IMO HARMFUL AQUATIC ORGANISMS IN BALLAST WATER. IACS Hazard Identification (HAZID) of Ballast Water Exchange at Sea - Bulk Carriers

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1 INTERNATIONAL MATIME ORGANIZATION E IMO MANE ENVIRONMENT PROTECTION COMMITTEE 45th session Agenda item 2 MEPC 45/2/1 27 June 2000 Original: ENGLISH HARMFUL AQUATIC ORGANISMS IN BALLAST WATER IACS Hazard Identification (HAZID) of Ballast Water Exchange at Sea - Bulk Carriers Submitted by the International Association of Classification Societies (IACS) SUMMARY Executive summary: This paper presents the IACS report "Hazard Identification During Ballast Water Exchange at Sea - Bulk Carriers". Action to be taken: See paragraph 7 Related documents: MEPC 41/9/2 1 A HAZID-report on ballast water exchange at sea (BWE) bulk carriers has been compiled by IACS and is attached at annex. The Structured What-IF checklist Technique (SWIFT) has been applied to ballast water exchange (BWE) at sea. 2 In 1998, IACS conducted a preliminary hazard identification study (HAZID) of BWE for all ship types, identifying various additional hazards and recommending that each ship should have a BWE plan (MEPC 41/9/2). A BWE plan has now been developed for a representative bulk carrier, and it was decided to carry out a HAZID of this ship and its plan using the SWIFT. 3 In the BWE plan for the selected bulk carrier a set of safety critical parameters are calculated for the sequence of ballast operations that are required to replace the ballast water taken onboard in harbour by ballast water taken onboard at sea. Such a plan should be provided for each loading condition (light ballast, heavy ballast, homogeneous loading, alternate loading etc.). The parameters presented for the selected ship were: lightship weight, bunkering weight, water ballast, cargo, dead-weight, displacement, draft equiv.(draft corresponding to displacement), draft at fore peak., draft at aft peak, trim, transverse meta-center above base line, KG, free surface correction by liquid, G M=GM-GG, C.C.G, L.C.B, L.C.F, M.T.C, T.P.C, propeller immersion, max bending moment, and maximum shear force. For reasons of economy, this document is printed in a limited number. Delegates are kindly asked to bring their copies to meetings and not to request additional copies.

2 - 2-4 The BWE plan for the selected ship was a plan based on the sequential method (sequential emptying and refilling tanks/holds). Some intermediate loading conditions were at the design limit for strength. For the purpose of this HAZID, however, the group also considered associated hazards where a flow through method may be employed for BWE. 5 The conclusions drawn as a result of this HAZID can be found at section 11 of the annexed report, and are reproduced as follows:.1 Ballast system needs more attention because of increased hazards during BWE at sea (with BWE at sea the ballast system is safety critical)..2 New rules for ballast system should be considered..3 New rules for survey of testing of ballast systems should be considered..4 BWE should be addressed in IMO regulations (e.g. ISM, STCW)..5 Severity of hazards combined with frequency of operation suggest necessity for FSA for relevant risk control options..6 Procedures, training, and planning for BWE should be consistent with other safety critical operations..7 Design of ballast system and associated control and vent system should take account of BWE at sea..8 Class rules should be assessed to establish the degree of coverage and improved where necessary..9 Recognised safety margins should be verified for use during BWE allowing for actual weather conditions..10 IMO should further develop BWM model plans, including model plans for generic ship types. The ICS/INTERTANKO plan could be used as a starting point..11 Loading instruments should be verified to become a safeguard during BWE..12 The overall decision on BWM should take account of hazards to the ship, environmental drawbacks, as well as the environmental benefits..13 Hazards of BWM may not be fully appreciated within the shipping industry as a whole. More education and awareness may be necessary..14 Standard guidelines for the development of BWM/BWE should be developed..15 It should be recognised that BWE at sea significantly increases the risk affecting BC operation. It is important to allow the master not to proceed with BWE in case of unfavourable weather conditions..16 Existing safety measures and monitoring/safety systems/gauging on board should be reassessed to take into account additional hazards arising from BWE at sea.

3 - 3 - MEPC 45/2/1.17 BWE should not be allowed at sea unless a BWE plan has been developed based on verified, updated information and approved..18 Class rules should be reviewed with regard to BWE at sea in terms of: Permissible strength limits; Sloshing loads and the unique aspects of the flow through method; and Explicit considering BWE by flow through method..19 Hazards identified here are not unique to BCs and can apply to all ship types. However, other ship types will present hazards not present for BCs (e.g. related to stability)..20 The study should be extended to other bulk carriers and non-bc. 6 FUTURE IACS ACTION IACS has categorized the identified hazards into three principal areas and has tasked three specialist IACS working groups to evaluate current rule requirements and the need for enhancements in aspects related to the capacity and functionality of the ballast system and the ship's strength and stability. The impact of the "flow through" and "sequential" methods on new ships (which can be designed to more efficiently and safely carry out ballast water exchange) versus existing ships will be considered in association with the time duration and complex/numerous steps needed to carry out complete exchange for certain types of ships. Action requested of the Committee 7 The Committee is invited to note the foregoing, take action as appropriate and advise the Maritime Safety Committee accordingly. ***

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5 International Association of Classification Societies (IACS) HAZID of Ballast Water Exchange at Sea For Bulk Carriers By SWIFT

