackets to be welded on to the hatch covers.
Subsequently those brackets required removal
and a fitter was assigned to remove them with
oxyacetylene cutting equipment.The fitter
accidently cut a hole in the hatch cover and
sparks fell into the cargo hold causing
palletised cargo to catch fire.
The Master quickly decided to fill the hold with
CO, however his entire supply of CO was soon
exhausted with little apparent effect. He then
decided to notify the Harbour Master and
requested more CO and that the ship be
allowed alongside.
Two days later the vessel berthed and the local
fire and emergency services utilised more CO,
but still the fire remained alight.Thereafter, cargo
was removed to reach the seat of the fire so that
fire hoses could be utilised,but the fire persisted.
Expansion foam was utilised to flood the hull.
Still the fire persisted.Eventually, four days after
the fire began, it was extinguished by utilising an
off-shore supply vessels fire monitor to flood the
cargo hold with 700 tonnes of sea water.
It appears that:
The ships officers had not compiled accurate
or complete cargo stowage plans. Apart from
being in breach of SOLAS requirements, this
also meant that the Master and crew did not
have the proper information concerning thelocation and type of the different dangerous
goods on board to allow them to deal with the
emergency efficiently.
Although there was a safety management
system requiring a hot workpermit, the crew
had not been trained or supervised in the
implementation of that procedure. Additionally,
the fitter could not read English and hence
could not understand its requirements in any
event.Accordingly, no continuous fire watch
was maintained inside the cargo hold.
The incident illustrates what all good officers
know; without training and supervision it is
unlikely that safety management systems will be
implemented properly.
The report also highlighted that the shore
firefighters had little experience in responding
to, or fighting, shipboard fires.
http://www.atsb.gov.au/publications/investiga
tion_reports/2007/MAIR/pdf/mair245_001.pdf
Rescuers continue to diein significant numbers
Coincident with the UK Marine Accident
Investigation Branch (MAIB) report on fatalities
on board three separate vessels in the last year,
the Marine Accident Investigators International
Forum (MAIIF) has identified a large number of
fatalities in the shipping industry world-wide
which relate to work in confined or enclosed
spaces.The investigation by the MAIIF hasrevealed 129 fatalities and 123 injuries resulting
from entry into confined spaces
since 1991.
The three specific investigations by the MAIB
into the VIKING ISLAY, the SAGA ROSE and the
SAVA LAKE illustrate the tragedy of the initial
deaths often being multiplied by the highly
understandable, but nevertheless lethal, human
instinct to help a colleague in danger.
All three incidents involved either ballast tanks
or void/store spaces which had become
depleted of oxygen. In the VIKING ISLAY a third
seaman, improperly entering the space in order
to rescue two collapsed seafarers, died along
with his colleagues. In the SAVA LAKE and the
SAGA ROSE, seafarers were again tempted into
the enclosed/confined spaces in order to rescue
their fellow seafarers. Fortuitously the Chief
Officer on the SAVA LAKE having entered the
space, recognised the danger and turned back.
On the SAGA ROSE, the motor man collapsed
whilst attempting a rescue; thankfully he was
rescued following a prompt and efficient rescue
operation and made a recovery.
It cannot be over emphasised how critical it is
that seafarers, upon noticing the collapse or
unusual behaviour of a fellow crew member
whilst in any confined or enclosed space,resist
the temptation to assist by entering that space.
The MAIB report into VIKING ISLAY has already
been published and the other two reports will
be available shortly through the MAIB website.
Such reports could usefully be distributed
amongst all crew members who are likely toenter enclosed spaces by virtue of their duties.
http://www.maib.gov.uk/cms_resources/SB2-
08.pdf
Safety
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6 Britannia RISK WATCH Volume 15: Number 3: August 2008
Containers and cargoes
Problems loading hot cement clinker in bulk the Club managers havebeen assisting Members with two cases where the loading of hot cementclinker, in excess of 100 degrees centigrade, has posed a safety hazard andrisked damage to vessel hold paint coatings.
The remedy of course is to wait for it to cool
down before loading,but this too gives rise to
costs and delay that may be the subject of later
dispute between owner and charterers.Thisarticle seeks to highlight some of the issues
involved.
The background is that cement clinker is often
loaded directly from the processing plant
where it is baked at high temperatures.This
may have two problematical effects upon the
vessel.The first is that unless holds are coated
with temperature resistant coatings- typically
glass fibre the hold paint coatings will be
damaged, as may the ballast tank coatings.The
second and more important problem is that
the temperature of the IFO in double bottom
fuel tanks may be raised above the flash point
with attendant risk of explosion.In one of the
cases that we saw, the paint coatings were
severely damaged, and bubbled off over large
surface areas, requiring complete re-painting of
the affected holds,with attendant downtime.
