Your Say provides our readers with the opportunity to air views on all the pertinent issues. Contact us at webeditor@lloydslist.com. All comments will be moderated.

Greece reiterates zero tolerance on substandard shipbuilding

SIR, With reference to the article in Lloyd’s List, April 22, 2008, “Napoli sparks boxship crackdown”, discussing the Marine Accident Investigation Branch report, Greek shipping has been publicly questioning shipbuilding practices for the last 16 years. It has supported in all fora that ships should be built robust and fit for purpose. This is particularly important in this era of changing weather conditions and larger ships.

We understand that from a series of 1,500 containerships of similar configuration that were examined after the issuance of the MAIB report that a further 12 appeared to have problems. We regret to note that a responsible classification society is quoted as saying that “the fact that only 12 of 1,500 ships indicated any problems show this was not an industry problem”.

We beg to disagree: shipping operates in a ‘zero tolerance’ environment, so the probability of losing one in 125 ships is not insignificant.

In 2002, Greece, together with The Bahamas, initiated the discussions on goal based standards in the International Maritime Organization to support improved ship design and construction, so that the international community would face up to its responsibilities and improve shipbuilding standards.

In light of the MAIB report we would expect that all governments will base the requirements of the goal based standards on sound engineering principles, avoiding shortcuts and generalisations that have led to discontinuities in hull structures, lack of proper design of load carrying members that result in cracks or buckling and other phenomena. Oversimplification in the use of design tools leads to results that do not reflect everyday situations on board ships.

Finally classification societies’ rules should close all loopholes that have been identified at great length by the Greek shipping community based on its wealth of experience, so that such accidents do not occur in future.

George A Gratsos
President
Hellenic Chamber of Shipping


Remember: no ship is unbreakable

SIR, Comforting as it may be to read the assurances by the classification societies, in the wake of the superb MAIB report on the loss of MSC Napoli (Lloyd’s List Wednesday April 23), that containerships are “structurally safe”, there are many other aspects of that report that must give rise to grave concern.

As an ex-shipmaster, chief marine superintendent and containership manager, I find it almost incredible that, despite the implicit instructions from the company in respect of speed in heavy weather, the master of this 16-year-old vessel elected to attempt to maintain 17 knots (and this with a defective engine governor) when heading into the high seas generated by storm force winds.

His log book entries make reference to “vessel pounding heavily at times”, witnesses refer to “quite powerful strikes”, crew members speak of “difficulty in standing” and the report stresses that these were not “rogue waves”.

The key finding in the investigation is contained in the synopsis that “the ship’s speed was not reduced sufficiently in the heavy seas”, and there can be little doubt that had the master given more thought to the possibility of severe damage to the vessel’s structure and engines (and to the risk to the lives of the crew) and rather less to the wellbeing of the forward containers (and his schedule), then MSC Napoli would still be trading today.

But then, one reads in an earlier 2007 report that “while key industry players will attest that safety is of paramount concern, evidence obtained during this and other MAIB investigations into container shipping accidents suggests that, in reality, the safety of ships, crews and the environment is being compromised by the overriding desire to maintain established schedules or optimise port turn around times”.

So should we be critical of the master of a ship that is already running some six days behind schedule?

The MSC Napoli report hits equally hard by commenting that “speed and quick turnarounds appear to have become the focus of the industry at the expense of the safe operation of its vessels” and, more pertinently, “keep the ship’s speed as fast as possible when pounding into heavy seas [and are] symptomatic of the industry’s ethos to carry as much as possible as quickly as possible”.

But the ultimate truism is that no ship is unbreakable. “Classification societies apply structural strength limitations which are contingent on the application of good seamanship and prudent operational practice. It has been apparent during the course of this investigation that these caveats are not widely recognised by many in the containership industry,” the report concluded.

We can but hope that the authors of the pending Code of Practice for the container trade will read this report in detail — and be guided accordingly.

Captain C R Kelso
5 Bursledon Heights
Southampton SO31 8DB


ACP has Panama jam under control

SIR, I wish to comment on the article ‘Panama battles to clear canal bottleneck’ (Lloyd’s List, April 18).

You claim that “the Panama Canal is struggling to control major congestion” and that “local agents have suggested that an industrial dispute between the canal authority and pilots that help ships transit the canal may be responsible”.

The fact is that this time of the year is always a high season for the canal where there are more ships than usual going through the waterway. To suggest that this is otherwise is pure speculation.