6 Page 2 1. OBJECTIVE OF THE STUDY The objective of the study was to identify hazards that are unique to BWE at sea, so as to assist with the development of rules and regulations by IACS or at IMO. 2. DEFINITIONS OF BWM/BWE PLANS Ballast water Management Plan (BWM plan): A ballast water management plan typically would consist of the following sections: 1) Description of ship particulars; 2) Explanation of the need for ballast water management; 3) Description of ballast water arrangements on board; 4) Safety considerations relevant to ballast water management; 5) Procedures for managing ballast water on board. If ballast water exchange is a selected management option this section is the ballast water exchange plan (BWE plan); 6) Ballast water sampling points (for crew or port state control by quarantine authorities); 7) Crew training and familiarisation; 8) Duties of ballast water management officer; 9) Ballast water reporting form and ballast water handling log; and 10) IMO resolution A.868(20). A model ballast water management plan has been prepared by International Chamber of Shipping/INTERTANKO. In the future ballast water management plans may become mandatory by IMO. Currently ballast water management plans are prepared in accordance with A.868 (20). Ballast water exchange plan (BWE plan): The BWE plan is a document containing a description of a sequence of ballast water operations resulting in ballast water exchange. A sequence is presented for relevant loading/ballast conditions. For each step in the intermediate ballast water exchange sequence it is documented that the ship is within allowable strength and stability limits. A BWE plan may be part of the BWM plan. For a bulk carrier the BWE plan may also be part of the loading manual which is approved by class according to UR S1A. At the SWIFT meeting such a BWE plan was presented.

7 Page 3 3. GENERAL APPROACH TO THE STUDY 3.1 Main Elements of study The main elements of the study approach were: Select a representative bulk carrier and BWE plan. Examine the BWE plan and identify critical intermediate loading conditions under which safety margins are lowest. Develop a detailed procedure for the selected loading condition, identifying systems and personnel involved in the operation. Identify hazards, i.e. deviations from plan that might lead to an accident, especially hazards that are unique to BWE at sea. Identify safeguards, i.e. statutory, class or internal requirements that can prevent or mitigate each hazard. Rank hazards and categorise safeguards in order of priority (for later analysis, as required by HAZID (Step 1 of FSA), in the Interim Guidelines for the Application of Formal Safety Assessment (FSA) to the IMO Rule-Making Process). Consider how representative is the specific design for the bulk carrier fleet as a whole, including class society differences. Prepare a HAZID study report with recommendations fore new safety rules and regulations by IACS and at IMO. 3.2 Structured What-If Checklist (SWIFT) Technique SWIFT is a systematic team-oriented technique for hazard identification (HAZID). It can be contrasted with other HAZID techniques as follows: SWIFT can be used to address systems and procedures at a high level. It considers deviations from normal operations identified by brainstorming, supported by checklists. Standard HAZOP (hazard and operability study) is usually applied to process flow at a detailed piping & instrumentation level, and identifies deviations from design intent by means of guide-words. It may be noted that in the marine industry the term HAZOP is often used loosely where the term HAZID (for an operation) would be more appropriate. FMEA (failure modes and effects analysis) addresses hardware at the level of detailed equipment items, and does not usually consider the human element. SWIFT, like standard HAZOP, can be used to address operability issues as well as safety hazards. SWIFT may be used simply to identify hazards for subsequent quantitative evaluation, or alternatively to provide a qualitative evaluation of the hazards and to recommend further safeguards where appropriate.

8 Page 4 SWIFT, like any group-based HAZID technique, relies on expert input from the team to identify and evaluate hazards. The SWIFT facilitator s function is to structure the discussion. The SWIFT recorder keeps an on-line record of the discussion on a standard log-sheet. There is no single standard approach to SWIFT - one of its strengths is that it is flexible, and can be modified to suit each individual application. 3.3 SWIFT Protocol used in the study 1. Define BWE operations Consider each operation in sequence. 2. Brainstorm possible hazards, e.g. What if...?, How could...? List but do not discuss hazards yet. Once ideas are exhausted, use previous accident experience to check for completeness. 3. Structure the hazards into a logical sequence for discussion. Start with the major ones, so that escalation of initiating ones can be cross-referenced. 4. Consider each hazard in turn. Consider possible consequences if the event occurs. Consider safeguards that are in place to prevent the event occurring. Consider whether additional safeguards are needed Record discussion on SWIFT log-sheets 5. Reconsider whether any hazards have been omitted, using a generic checklist 3.4 SWIFT generic checklist Operating errors and other human factors e.g. crew error, accidents (falls, trapping, trips, access to dangerous areas), illness or injury, passenger error, abuse of equipment etc. Measurement errors e.g. passenger numbers, cargo/vehicles, trim, GM, navigation etc Equipment/instrumentation malfunction e.g. structural failures, equipment failure, control system failure etc Maintenance e.g. dangerous areas, permit systems, control of modifications, mechanical handling, danger to passengers etc Utility failure e.g. power, air, fire water, communication systems, lighting etc Integrity failure or loss of containment e.g. fire, loss of containment

9 Page 5 Emergency operation e.g. evacuation, fire etc External factors or influences e.g. transport accidents, impact, other accidents on-board or near to the ship, terrorism etc 4. REFERENCE DOCUMENTS ICS/INTERTANKO model ballast water management plan Documents available for a particular ship: Ship capacity plan Ship-specific BWE plan (as part of BWM) Loading Manual (also includes BWE plan) Piping System Diagram Hull Piping Diagram except living quarter Machinery Arrangements in E/R Instrument List Valve Remote Control System Damage Stability Calculation Interim Guidelines for the Application of Formal Safety Assessment (FSA) to the IMO Rule-Making Process (Steps 1 and 3) IMO resolution A.868(20) 5. SHIP TYPE-BULK CARER 5.1 Selected ship The selected representative bulk carrier was an existing 73,000 dwt 7-hold single-skin Panamax vessel, for which a BWE plan had been developed, based on the sequential exchange method. It was noted that the aft peak had to be emptied and filled twice to stay within acceptable limits (propeller immersion)..4 cargo hold is used for ballast water in the heavy ballast condition. The ship was a single side skin bulk carrier, with topside and lower hopper tanks, which load high density cargo and comply with the strength and stability survivability standards of SOLAS chapter XII and has an approved loading manual complying with IACS UR S1A. The selected BC has 2 main ballast pumps situated in the machinery space, serving all ballast tanks including the fore and aft peak tanks through two ballast main running through the pipe tunnel located amidships and of the same height as the port & starboard DB ballast One ballast main connected fore peak, aft peak, port side DB tanks, hopper tanks and.4 cargo hold. The other ballast main connected starboard side DB tanks, hopper tanks and.4 cargo hold. The two ballast main are cross connected such that either both or each of the pumps can be used to serve either port or starboard or both the ballast. The ballast pumps are also connected through appropriate isolation valves to the bilge system and fire pump. Hopper and DB tanks are connected. The ballast main connected to each DB and the fore peak tank has isolation valves fitted at the tank situated inside the

