RO- RO SAFETY PART 2

A further important point made by the

dNV study was that the

ro-ro ships most frequently

exposed to serious casualties and total losses were the pure

ro-ro and freight-only types. Pure

ro-ros

had a high percentage share of all casualties and especially of total losses. Passenger ferries, on the

other hand, had a fairly high percentage share of all categories but the serious casualty/total loss

frequency was relatively low.

The study also showed that the total loss rate for

ro-ros was significantly

lower

than the

average for the world fleet (under 0.25% over the 13-year period compared with about 0.55% for the

world fleet).

A quick look at some of the best-known accidents involving

ro-ro ships

also indicates some

of the major problem areas. Several of them involved water getting on to the vehicle deck through

the cargo doors, either as a result of a mistake or an accident.

The first

ro-ro ship to be lost at sea was the

Princess Victoria,

a rail ferry which sank on a

voyage to Belfast in 1953 when heavy seas stove in the stern door: 133 lives were lost. At least 264

people died in 1966 when the Greek ferry

Heraklion

sank in heavy seas on a voyage to Piraeus.

Although not a

ro-ro, the ship did have a large car deck without

subdivisional bulkheads. This deck

flooded when

the loading hatch was smashed by a vehicle which had broken loose. The cargo

ro-ro

Hero

was lost in 1977, partly as a result of water entering through a leaking stern door. In September

1994 the passenger

ro-ro

Estonia

was lost with more than 900 lives when

the bow door was torn off

by heavy seas. The car deck flooded and the ship capsized within a few minutes (see page 20).

These accidents happened in heavy seas, but other

ro-ros have been lost through water

entering doors in port or sheltered waters.

They include the

Straitsman

,

which sank when the stern

door was opened as the ship approached land, with the crew unaware that the door sill was below the

waterline: and the

Seaspeed

Dora

, which capsized in 1977 when a movement of cargo caused the

ship to list sufficiently for water to enter through an open bunkering door. In the case of the

Herald

of Free Enterprise

, water entered through the bow door which had been left open (see page 13).

Ro-

ro

ships which have sunk rapidly as a result of a collision have included the

Jolly

Azzurro

(1978),

Collo

(1980),

Tollan

(1980),

Sloman Ranger

(1980),

Ems

(1981),

European Gateway

(

1983)

and

Mont Louis

(1984).

Among

ships which have been lost following a shift of cargo are the

Espresso

Sardegna

(1973),

Zenobia

(1980) and

Mekhanik

Tarasov

(1982, in very bad weather).

How safe are ro-ros?

How safe are

ro-ros?

Because of the publicity surrounding accidents involving passenger

ro-ro ships such as the

Herald of

Free Enterprise, Scandinavian Star

and

Estonia

it is sometimes assumed that this type of ship is

much more dangerous

than others. This is not borne out by statistics. The World Casualty Statistics

for 1994 published by Lloyd's Register of Shipping show that passenger/

ro-

ro cargo loss rate per

thousand ships was 2.3 - the same as the average figure for all ships.

However, when one considers loss of life at sea the picture changes. Between 1989 and

1994, the Lloyd's Register figures show that 4,583 lives were lost in accidents at sea. Of these 1,544

were lost in accidents involving passenger/

ro-

ro cargo ships - exactly one third, even though

ro-ro

ships make up only a small fraction of world merchant marine tonnage. This would seem to indicate

that although passenger

ro-ro ships are involved in an

average number of accidents the

consequences of those accidents are usually far worse.

An important study concerning the safety of

ro-ro

ships (including cargo ships) was

submitted to IMO in 1983 by Norway. The study was compiled by the classification society

det

Norske

Veritas and covered the years 1965-1982. Of 341 casualties during the period, 217 were

defined as serious and 36 resulted in the total loss of the ship.

The study showed that the most common causes of serious casualties were collisions (24%);

machinery damage (17%): grounding (17%); shift of cargo and operational (16%); fire and explosion

(14%). The figures changed significantly when total losses were studied. Here the most common

cause was shift of cargo and operational faults (43%)

; collision (25%) and fire and explosion (18%).

The

dNV study showed that total losses as a result of a collision were much higher for

ro-ros

than for other ships (with only a 9% occurrence). Both collisions and uncontrolled shifts of cargo

more frequently led to serious consequences with

ro-ros.

The paper noted that more than 70% of all

ro-ro total losses due to collision resulted in loss

of lives while 60% of ships reported to have capsized or sunk following a collision did so in less than

ten minutes. Nearly all of the total losses involved ships of less than 110 metres in length.