The Panama Canal Authority and its pilots are working together to continue to provide a safe, efficient and reliable service to our clients and their performance continues to be of the highest degree.

The backlog, which occurred during the second half of February, was due to a surge in arrivals within the waterway’s peak season (February-May) that happened to coincide with maintenance work being carried out at the Pedro Miguel and Miraflores Locks.

The ACP is concerned about the situation and is working assiduously to reduce the backlog. Every measure taken by the ACP to date, including the reduction of booking slots, the addition of more equipment and personnel and the postponement of non-critical maintenance work, has allowed us to be more responsive to our customers’ needs.

We have seen a downward trend in waiting times and we expect to see an even more pronounced reduction for transits in the weeks to come.

Teresa Arosemena
International Communications
Panama Canal Authority


When Cold War authorities offered a warmer welcome to seafarers 

A LONG time ago I arrived with a coaster in Wismar, in that time still in the former German Democratic Republic.

When the gangway was ashore and the pilot disembarked, I walked behind him to take the drafts, as was my usual task as second mate. At the bottom of the gangway I looked in the barrel of a gun and decided to wait until I had a shore pass and all formalities were done.

A number of vessels from companies I sailed with went to ports behind iron and bamboo curtains and the stories of the crews were all similar: a strict system with shore passes and shore leave only for the seaman’s club.

When you were found on a stroll somewhere, a black car stopped next to you and asked where to bring you: to the seaman’s club or to the ship.

We saw this as a sure sign that freedom in these countries was severely restricted and we were happy that we lived on the right side of the fence.

Now there are many places where you don’t even come near a seaman’s club, where trespassing as I did might cost you a $10,000 fine and maybe even your career, as you are not allowed to come back in the country for some years.

I am now a pilot and I am ashamed to say that even in my own country there is very little concern for seamen. I was ordered to a Russian reefer somewhere between Christmas and New Year 2006. On board I heard that the gate had closed on the Friday afternoon before Christmas and had opened again on the Wednesday morning after.

Fortunately, the crew had not received any wages over the past months, so it didn’t matter that much, they had nothing to spend anyway. Who wonders why retention of seafarers is a problem?

The iron curtain has fallen, but to me there is no doubt on which side seamen have ended up: the wrong side.

In the name of freedom, and especially in countries which say that they defend freedom, freedom for seamen is much more restricted then it ever was under regardless which communist rule. Or to say it bluntly: the modern US and some countries in western Europe offer less freedom to seamen than the USSR or mainland China did during the Cold War.

Ed Verbeek
Van den Vondellaan 25
1985BA Driehuis
The Netherlands


Left high and dry at dock 

SIR, While agreeing whole-heartedly with Werner Lueken (Lloyd’s List April 15) about the welcome trend to treat yards as a vital part of the supply chain rather than a last resort, I should like to question some of his statistics.

If he is right to estimate the total merchant fleet at about 100,000 ships, then surely we need to replace them much faster than 2% per annum? Otherwise, he is implying that their average life expectancy is 50 years? He also states that the average ship will dock only once every four years. Is this right?

On page seven of the same issue, you report that DNV believe that the demand for drydocks by 2011 will be 50% greater than it was in 2004 and that the main demand for repair and conversion services, at least of big ships, will be in South east Asia.

Certainly my recent experience is that docks and repair services are already becoming far harder and more costly to secure than they were comparatively recently.

Geoffry Lucas
Shipbroker
London SW3 


Did strait talking end piracy? 

SIR, The front page on April 15 announced that there were no piracy incidents recorded in the Malacca Strait during 2007. I don’t remember the relevant dates, but I wonder to what degree this was a direct result of Lloyd’s Insurance market imposing a war premium on vessels passing through the strait, thus finally concentrating the minds of the littoral states into concrete preventative measures?

Sean Gay
Antrak Group
Marc House
13/14 Great Saint Thomas Apostle
London
EC4V 2BB


Repair yards’ capacity crisis is unjustified

SIR, Repair and conversion yards in Europe are as busy as they have been for the last 25 or 30 years, and we know that the picture is more or less the same world wide.

What we have today is a boom market in which yards and owners in partnership should be looking for ways to meet the need for ever-higher standards of cost-effective repair and maintenance.