10 Page 6 pipe tunnel and in the case of fore-peak, inside the tank. The ballast pumps are fitted with isolation valves at the pump as well as the appropriate valves at the overboard discharge and the sea suctions port 7 starboard. Valves status (open/closed) is indicated in the control room as well locally inside the pipe tunnel. The valves are remotely operated. Each ballast tank is fitted with vent pipe with automatic means of closure at the outlets located at the main deck level. Also tank level reading are available in control room. 5.2 Representative ship As far as the hazards were concerned this ship was considered representative of all existing single side skin bulk carriers, with topside and lower hopper tanks, which load high density cargo and comply with the strength and stability survivability standards of SOLAS chapter XII and has an approved operating manual complying with IACS UR S1A. Bulk Carriers carrying deck loads, and combination carrier were excluded. 6. PROCEDURE FOR BWE Design of ballast system, venting system, tank level system. Development of BW management plan, BWE plan, loading manual. Ship informed that BWE will be necessary before leaving port. Sequence of ballasting operations at sea, each involving: Planning prior to start: How long will it take? Is there an appropriate weather window? (Consider strength and stability margins for the operation under predicted weather conditions). Line-up and open appropriate valves for BWE (tank valve, close other tank valves). Typically up to 10 valve alignments per operation to flood/empty a tank. There are special locking arrangements for floodable cargo hold valves. Check that vents are clear. (Vents may be designed to avoid under/over pressure). Confirm tank level (by remote gauge or manual sounding). Open ballast pump suction and overboard discharge valves (or sea chest suction valves). Start the pump. Monitor tank level. As end of operation approaches, monitor more closely and reduce pump speed. Stop pump. Close valves. Confirm tank level reading and record in log. 7 LOADING CONDITIONS 7.1 Ballast conditions Light ballast condition - with DB and hopper tanks filled with BW and no cargo. This would be used in calm or moderate weather, and hence would be the most likely starting condition for BWE. If the cargo hold is filled at sea, BWE of this hold may be unnecessary as the BW is already clean. Heavy ballast condition - with DB and hopper tanks and 4 floodable hold filled with BW and no cargo. This would be used in severe weather.

11 Page 7 Partly loaded condition - with some cargo and some ballast tanks filled with BW. This may be the starting condition for BWE, with less BW involved. Details of such partly loaded condition could be varying (strength and stability wise). In this condition all BW would not normally need to be discharged at the arrival port. 7.2 Critical intermediate conditions The BWE plan for the representative ship showed Conditions 51 and 42 were the most critical in terms of BM and SF. The ballasting operations outlined above would be similar for all conditions. The stability margins were well above the safety limits and thus it was not considered necessary to expand on this issue in detail. 8. RESULTS OF HAZARD BRAINSTORMING 1. Inadequate ballast system design 2. Valve failure 3. Pump Failure 4. Pipeline Failure 5. Overpressure in Tank 6. Remote operation system failure 7. Valve control system failure 8. Power failure 9. Gauging system failure 10. Tank under-pressure 11. Maloperation of valve 12. Failure of Venting System 13. Remote/Local valve indication failure 14. Structural failure 15. Maloperation of closing devices in cargo hold 16. Failure to remove closing devices 17. Valve open/closing in wrong sequence 18. Miscalculation onboard 19. Poor maintenance 20. Continuous use of pumps 21. Inadequate/insufficient manpower 22. Inadequate training 23. Unintended filling of tanks (cross) 24. Overfilling of tanks 25. Original BWE plan wrong/inadequate 26. BWE plan not used/followed 27. Blockage of sea suction 28. Icing on deck 29. Weather changes 30. BE in severe weather (HE) 31. Time pressure 32. Reduced system capability 33. Low quality weather prediction 34. Suction/overboard head location does not suit pump performance 35. Exceed permissible bending moment 36. Exceed permissible shear force

12 Page Exceed permissible weight in one hold 38. Lack of adequate stability 39. Filling/emptying tank too quickly 40. Exceed permissible trim 41. Propeller not immersed 42. Insufficient forward draft causing slamming 43. Submerged LL 44. Sloshing in half full tanks 45. Global structural failure 46. Torsion stresses 47. Bad visibility 48. List angle 49. Loll 50. Insufficient manoeuvrability 51. Collision 52. Illness 53. Fire 54. Flooding 55. Grounding 56. Shell damage 57. Inadequate survey 58. Wrong material specification 59. Unsupervised maintenance 60. Contamination of BS by pollutant 61. Taking on board contaminated water as BW 62. Failure to adhere to BWM plan 63. Manhole cover removed 64. Error in strength calculation/verification 65. Unknown corrosion, reduced scantling 66. Wrong BWE plan on board 67. Outdated BWE plan on board (modification of ship) 68. Misjudgement of stability 69. Gauging system wrongly calibrated 70. Onboard computer failure 71. Lack of system understanding 72. Failure to monitor BW operation (HF) 73. Complacency 74. Communication failure 75. Common cause failure of S&P Ballast pump (e.g. flooding) 76. Vulnerable ballast pump location (e.g. in fore peak) 77. Inaccessible equipment 78. Wrong tagging of valves 79. Start wrong pump 80. Inadequate contingency planning 81. Inadequate/lack of recording of operation 82. Failure to monitor empty spaces 83. Pipe duct bilge alarm failure (or lack of) 84. Increased work load 85. Inadequate ventilation of pipe ducts (HF) 86. Ship not informed that ballast water exchange is necessary before leaving port