Expert advice received by the Club is that for
vessels not equipped with a temperature
resistant hold coating,the means to avoid
these risks is to equip the vessel with suitable
thermometers capable of measuring
temperatures up to 200 C. Prior to loading,the
Master should verify the temperature of the
clinker presented at ships side by physically
measuring temperatures within the bulk of the
stow in barges or lorries. No cargo in excess of
the FP of the IFO should be accepted, and
cargo in excess of 80 C should be allowed to
cool before loading.Protest letters should be
issued as necessary. Many cement clinker load
ports are well used to taking these precautions,
and their protests will be minimal.
During loading of cement clinker, double bottom
tanks should remain filled as long as longitudinal
stress, trim and draft permit, as these provide
boundary cooling to fuel tanks and holds.
Throughout the loading ships staff should
continue to monitor temperatures as cargo is
brought to the vessels side,and any over-heated
cargo should be rejected until it has cooledsufficiently. A record must be kept showing
where temperatures are taken, by what means,
by whom, times and of course temperatures.
The practice of trying to admix the cargo using
grabs in an attempt to cool it has little value
in so far as hold coatings are concerned, as the
damage is done whilst loading.The only sensible
preventive measure is to not permit overheated
cargo to be loaded as described above.
The alternative to the above is to upgrade the
hold coatings to an alkyd based heat resistant
coating of a type that will tolerate loading at
temperatures up to 160 C without damage to
the coating. Such coating may have an
aluminium or glass pigment that is designed to
withstand the much higher temperatures
encountered when cargo is loaded direct from
the bake house or k iln.
The charterer stated, in one of the cases
handled here, that the risk of heating bunkers
in tanks adjacent to very hot cargo, up to their
flashpoint,was minimal, since the atmosphere
would be too rich for ignition within the tank,
and further there was no source of ignition
within the tank.
The expert advice in response was that vapour
may vent on to the deck via the air pipes of
each of the fuel tanks.The vapour leaving the
tank may well still be above the flashpoint. On
deck there are plenty of sources of ignition.
Stevedores smoking, mobile phones, non-
intrinsically safe lighting, motors, radios, etc. Any
of these could cause ignition of the vapour ondeck. Provided the flash screens in the air pipes
are intact it is not likely that a major fire would
result.However if the flash screen is inefficient
then there could be a blow back into the tank.
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7
More cement cargo problemsThe Association continues to have problems
with cement cargoes that have hardened
because of leaking ballast tanks.The price of
cement has risen significantly in line with
most commodities in recent years but the
cost of any cargo damage is quite often
overshadowed by the significant
operational difficulties in loosening and
disposing of hardened cement cargoes.
Masters and crew are reminded of the
importance of pressing up all ballast tanks
adjacent to cargo holds destined to receive
cement, and to closely inspect those holds
for any signs of leakage.Particular attention
should be paid to vent pipes and sounding
pipes passing through the hold.
Inspecting holds on a ballast voyage may
be quite difficult and cherry pickers are
rarely available to Chief Officers inspecting
the upper reaches of a hold, and it is
recognised that inspection of piping can
be especially difficult.
A somewhat old fashioned practice
amongst deck officers was to carry
binoculars whilst working cargo alongside
for the purpose of inspecting derrick and
crane rigging. Given the difficulties that arise
from the smallest of leaks, deck officers may
consider this practice when undertaking the
pre-load inspection of holds.
Beware bankrupt cargo interestThose Members operating liner services would
especially be aware of the expense and nuisance
generated by cargo which is uncollected by
reason of cargo receivers becoming bankrupt.The
Association has recent experience of the difficulties
which Member's agents face when confronted
with the need to dispose of the uncollected
cargo and at the same time the complex and
powerful legal rights given to Court-appointed
administrators of an insolvent company.
In the subject case cargo had not been collected
for over 6 weeks, in which period the Member
had sent several warnings and notices to the
receiver that a lien would be enforced and the
cargo disposed of.None of those notices received
an answer but shortly thereafter a firm of
accountants contacted the Member by
telephone advising that they were the
administrators of the consignee company, which
was in financial difficulty.The administrators
requested extra time to arrange their own sale of
the cargo.Members agent agreed to give the
administrators a week to do so on the expressunderstanding that the lien would be exercised
(i.e. they would force the sale of the goods) if the
administrators failed to pay Members by that
date.The existence of the Administration Order
was only referred to in oral telephone
communication and the time extension agreed
by e-mail.The administrators did not explain that
they were appointed by the Court or what their
powers were nor did they request any further
extension of time.The deadline passed without
any further contact from the administrator and
the Members accordingly arranged the sale of
cargo to salvage buyers to defray their own cost.