Long newbuild orderbooks produce two side effects for the repair and conversion yards. One is that the demand for conversions increases as owners seek to convert rather than wait five years or more for a newbuild.

Second, not only will some of the capacity that might have been used for general ship repair be devoted to that conversion work, but there may also be some diversion of capacity from repair work to newbuild.

Even allowing for these two points,in my view it is not correct to suggestthat the progressive delivery of thecurrent newbuild orderbook to theworld fleet will generate a repair capacity crisis.

Just consider the numbers. Shipyards delivered about 2,000 ships in 2007. If you take the broadest definition of the global merchant fleet, it consists of just under 100,000 ships.

With scrapping rates so low as to be disregarded, assume the growth of the fleet is 2% per annum in terms of ship numbers. Ships will dock on average once in four years, which means that demand is for 25,000 dockings each year globally, and the rate of growth in the fleet will generate another 500 dockings each year until the order backlog is cleared.

If you make some allowance for productivity improvements in the repair and conversion sector — and all the companies I know about are improving productivity at more than 2% per annum — then I simply do not see how the claim of a capacity crisis can be justified.

Analysing the market at its most recent meeting in early March, the CESA Ship Maintenance, Repair and Conversion Group view was that there has been no fundamental change in the decision-making process of owners about where to award a repair job. Rather, the elements in the decision-making equation now produce an answer that favours ships that start or end a trading journey in Europe making repairs in Europe.

Quoted cost of the repair, plus length of time of hire in the yard, plus the cost of diversion are the principal elements in the decision equation. In short, for as long as freight rates remain high, and while fuel remains expensive, the picture looks good for European shiprepairers.

Group members notice that, in the last couple of years, they are being asked to do more work on each ship that they dock. It seems that there is a certain amount of catching up on repair and maintenance work deferred from years when freight rates were not as high as they now are. However, this will not continue indefinitely.

In the SMRC group, we hear of growing numbers of owners who, instead of regarding a repair yard as a place of last resort, are instead working in partnership with yards to schedule maintenance and repair dockings. This seems to us to be a far more sensible approach based on the constructive involvement of a vital service industry as part of the shipowners’ supply chain, which is what repair and conversion yards actually are.

From the yards’ perspective, there is no capacity crisis, just a situation that encourages and rewards owners for dealing with repair yards in a more constructive, less adversarial way than they might have done in the past.

Werner Lüken, (Lloydwerft), 
Chairman, CESA Ship Maintenance, Repair and Conversion Group
Brückenstrasse 25
27568 Bremerhaven


Marpol Annex VI revision not a ‘knee-jerk reaction’ 

SIR, I was most concerned to read the leader, ‘Show us the proof’ (Lloyd’s List, April 11). In no sense can the International Maritime Organization decision on the revision of Marpol Annex VI be described as a “knee-jerk reaction”. The process of revising Annex VI started immediately the existing Annex achieved its ratification criteria for entry into force.

While most involved in the process had understood for a long time the controls on air emissions did not reflect the expectations of society, or indeed the aspirations of the industry, they could not for legal reasons be changed until sufficient states had ratified the agreement reached back in 1997.

Having agreed to start the review, IMO embarked on a programme that was both transparent and exhaustive. It will be recalled that most people (including this newspaper) welcomed the IMO secretary-general’s decision to convene the ‘Scientific Group’ on the implications of options under consideration and the findings of that group played a pivotal role in ensuring that the new requirements are deliverable.

The draft text agreed unanimously at IMO last week is certainly welcomed by the International Chamber of Shipping. This text reflects the convergence of a number of long-held and fiercely-argued positions; that it should be so widely accepted is a remarkable international achievement.

From the opening of the review process, ICS argued for principles that included a goal-based approach to deliver short-term and long-term solutions to meet environmental concerns and so that the industry could plan for known targets. ICS also argued for the concerns of the refining and bunker industries to be heard in support of a deliverable solution.

Representatives of the refiners consistently talked about a seven- to 10-year lead time to develop the capability to deliver lower sulphur fuel in sufficient quantity. The lowering of the Seca [sulphur emission control area] cap in 2015 and of the global cap in 2020 (subject to a review of fuel availability) provides the certainty that the oil industry sought.

ICS has always argued that whatever the solution, there is a need to not only allow, but to positively encourage, innovation so that future ships can take advantage of technological development without the need to revisit the regulation with a further review. This aspect is also built into the agreed text.