13 Page 9 9. LIST OF HAZARDS IDENTIFIED The hazards are structured into a logical sequence, starting with those which were initially expected to be the major ones, so that escalation of initial ones could be cross-referenced. Also, hazards were grouped together when similar, or could have been dealt with by similar risk control options. The numbering is sequential. The numbering is not related to the numbering in the previous paragraph. Hazard definition Inadequate ballast system design Fit for purpose in general, not for BWE at sea ID 1 Consequences Current safeguards Recommendations New building: Lack of experience at yard. Tradition. Lack of guidance or regulation. Poor design process and quality checking. Financial constraints. Design of existing ships may not be suited for BWE at sea. Pump system capacity too low. Inability to BWE efficiently. Special measures for flow through method. Inadequate monitoring and capacity of venting system to release liquid. Minimum vent sizes (Class). Minimum ballast tank capacity (Class/IMO). Class Rules specify minimum requirement if a ballast system is fitted, but do not have direct requirements for ballast systems. Class societies have slightly different Rules. Design criteria for ballast systems should consider BWE at sea FI Hazard definition Inadequate BWE plan BWE plan/sequence as part of loading manual will be developed by consultant or yard, for the owner, approved by Class. BWE plan will be referred to/included in BWM plan (See definitions above). Human errors, e.g. poor training, lack of knowledge. Communication errors, e.g. wrong data from designer/owner/consultant/yard/class Software error. Calculation error undetected. Lack of updating. Last minute completion of BWE plan. Consequences Unfavourable mass distribution (ID 5). Submerged load line (ID 6) Insufficient stability (ID 15) Current safeguards Class approval of BWE plan (Only for BC). Same approach as normal class approval of loading manual. ID FI 2 Recommendations Research into effects of BWE on structures and stability of ships should be continued

14 Page 10 Hazard definition Inadequate BWM plan ID 3 (See definitions above) Insufficient guidance. Lack of knowledge. Wrong information. FI Misinterpretation of the BWE plan by the BWM plan author. Consequences As ID 2 Procedural error in BWE (ID 9) Wrong BWE sequence used (ID 4) Current safeguards Existing guidance on BWM plan development. Will be audited in ISM audit. Recommendations IMO should develop guidelines for preparation of BWM plans, with due consideration of the human element. A ship s BWE plan should be harmonised with the BWM plan. Hazard definition Wrong BWE sequence used Most ships will have many BWE sequences (for different loading/ballasting conditions) Human errors, e.g. misjudgement of actual loading condition FI Consequences As ID 2. Current safeguards All BCs have loading instruments (UR S1). This could be used to simulate the BWE sequence for the actual loading condition prior to BWE. Recommendations Loading instruments should have automated BWE simulation capabilities. Deviating BWE sequences should be carefully checked against established limits. Hazard definition Unfavourable mass (e.g. ballast water) distribution during BWE ID Inadequate BWE plan (ID 2) FI Inadequate BWM plan (ID 3) Wrong BWE sequence used (ID 4) Failure of ballast system (ID 7) Inadequate planning of ballast operation (ID 8) Maloperation of ballast system (ID 9) Local structural damage (ID 13) Hull damage (ID 14) Ballast control system failure (ID 18) Gauging system failure (ID 20) Consequences Exceed permissible bending moment, shear force, torsion stress, weight in hold. Excessive trim (ID 16), propeller not immersed, insufficient forward draft. Structural failure (ID13) Hull damage (ID 14) Total loss Current safeguards Class Rules. BWE Plan Recommendations As ID 4. Hazard definition Immersion of load line during BWE ID As ID 5 FI Misjudgement of existing draft Consequences Progressive flooding. Structural failure (ID13) Hull damage (ID 14) Total loss Current safeguards Draft marks read in port Recommendations Means for measuring draft at sea may be necessary for BWE at sea ID 4 5 6

15 Page 11 Hazard definition Failure of ballast system ID 7 Failure or damage to pumps, valves, pipes, vent pipes, or suction FI blockage or inadequate location of suction and discharges. Inadequate strainers or filters in system, insufficient backup system. Consequences Inability to continue BWE. Increased duration of BW operation. Lack of ballasting capability. Unfavourable mass distribution (ID 5). Immersion of load line (ID 6). Current safeguards Design. Limited redundancy. Maintenance. Recommendations As ID 1. Ships should have maintenance schedule for ballast system. Ballast system should be surveyed. Ballast system should be performance tested. Hazard definition Inadequate planning of ballast operation (planning by crew ID 8 prior to BWE operations) Lack of training and knowledge, time pressure, insufficient crew FI availability (ID 26), complacency, procedural violation, failure to adhere to BWE plan. Inaccurate weather forecast. Consequences Inability to conduct safe BWE. Wrong BWE sequence used (ID 4). BWE sequence not followed. Unrealistic workload on crew. Unfavourable mass distribution (ID 5). Immersion of load line (ID 6) Failure of ballast system (ID 7). Local structural damage (ID 13). Insufficient stability (ID 15). Current safeguards Training, adequate ship specific BWM plan including BWE plan. Recommendations As ID 3. Training should emphasise hazards with BWE. Careful planning of manpower availability might be necessary. Hazard definition Maloperation of ballast system during BWE ID 9 Failure to follow BWE plan, failure to monitor BWE operation, FI poorly written BWE procedures. Maloperation of valve, wrong sequence of valve opening/closing, maloperation of closing devices (ballast system and cargo hold), wrong tagging of valves. Inadequate training (ID 31), insufficient crew availability (ID 26), time pressure, increased workload due to BWE, complacency, procedural violation, lack of system knowledge, communication error. Consequences Unfavourable mass distribution (ID 5). Immersion of load line (ID 6) Failure of ballast system (ID 7). Local structural damage (ID 13). Insufficient stability (ID 15) Current safeguards Training, adequate ship specific BWM plan including BWE plan. Acknowledgement of commands. Recommendations As ID 3 and 31. Valves should be clearly and accurately marked in the common working language of the crew. The BWM plan should include requirements for monitoring of the BWE operation. Procedures should be written in accordance with published guidance for HF (Reference: 1&2).