After the administrators became aware of the sale
they accused Members of acting in contempt of
Court by breaching the Administration Order.
They subsequently brought proceedings against
the Members in that regard.The Member argued
that the administrators had failed to properly
serve the statutory notice of their appointment.
The legal issues were complex and rather than
embark on an expensive legal battle the claim
was settled on a negotiated basis.
The salutary lesson to be learned is that
Members and their agents, when contacted by
anyone purporting to be a Court appointed
administrator of an insolvent consignee
concerning uncollected cargo should be very
wary of assuming contractual rights of sale and
if in any doubt whatsoever should seek the
assistance of the Association and/or lawyers.
The question of who is liable for damage to
coatings and loss of time in such cases will be a
complex one. Under a time charter it may often
be the responsibility of charterers to load, stow,
trim and discharge the cargo at their risk and
expense. But this may not absolve the Master of
his duties to supervise the loading insofar as it
impacts on the safety of the vessel, and where
the Master fails to intervene when it is clear
that a cargo is hot enough to damage the tank
coatings, this too will impact on the partiesrespective liabilities for the consequences.
Other charter clauses that may be relevant are
the Clause Paramount incorporating the Hague
Rules which provide that the vessel is not to be
employed in the carriage of dangerous or
injurious cargo.
A Member cannot be certain that his experts
view may go unchallenged in any subsequent
arbitration.The lawyer instructed for our
Members on one of the above cases advised:
In relation to the decision not to load cargo
above 80 C, I should hope that an arbitrator
would accept that,given the safety issues
involved, neither the Master nor owners should
be criticised for refusing to load said cargoes
until they had cooled.Further there may be
issues relating to the ability of the hold paint to
tolerate cargoes in excess of 80 C. There is a
risk that owners may be found liable if it is
found that the paint in the hold should have
been able to withstand higher temperatures.
These factors underline the importance of
Members knowing in detail about the coatings
in the vessel holds,and the manufacturers
guidelines for what they can withstand, before
fixing cargoes of this type.Where Members
seek expert guidance before loading and
before damage to the vessel has occurred, this
will do much to mitigate possible subsequent
losses that may be the subject of lengthy and
expensive litigation.
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Brazilian coastal trade foreign crews beware
We are grateful to our correspondents in
Santos, Brazil,Pandibra McLintock, for this
advice about crew visas in Brazil.
The immigration authorities in Brazil are
currently insisting that crews of foreign ships
working in the coastal trade for more than
30 days must have a full working visas. Such
visas are quite difficult to obtain and can only
be issued from consular offices outside Brazil.
This rule is, in fact, inconsistent with Brazil ian
law on the subject, which does allow foreign
crews to work in the coastal trade without full
working visas. However,the immigration
authorities nevertheless insist on the visa
Regulatory update
Publications
Integrated Bridge Systems Volume 1
Radar and AIS By Dr Andy Norris
From 1 July 2008, all new radars required
mandatory AIS integration;this combined use
of data is an innovative example of the power
and capability of modern shipboard
technology to display two completely separate
systems on the same display.While much effort
has gone into ensuring the AIS, radar and chart
information is consistent,with uniform symbols
and a standard resolution, operators still needguidance and instruction.
This new book by Dr Andy Norris and
published by the Nautical Institute builds on
the basic radar theory and target tracking
knowledge that seagoing officers already have
while looking ahead into the future where
New Technology (NT) radars will provide
significantly enhanced performance.
For more details and order information please
go to:
http://www.nautinst.org/press/pdf/radarAIS.pdf
or www.nautinst.org
Editors message We are always looking for ways to maintain and increase the usefulness, relevance and general interest of the articleswithin Risk Watch. Please forward any comments to: [email protected]
8 Britannia RISK WATCH RISK WATCH is published by The Britannia Steam
Ship Insurance Association Limited, and can be
found at www.britanniapandi.com/publications
The Britannia Steam Ship Insurance Association
Limited is happy for any of the material in Risk
Watch to be reproduced but would ask that
written permission is obtained in advance from
the Editor.
Tindall Riley (Britannia) Limited
New City Court
20 St Thomas Street
London SE1 9RR
Tel +44 (0)20 7407 3588
Fax +44 (0)20 7403 3942
www.britanniapandi.com
Miscellaneous
requirement.In order to challenge the
immigration department, it is necessary to start
legal proceedings, which inevitably means that
ships can face delays.While such disputes arebeing resolved, crew members could also face
forced repatriation by the authorities.
Members are advised to check carefully with
local agents to make sure that they are aware
of the current situation and visa requirements
in Brazilian ports to avoid any possible
problems with the immigration authorities.