RO-RO SHIP SAFETY

Focus on IMO

International Maritime Organization, 4 Albert Embankment, London SE1 7SR, United Kingdom

Tel: +44 (0)20 7735 7611 Fax: +44 (0)20 7587 3210

E-mail:

rkohn@imo.org

or

nbrown@imo.org

Web site:

www.imo.org

IMO and

ro-ro safety

The roll-on/roll-off ship 1

is one of the most successful types operating today. Its flexibility

,

ability to

integrate with other transport systems and speed of operation have made

it extremely popular on

many shipping routes.

The roll-on/roll-off ship is defined in the November 1995 amendments to Chapter II-1 of the

International Convention for the Safety of Life at Sea (SOLAS), 1974 as being "a passenger ship

with

ro-ro cargo spaces or special category spaces..."

One of the

ro-ro ship's most important roles is as a passenger/car ferry, particularly on short-

sea routes. But despite its commercial success, the

ro-ro concept has always had its critics. There

have been disturbing accidents involving different types of

ro-ro ship, the worst being the sudden

and catastrophic capsizing of the passenger/car ferry

Herald of Free Enterprise

in March 1987 and

the even more tragic loss of the

Estonia

in September 1994.

This

paper looks at the background of

ro-ros, the problems involved and the way in which

IMO has endeavoured to tackle them.

The development of

ro-ros

The modern roll-on/roll-off ship can trace its origins back more than one hundred years to the early

days of the steam train. Ships were specially designed to take trains across rivers which were too

wide for bridges: the ships were equipped with rails, and the trains simply rolled straight on to the

ship, which sailed across the river to another rail berth where the train would roll off again. An

example is the Firth of Forth ferry in

Scotland which began operations in 1851.

It was not until the Second World War, however, that the idea of applying the

ro-ro principle

of road transport became practicable - and was used in constructing the tank landing craft used at D-

Day and in other battles.

The principle was applied to merchant ships in the late 1940s and early

1950s. It proved to be extremely popular, especially on short-sea ferry routes, encouraged by

technical developments on land as well as sea, notably the increase in road transport.

 

 

 Until the early 1950s someone wishing to

take his car from one country to another by sea had to get it loaded into the ship's hold by crane, a

time-consuming and expensive process. The development of the

ro-ro car ferry changed all that and

many ports boomed as a result.

In the United Kingdom, Dover's first pair of drive-on berths was opened in 1953. Until then

the port had handled only 10,000 crane-loaded cars each year and forecasts that the berths would

enable the port to handle ten times that many must have seemed decidedly optimistic. But the

100,000 figure was exceeded in the first year and by 1985 Dover was handling over 2.5 million

vehicles and units through nine

ro-ro berths. By 1994 the total had risen to more than 4.5 million.

By 1994 around 4,600

ro-ro ships were in operation around the world: They are particularly

popular in Europe, and trading patterns reflect this.

Whereas pure container ships are to be found in

large numbers operating between Europe and North America, Europe and Japan and Japan and North

America,

ro-ros

operate primarily between Europe and North America and Europe and the Middle

East, although there is an important trade between North America and the Caribbean.

Today the world

ro-ro fleet can be subdivided into a number of different types. They include

ships designed to carry freight vehicles only; to carry a combination of containers and freight

vehicles

and to transport cars without passengers. There are various other types and freight-only

ro-

ro ships form about two thirds of the world

ro-ro fleet at present.

However, the

best known

ro-ro ships are ferries designed to transport commercial vehicles

and private cars, together with large numbers of passengers, usually on short voyages.

2002 passengership liability and compensation treaty

2002 passengership liability and

compensation treaty to enter into

force in 2014

The Athens Convention relating to the

Carriage of Passengers and their Luggage

by Sea, 2002, which substantially raises the                                                    

limits of liability for the death of, or personal

injury to, a passenger on a ship, is set to

enter into force on 23 April 2014, after the

required 10 ratifications were reached on 23

April 2013, with the ratification of the 2002

Athens Protocol by Belgium.

The 2002 Protocol to the Athens

Convention relating to the Carriage of

Passengers and their Luggage by Sea,

1974, (PAL), revises and updates the 1974

Convention, which established a regime of

liability for damage suffered by passengers

carried on a seagoing vessel. As a

precondition for joining, Parties to the 2002

Protocol are required to denounce the 1974

treaty and its earlier Protocols.

The Athens Convention declares a

carrier liable for damage suffered by a

passenger resulting from death, personal

injury or damage to luggage if the incident

causing the damage occurred in the course

of the carriage and was due to the fault or

neglect of the carrier. Such fault or neglect

is presumed, unless the contrary is proved,

Carriers can limit their liability unless they

acted with intent to cause such damage,

or recklessly and with knowledge that such

damage would probably result. For the

death of, or personal injury to, a passenger,

this limit of liability was set at 46,666 Special

Drawing Rights (SDR) per carriage in the

1974 convention.