16 Page 12 Hazard definition BWE in unsuitable weather conditions Unsuitable weather for the ship takes into account the maximum allowable SWBM and sheer force Time pressure, lack of knowledge, misjudging the weather situation. Unpredicted change in weather. Increased duration of BW operation. ID FI 10 Consequences Hull damage (ID 14) Loss of watertight integrity (ID 27) Slamming (ID 11) Sloshing (ID 12) Current safeguards The master has discretion not to do BWE in bad weather. Permissible values for SWBM, SF and torsion. Recommendations It is a matter for consideration by IACS to decide if the permissible values of SWBM and SF for BWE could be increased above the allowable values while at sea due to the fact that BWE is only undertaken under favourable weather conditions. Hazard definition Slamming during BWE ID Rough sea and insufficient forward draft during BWE FI 11 Consequences Local structural damage in the forward region Current safeguards Recommendations Checked for minimum draft during design. Selection of course and speed during operation. BWE should only take place in an appropriate weather window Hazard definition Sloshing during BWE ID Partial filling of floodable cargo hold (or ballast tanks) and FI significant roll/pitch motion if BWE carried out in unsuitable weather. (Unsuitable is defined by wave period rather than wave height) Level in tank passes through barred filling range Consequences Local structural damage in hold (ID 13) 12 Current safeguards Checking of sloshing during design. Selection of course and speed during operation. Use flow through may avoid passing through barred filling ranges. Use suitable weather window. Internal structure of ballast tanks is generally considered adequate to withstand sloshing. Recommendations As ID 11. Sloshing should be considered an essential element of design loads for ballast water exchange.

17 Page 13 Hazard definition Consequences Current safeguards Recommendations Local structural damage in ballast tank or floodable hold during BWE Over/Under pressure and corrosion. Sloshing (ID 12). Poor maintenance. Gauging system failure (ID 20). Venting system failure (ID 19). Overloading of tanks. Undetected damage due to cargo operations. Undetected flooding, power failure due to flooding of machinery spaces, progressive structural failure. Unfavourable mass distribution (ID 5). Immersion of load line (ID 6) Insufficient stability (ID 15). Design, maintenance, inspection by crew, surveys, Class Rules. Corrosion protection. Adherence to BWE plan BWE (flow through) during icing situation should be avoided. ID FI 13 Hazard definition Hull damage during BWE ID Slamming, unfavourable mass distribution (see above) FI Collision due to reduced visibility and manoeuvrability Grounding due to BWE in shallow waters Consequences Flooding, power failure due to flooding of machinery spaces, progressive structural failure. Unfavourable mass distribution (ID 5). Immersion of load line (ID 6) Failure of ballast system (ID 7). Local structural damage (ID 13). Insufficient stability (ID 15). Current safeguards Design, maintenance, inspection by crew, surveys, class Rules. COLREG. Grounding is unlikely as BWE will be in deep sea. Recommendations 14 Hazard definition Insufficient stability during BWE ID 15 Loss of watertight integrity (ID 27) FI Hull damage (ID 14) Inadequate recognition of transient ballasting conditions (e.g. free surface effects, movement of VCG and mass). Failure to follow BWE plan. Misjudgement of stability margins. Adverse heel angle and loll. Icing on deck (flow through). Consequences As for excessive heel and loll (ID 17) Current safeguards Recognised stability margins. Adherence to BWE plan. Recommendations Stability margins should be developed that are relevant to BWE, considering relevant sea states.

18 Page 14 Hazard definition Excessive trim during BWE ID 16 Unfavourable mass distribution (ID 5) FI Icing on deck during flow through. Consequences Propeller emergence. Lack of visibility from the bridge, reduced manoeuvrability. Slamming. Loss of stability. Power failure. Inability of ballast system to operate. Inability to launch lifeboats. Other system failures. Current safeguards IMO resolution on bridge visibility. BWE plan and onboard monitoring of BW operation. Recommendations Class review of BWE plans should check systematically propeller emergence and visibility during BWE. See also ID 17. Hazard definition Excessive heel during BWE ID 17 Unfavourable mass distribution (ID 5) FI Insufficient stability (ID 15) Icing on deck during flow through. Consequences Capsize Ballast system failure (ID 7). Inability of ballast system to operate [inability to perform BWE by flow through method due to pump-head insufficient to pump when outlet is on high side.] Power failure Reduced manoeuvrability. Inability to launch lifeboat. Other system failures. Current safeguards Adequate ballast system design. BWE plan and onboard monitoring of BW operation. Recommendations Ballast system should be designed to enable ballasting operations to avoid causing excessive heel and free surfaces. Time for effective intervention must be allowed. BWE should be developed to avoid any appreciable heel. Hazard definition Ballast control system failure during BWE ID 18 Power failure, cable failure, component failure, computer failure (for automated), hydraulic system failure, pneumatic system failure, inadequate system/component design, system feedback FI failure, inadequate maintenance, inadequate training, maloperation. Inadequacy of the system fluid, including contamination. Consequences Inability to continue BWE. Increased duration of ballast operation. Uncontrolled ballasting (ID 32) Unfavourable mass distribution (ID 5) Immersion of load line (ID 6) Failure of ballast system (ID 7). Current safeguards Adequate design to suit BWE. Fail-safe philosophy used in some class Rules. Class requirement for secondary means to operate valves. Recommendations System design should consider BWE at sea. Minimum Requirements should be developed for safe operation, considering fail-safe requirements, system monitoring and alarms, backup, redundant system (no single critical failure), adequate filters and strainers.

19 Page 15 Hazard definition Tank venting system failure during BWE ID Obstructions, icing, debris, poor maintenance, inadequate design, FI maloperation, wave damage 19 Consequences Current safeguards Recommendations Tank over/under pressure. Tank structural failure (ID 13). Inability to ballast. Current (varying) class requirements. Inspection prior to start of BW operation. Class/statutory survey. Venting system should be suited for BWE at sea. Vent sizes should be designed for maximum pumping capacity from all pumps used during BWE. Harmonised guidelines should be developed. Design should account for the flow through method. Hazard definition Gauging (tank level) system failure during BWE ID 20 Includes operator error Poor maintenance, control system failure, component failure, FI power failure, weather damage. Inability to access gauging points due to weather, fire, excessive list. Inaccuracy of gauging in bad weather, wrong tank manually gauged, wrong manual reading or reporting. Excessive workload (ID 26) Consequences Lack of control of ballasting operation, e.g. unintended filling levels of tanks/hold. Over/under pressure. Current safeguards Training, inspection, experience, varying class rules. Recommendations Gauging system should be designed for BWE at sea. Automated/improved gauging system should be encouraged. Hazard definition Continuous use of pumps during BWE ID 21 Pumps not designed for BWE at sea FI Consequences Pump failure (ID 7). Early wear-out of pump. Lack of time to maintenance. Inadequate power balance may cause power failure. Fire in electricity supply. Current safeguards Over current protection for electrical pump. Temperature alarm on other pumps. Recommendations Pump system & supporting systems should be designed (or upgraded for existing vessels) for BWE at sea, providing adequate availability. Hazard definition Personal accidents due to BWE at sea ID BWE at sea may require visits to compartments and pipe ducts FI not normally used at sea. Inadequate ventilation. Inadequate accessibility of valves and other ballast system components Ice on deck, water on deck (flow through method). Tank gauging in bad weather. Increased workload (ID 26). Inefficient bilge system in ducts or other relevant compartments. Poor lighting. Poor monitoring of water levels or air in spaces not normally used. Consequences Injuries, reduced health, fatalities. Current safeguards IACS UR Z-12 for safe entry into confined spaces Recommendations Personal safety requirements should be developed for BWE at sea. 22

20 Page 16 Hazard definition Loading instrument (computer) inaccurate or inadequate for BWE ID Software error FI Consequences Wrong BWE sequence (see ID 2.) Current safeguards Review of loading instruments according to S1A. Recommendations Review of requirements for loading instruments should include BWE. Hazard definition Loading instrument failure during BWE ID Software error, power failure, excessive vibrations, unintended FI liquid ingress Consequences Wrong BWE sequence (see ID 2.) Current safeguards Environmental testing for single system or provision of backup system, varying class requirements for acceptance. Procedure for manual backup of computer. Recommendations Backup procedure should be available, and adequate training Hazard definition Inaccurate knowledge of cargo mass In a mixed loading condition, cargo mass is an input to the loading instrument for BWE Difficulty in estimating cargo mass. FI Consequences As ID 2. Less relevant for pure ballast conditions as ballast water mass is better known than cargo mass Current safeguards Routines used on board Recommendations Crew should be adequately trained for BWE, including knowledge of the inaccuracy in cargo mass estimation. Hazard definition Insufficient crew availability for BWE workload ID 26 Increased workload due to BWE FI Low manning Sickness Consequences Increased potential for human error. Increased time to carry out BWE. Reduced monitoring and recording capability. Inadequate planning. Current safeguards Minimum manning requirements. Decide not to BWE if insufficient crew. Recommendations Manning must be carefully planned considering BWE. Master decision must be respected. Hazard definition Loss of watertight integrity during BWE ID 27 Flooding through open manhole covers (flow through), FI open/closing devices. Consequences As ID 9. Personnel accidents (ID 22) Current safeguards Inspection. Procedures on board. Recommendations Procedures to prevent loss of watertight integrity should be part of BWM plan ID 25