The 2002 Protocol substantially raises

those limits to 250,000 SDR per passenger

on each distinct occasion unless the carrier

proves that the incident resulted from an

act of war, hostilities, civil war, insurrection

or a natural phenomenon of an exceptional,

inevitable and irresistible character; or was

wholly caused by an act or omission done

with the intent to cause the incident by a

third party.

If the loss exceeds this limit, the carrier is

further liable – up to a limit of 400,000 SDR

per passenger on each distinct occasion –                          

unless the carrier proves that the incident

which caused the loss occurred without the

fault or neglect of the carrier.

As far as loss of, or damage to, luggage

is concerned, the limit of the carrier’s liability

varies, depending on whether the loss

or damage occurred in respect of cabin

luggage, of a vehicle and/or luggage carried

in or on it, or in respect of other luggage.

•

The liability of the carrier for the loss of

or damage to cabin luggage is limited to

2,250 SDR per passenger, per carriage.

•

Liability of the carrier for the loss of or

damage to vehicles including all luggage

carried in or on the vehicle is limited

to12,700 SDR per vehicle, per carriage.

•

Liability of the carrier for the loss of or

damage to other luggage is limited to

3,375 SDR per passenger, per carriage.

The carrier and the passenger may agree

that the liability of the carrier shall be subject

to a deductible not exceeding 330 SDR in

the case of damage to a vehicle and not

exceeding 149 SDR per passenger in the

case of loss of or damage to other luggage,

such sum to be deducted from the loss or

damage.

The 2002 Athens Convention also

introduces compulsory insurance, as well

as mechanisms to assist passengers in

obtaining compensation, based on well-

accepted principles applied in existing

liability and compensation regimes dealin

with environmental pollution. These include

replacing the fault-based liability system with

a strict liability system for shipping-related

incidents, backed by the requirement that

the carrier take out compulsory insurance to

cover these potential claims.

Ships are to be issued with a certificate

attesting that insurance or other financial

security is in force and a model certificate is

attached to the Protocol in an Annex.

The limits contained in the Protocol set

a maximum limit, empowering – but not

obliging – national courts to compensate for

death, injury or damage up to these limits.

The Protocol also includes an “opt-out”

clause, enabling State Parties to retain

or introduce higher limits of liability (or

unlimited liability) in the case of carriers who

are subject to the jurisdiction of their courts.

The 2002 Protocol introduces a tacit

acceptance procedure for raising the

limits of liability, whereby a proposal to

amend the limits would be circulated on

the request of at least one-half of the

Parties to the Protocol, and adopted by a

two-thirds majority of the States Parties.

Amendments would then enter into force

within 36 months unless not less than one

fourth of the States Parties at the time of the

adoption informed that they did not accept

the amendment.

 

The 2002 PAL Protocol has now been

ratified by 10 States: Albania, Belgium,

Belize, Denmark, Latvia, Netherlands, Palau,

Saint Kitts and Nevis, Serbia and Syrian

Arab Republic. It has been also ratified by

the European Union.

The 1974 convention has been ratified

by 35 States

MARPOL Annex VI New regulations

MARPOL Annex VI
New regulations
Annex VI of MARPOL 73/78 "Regulations for the prevention of Air Pollution from ships" will enter
into force on 19 May 2005, and apply to all ships, fixed and floating drilling rigs and other platforms
of 400 gross tons and above. Such vessels are required to hold an International Air Pollution
Prevention Certificate (IAPP Certificate).

This certificate must be on board upon
delivery of newbuildings with keels laid after 19 May 2005. For other vessels, the
IAPP certificate must be on board at the
first scheduled drydocking after 19 May
2005,
 but not later than 19 May 2008.
Annex VI requires that every vessel for
which the regulation applies is subject to an initial survey as well as annual,
intermediate and renewal surveys.

Regulation 12 – Emissions from Ozone
Depleting Substances (ODS) from
refrigeration plants and fire fighting
equipment

Annex VI prohibits any deliberate emissions
of ODS (CFC’s, Halons, HCFC’s) as defined
in the 1987 Montreal Protocol. Minimal
releases in connection with recapture or
recycling are, however, permitted.
New installations containing ODS are
prohibited on all ships after 19 May 2005,
with the exception of those containing
Hydrochlorflouro-carbons (HCFCs),
such as R22. These are permitted until
1 January 2020.

The EIAPP certificate is issued for marine
diesel engines after demonstrating
compliance with NOx emission limits, as
per the NOx Technical Code issued by IMO.
All certified engines are to be provided with
an individual Technical File that contains
the engine’s specifications for compliance
with the NOx regulation and onboard
verification procedures. Further, each
engine is to be provided with a Record
Book of engine parameters, where any
changes to the engine are to be recorded.
The phrase "major conversion", means a
modification of an engine where:
• The engine is replaced by a new engine
built on or after 1 January 2000, or
• Any substantial modification is made to
the engine, or
• The maximum continuous rating of the
engine is increased by more than 10%
Note that for engines installed on keels laid
on or after 1 January 2000, a substantial
modification would be classed as any
modification outside the ranges specified
in the Technical File (see later description).
For engines installed on vessel keels laid
before 1 January 2000, a substantial
modification means any modification made
to an engine that increases its existing NOx
emission. These changes include, but are
not limited to, changes in its operation or
its technical parameters (e.g. to reduce
fuel consumption).
Regulation 14 – Sulphur Oxide (SOx)
emissions from ships
Upon entry into force of Annex VI to
MARPOL on the 19 May 2005, the
maximum sulphur content of marine fuel
oils used on board ships, regardless of
application, is 4.5%. Further, a limit of 1.5%
on the sulphur content of marine fuel oil,
applies in the following designated SOx
Emission Control Areas (SECAs):
• The Baltic Sea Area which enters into
force on 19 May 2006
• The North Sea Area and the English
Channel which will not enter into force
until 19 November 2007
An alternative to using marine fuel oil with
a 1.5% sulphur content in SECAs, is an
exhaust gas cleaning system or other
equivalent abatement technology. The
emission criteria for such systems are
6 g SOx/kWh.
Operational impact of low sulphur fuel
Fuel quality issues
There have been indications that low
sulphur fuel oil production may lead to
increased quality problems, such as
instability, incompatibility, ignition and
combustion difficulties, increase in levels
Designated SOx Emission Control Areas
Excessive sludging in fuel oil separator
of catalytic fines and the potential
introduction of chemical waste.
Fuel tank/system configuration
When approaching a SECA a change to
1.5% sulphur content fuel must be made
and recorded before entry into the area.
Given fuel compatibility problems, and in
consideration of the differences in cost,
some owners are considering installing an
additional set of service and settling tanks
for low sulphur fuel oils. Such measures
would also simplify change-over
procedures and bunker management.
Inadequate availability of low sulphur heavy
fuel oils may force owners to increase
consumption of low sulphur diesel oils
within SECAs. Accordingly, allocation of
additional marine diesel oil tank capacity
may have to be considered.
Lube oil considerations
Experience has indicated that for 2-stroke
engines, long term operation on blended
low sulphur fuel oils and the use of high
base number (BN 70) cylinder lube oils
may lead to deposit build-up on piston
crowns, piston ring grooves and,
subsequently, liner scuffing.
The maximum operation time on fuel oils
with low sulphur content and high BN lube
oils appears to vary substantially depending
on fuel quality, engine make, type, age, load
profile, liner temperature, efficiency of water
mist catchers, installation of scraper rings,
as well as cylinder lube oil quality, feed rate
and lubrication system. Accordingly, the
relevant engine manufacturer and lube oil
supplier should be consulted prior to
operation on low sulphur fuel oil.
Regulation 15 – Volatile Organic
Compounds (VOC) emissions from
cargo oil tanks in oil tankers
The requirements apply to tankers
operating in terminals that have been
designated by the Port state as an area
where VOC is regulated. The relevant
Port state is required to give advance
notification to IMO of such designations.
Any tanker that has a USCG compliant
vapour emission control system will
automatically comply with the IMO
requirements.
Regulation 16 – Emissions from
shipboard incinerators
Each incinerator installed on board on or
after 1 January 2000 is to be type approved
under the IMO Resolution MEPC 76(40).
The operation manual and the type
approval certificate for such incinerators
must be provided on board and the crew
trained and capable of operating the
incinerator in accordance with the manual.
Further, shipboard incineration of certain
specified substances (e.g. PCB’s) is
prohibited. Incineration of sewage sludge
and sludge oil is not permitted in boilers or
diesel engines inside ports, harbours and
estuaries.
Regulation 18 – Fuel oil quality
General points
Regulation 18 specifically requires that fuel
oil supplied to ships must be free from
inorganic acids or chemical wastes that
could jeopardise the safety of the ship, be
harmful to ships' personnel, or pollute the air.
Guidelines relating to Regulation 18 are
found in Resolution MEPC. 96(47)
"Guidelines for the sampling of fuel for
determination of compliance with Annex VI
of MARPOL 73/78".
Bunker delivery notes

Regulation 18 requires that any fuel oil
delivered on board must be recorded on
a Bunker Delivery Note (BDN).
There is a requirement that BDNs must
contain specific information, including
quantity, sulphur content and a declaration
by the fuel oil supplier's representative that
the fuel oil supplied conforms with
regulations 14 and 18.

The BDNs must be kept on board for a
three-year minimum and be ready for
inspection at all times.
MARPOL Annex VI fuel oil samples
Regulation 18 requires that every BDN is
to be accompanied by a representative
sample of the fuel oil delivered, taking into
account the guidelines in Resolution
MEPC.96(47).