21 Page 17 Hazard definition Fire on board during BWE ID Traditional causes. See also ID 21. FI Consequences Inability to complete BWE. Reduced strength due to fire damage. Reduced fire fighting capability if BWE is continued. Current safeguards Traditional safeguards Contingency planning (ID 29) Recommendations Fire drills should include BWE. Hazard definition Inadequate contingency planning for BWE ID Lack of manpower (ID 26). Lack of experience with BWE. Lack FI of awareness of hazards. Lack of training (ID 31). Consequences Inappropriate response making emergency worse. Lack of availability of adequate equipment, e.g. emergency lighting Current safeguards Limited coverage in available model BWM plans. Recommendations Proper coverage of contingency plans in BWM plan. Hazard definition Inadequate survey of BWE systems ID Current surveys do not address BWE FI Consequences Failure of ballast system during BWE. Current safeguards Inspected, but not considering BWE at sea Recommendations Surveys should be extended to cover BWE Hazard definition Inadequate training for BWE ID 31 Complacency due to familiarity with ballast operations in port. FI Lack of understanding of the hazards of BWE at sea. Consequences Inadequate planning of ballast operation (ID 8) Maloperation of ballast system (ID 9) BWE in unsuitable weather (ID 10) Wrong BWE sequence used (ID 4) Current safeguards ISM, STCW Recommendations IMO should require training consistent with other safety critical operations. Training must ensure adequate knowledge and understanding of the BWE operation, hazards and associated systems, and should specifically include training for contingency Hazard definition Uncontrolled ballasting during BWE operation ID 32 Inadequacy of tank/hold isolation, ingress of water [overboard FI discharges], in particular for flow through method. Human error. Component failure. Procedural violation. Unknown corrosion in scantling. Consequences Unfavourable mass distribution (ID 5) Submerged load line (ID 6) Insufficient stability (ID 15) Current safeguards Class Rules. Current BWE plan, if any. Recommendations Isolation valves should be fitted at tank and holds. Positive closing non-return valves at overboard discharge should be considered.

22 Page 18 Hazard definition Inaccessibility of components used for BWE ID Inadequate design for use at sea, poor lighting. Adverse weather. FI Consequences Poor maintenance. Inability to operate. Increased probability of error or procedural violation. Personnel accident (ID 22) Current safeguards ISM Code Recommendations As ID RANKING OF HAZARDS 10.1 Purpose This chapter provides notes for the risk ranking element of a Structured What-If Checklist (SWIFT) review of ballast water exchange (BWE) at sea Severity Index The following severity index was used: SEVETY EFFECTS ON HUMAN SAFETY EFFECTS ON SHIP S (fatalities) 1 Minor Single or minor injuries Local equipment damage Significant Multiple or severe injuries n-severe ship damage Severe Single fatality or multiple severe Severe casualty 1 injuries 4 Catastrophic Multiple fatalities Total loss Frequency Index The following frequency index was used: FI FREQUENCY DEFINITION F (per ship year) 7 Frequent Likely to occur once per month on one ship 10 5 Reasonably Likely to occur once per year in a fleet of several ships, i.e. 0.1 probable likely to occur several times during the ship s life 3 Remote Likely to occur once per year in a fleet of several tens of 10-3 ships, i.e. likely to occur in the total life of several similar ships 1 Extremely remote Likely to occur once in 10 years in the world fleet of several hundred ships By insisting to use a logarithmic scale the Risk index for ranking purposes may be calculated as = FI + E.g. An event rated remote (FI=3) with severity moderate (=2) would have = Risk Matrix The risk matrix (risk indices in bold) used therefore was:

23 Page 19 SEVETY () FI FREQUENCY Minor Moderate Serious Catastrophic 7 Frequent Reasonably probable Remote Extremely remote Risk reduction options affecting hazards with higher are considered most desirable Hazard Ranking All hazards were ranked individually by each member of the team (excluding the facilitator and recorder). An average risk index was estimated for each hazard. As the team felt that the risk ranking was uncertain and may be arbitrary, it was decided to present only the order of hazard rank without listing the rank index. Actual risk ranking should be presented after actual risk analysis (step 2 of FSA). The resulting ranking of hazards was (highest risk first): 29, 9, 31, 5, 2, 12, 1, 7,10,11, 13, 26, 17, 4, 8, 20, 15, 16, 21, 22, 19, 18, 27, 30, 3, 25, 33, 28, 14, 24, 32, 23, CONCLUONS 1. Ballast system needs more attention because of increased hazards during BWE at sea (With BWE at sea the ballast system is safety critical). 2. New Rules for Ballast system should be considered. 3. New Rules for survey of testing of ballast systems should be considered. 4. BWE should be addressed in IMO regulations (E.g. ISM, STCW). 5. Severity of hazards combined with frequency of operation suggest necessity for FSA for relevant risk control options. 6. Procedures, training, and planning for BWE should be consistent with other safety critical operations. 7. Design of ballast system and associated control and vent system should take account of BWE at sea. 8. Class rules should be assessed to establish the degree of coverage and improved where necessary.

24 Page Recognised safety margins should be verified for use during BWE allowing for actual weather conditions. 10. IMO should further develop BWM Model plans, including model plans for generic ship types. The ICS/INTERTANKO plan could be used as a starting point. 11. Loading instruments should be verified to become a safeguard during BWE. 12. The overall decision on BWM should take account of hazards to the ship, environmental drawbacks, as well as the environmental benefits. 13. Hazards of BWM may not be fully appreciated within the shipping industry as a whole. More education and awareness may be necessary. 14. Standard guidelines for the development of BWM/BWE should be developed. 15. It must be recognised that BWE at sea significantly increases the risk affecting BC operation. It is important to allow the master not to proceed with BWE in case of unfavourable weather conditions. 16. Existing safety measures and monitoring/safety systems/gauging on board should be reassessed to take into account additional hazards arising from BWE at sea. 17. BWE should not be allowed at sea unless a BWE plan has been developed based on verified, updated information and approved. 18. Class rules should be reviewed with regard to BWE at sea in terms of : Permissible strength limits; Sloshing loads and the unique aspects of the flow through method; and Explicit considering BWE by flow through method. 19. Hazards identified here are not unique to BCs and can apply to all ship types. However, other ship types will present hazards not present for BCs (e.g. related to stability). 20. The study should be extended to other bulk carriers and non-bc. 12. REFERENCES 1. Improving Compliance with safety procedures; reducing Industrial Violations, HFRG, HSE Book, 1995, ISBN Developing best operating procedures: Guide to designing good manuals and job aids. The SRD Associating, SRDA-R1, July Edited by A.S. Bardsley & A.M. Jenkins, SRD HF Dept. Prepared by Dr. A Shephard, Loughbourough University on behalf of SRD.

25 Page 21 Interim Guidelines for the Application of Formal Safety Assessment (FSA) to the IMO Rule-Making Process 13. SWIFT TEAM 13.1 SWIFT Meeting The hazard identification has been carried out in accordance with the IMO INTEM GUIDELINES FOR THE APPLICATION OF FORMAL SAFETY ASSESSMENT (FSA) TO THE IMO RULE MAKING PROCESS The team carried out the HAZID in a three day SWIFT meeting at the Det rske Veritas office in London October 6-8, The planning was carried out by the chairman and facilitator prior to the meeting. The BWE plan for the selected ship was distributed prior to the meeting. The members of SWIFT team were selected to represent all competence areas relevant to the hazards presented during ballast water exchange at sea. The members are: 1. Dr. R. Skjong, Det rske Veritas, Chairman/Reporting 2. Mr. J. Spouge, Det rske Veritas, Facilitator 3. Mr. M. Dogliani, NA, Hydrodynamic Loads (Participated day 1&2) 4. Mr. Segretain, Bureau Veritas, Structures 5. Mrs. A. Jost, Germanischer Lloyd, Stability 6. Mr. M. Mahmood, American Bureau of Shipping, Piping & Systems 7. Capt. G.J. Greensmith, Lloyd s Register, Operation 8. Mr. G. Hughes, Det rske Veritas, Human element 9. Mr. O. M. Nesvåg, Det rske Veritas, Machinery/Electrical Systems/Automation 13.2 Short CV's Dr. Rolf Skjong: Chief Scientist, Structures and Systems Reliability, DNV, Strategic Research Department. Experience: 15+ years in risk and reliability analysis, specialist in structural reliability theory, rwegian specialist in FSA at IMO/MSC (66, 67, 68, 69, 70), member of the IACS/AD HOC Group on FSA, rwegian specialist on FSA in the EU Concerted Action on FSEA. Team leader IACS/PT/HAZID/BWE, project manager and project responsible of a number of international joint industry projects, including structural reliability projects, for the ships, offshore, and process industries. Published about 50 papers in technical journals and conference proceedings. Mr. J. Spouge: Principal Engineer with DNV London Technical Consultancy. 12 years experience in quantitative risk assessment of shipping operations, offshore installations and road transport. Experience in leading and participating in SWIFT studies for tankers, passenger ferries, air traffic control and railway operations. Previously worked in ship safety research with the UK National Maritime Institute. Chartered Naval Architect; BSc in Ship Science from Southampton University, 1982.

26 Page 22 Mr. M.Dogliani: Naval Architect. Head of Scientific research Section at NA. 14 years experience on wave loading, stochastic processes, structural reliability. Experience in risk analysis (FMEA for HSC). Former member of IACS AHG/FSA. Chairman of IACS WP/HE. Mr. J.F.Segretain: Naval architect (hydrodynamics). Head of Development department (rules and technical software) in Bureau Veritas. 16 years of experience within BV for propulsive installations, hull drawings approval, classification rules and structural calculation tools. Bureau Veritas representative to IACS WP/S. Mrs. A. E. Jost: Dipl. Ing, Naval Architect. Expert on stability and Load Line matters at Germanischer Lloyd. Experience: 12 + years in approval of stability and load line related matters; German Expert in the Joint rth West European Research Project on Ro-Ro Ferry Safety; Chairman of IACS WP/SSLL. Member of IACS/PT/HAZID/BWE. Mr. M. Mahmood : Manager of Technology Development, American Bureau of Shipping Europe. Graduate of Surrey University in Mechanical Engineering. Prior to that he sailed on various types of merchant marine vessels up to the rank of Chief Engineer. Since graduating from Surrey, he worked with P&O as Senior Project Engineer on their new building program. He has been with ABS since 1975, in various capacities including Manager of the Engineering Services. He has been involved with the Offshore Safety Case regime and has participated in Hazop analysis for systems on offshore units and ships systems. Member of IACS/PT/HAZID/BWE. Capt. G.J. Greensmith: Senior Statutory Examiner in Lloyd s Registers, Marine Division, Tanker and Chemical Group. Holds a UK Deck Class 1 (Master Mariners) Certificate of Competence, 14 years in the UK Merchant Navy serving with major oil companies, 5 years in Senior Officers positions. 12 years with Lloyd s Register, involved in MARPOL and International Chemical and Gas Code statutory certification work including approval of operations manuals required by the conventions. Member of the IACS AHG BLG/WP and IACS/PT/HAZID/BWE, technical adviser at MEPC to a signatory delegation. Mr. G. Hughes: Gareth joined DNV in August 1997, as a senior engineer. He is currently responsible for the development of human factors business within DNV. Prior to joining DNV, Gareth spent eight years as a consultant with AEA Technology s human factors department. During this period Gareth developed his experience of using human reliability techniques for Safety and Reliability applications across a wide range of safety critical industries including; nuclear, transport, defence, chemical processing etc. Gareth has extensive knowledge of the application of task analysis and human reliability analysis techniques and participated, as an expert, in an HSE funded study to provide a comparison of their use. Gareth was more recently a member of the PT-HRA team who developed the method for the incorporation of the human element into FSA, and member of IACS PT/HAZID/BC. Gareth has an MBA from the Open University and a BSc in Ergonomics gained at Loughborough University. Mr. O.M. Nesvåg: M. Sc. in electrical engineering from the University of Trondheim, rway. Working area: Det rske Veritas, Division Technology and Products, Electrical Systems. Member of IACS/PT/HAZID/BWE. Four years experience.