ICS has a global view that is informed by its international and cross-sectoral membership. It was around this foundation of realistic and practical analysis that the ICS principles were built and this was recognised throughout the debate. It is our view that the IMO outcome is not only deliverable but it also provides the environmental protection that was sought and positions the shipping industry on a well-founded platform for the future.

Peter Hinchliffe
Marine director
International Chamber of Shipping
12 Carthusian Street, London EC1M 6EZ


Masters and pilots must communicate

SIR, I read Michael Grey’s article (Viewpoint, February 25) with great interest. As a Rotterdam pilot I can understand his point of view.

In my experience, the master/pilot relationship is open for interpretation. Where some masters/pilots like to know everything and believe sharing information is normal, others are completely the opposite. It comes down to explaining what your intentions (as a pilot) are and doing what you say; not doing what you think has to be done (as a pilot) and then explaining your actions.

Masters and the bridge team should shape up and start to assist and control pilots.

In real life, tools for this kind of communication are not available. Pilots and masters are always working individually. They develop, on their own, some kind of communication and sharing of information. Each has their own priority list which they do not share.

Training and shared vocabulary are not really available and are underestimated. How, then, can they truly communicate? Why do we not develop an international standard that is realistic and workable with a shared terminology? In other industries this is possible, so why not in shipping?

Margriet J Torpstra
Johanna Naberkade 60
3137 TN Vlaardingen
The Netherlands


Shipping industry regulation must be on international basis 

SIR, Denmark is deeply committed to the objective of ensuring the highest possible levels of quality shipping, safety at sea and environmental protection.

A way to achieve this is through global regulation, which is a cornerstone of Denmark’s shipping policy. Shipping is an industry that operates on a global level, which is why it must also be regulated on an international basis.

That being said, Denmark of course supports European legislation that enhances maritime safety. Denmark therefore hopes that the first five proposals in the third maritime safety package are implemented as quickly as possible.

At a European Union meeting yesterday, 27 transport ministers discussed the remaining two proposals by the European Commission on flag state requirements and on shipowners’ civil liability. I do not believe that these directives will lead to the intended results. I find that these proposals are the “wrong medicine”, as the problems they seek to address are those which are neither confined to, nor significant within, Europe.

As minister for Danish shipping, my primary concern is that Danish shipping can prosper. But Danish shipping can only prosper with a well-functioning, global and universally applicable, regulatory framework. This is to ensure a high level of safety, security and environmental protection as well as a well-working liability and compensation regime. I believe that the two proposals may work contrary to the international regulation and merely create new administrative burdens for the European shipping industry and administrations alike. I do not see the necessary added value in the proposals. Therefore, such regionalism is not justified. It is simply not in line with the EU´s better regulation agenda.

Given the international nature of shipping, the problems that haunt the industry are mostly global. It is therefore often futile to try to combat a global problem with regional measures. Regional measures lack the scope of international measures. Compared to unilateral and regional regulation, the International Maritime Organization’s regulation has the benefit of applying to all ships, no matter where in the world they operate.

When we decide to regulate shipping, we must ensure that the regulations are effective and easy to implement.

I believe that the IMO time and again has shown that value is added by achieving global solutions. Examples of this are the Voluntary Member State Audit Scheme; the International Ship and Port Facility Security Code and the introduction of double-hulls, among others. One of the strengths of the IMO is the technical knowledge that individual member states bring to the IMO. This ensures sound solutions to the benefit of the shipping industry at large. We need solid, sound and long-term solutions.

Instead of creating a patchwork of regional regulation we should support the work done at an international level. For example, the member states and the commission could join forces to make the IMO Voluntary Member State Audit Scheme mandatory and further encourage the ratification of the international conventions by all states.

The IMO has, in the past, in many ways demonstrated the requisite leadership to handle the problems that global shipping is faced with. That is why my commitment on behalf of Danish shipping to global regulation is as firm as ever.

Bendt Bendtsen
Minister for Economic and Business Affairs
Denmark


Turkey takes the lead on European ship recycling initiatives

SIR, I refer to Aline De Bievre’s Quarterpoints article on IMO’s ship recycling Convention (Lloyd’s List, March 5, 2008) and particularly to the “…encouraging signs that critically important countries such as India and China are keen to sign up to the agreement”.

At this point one should also mention Turkey, which provides a reliable and environmentally responsible solution to ship recycling. Turkey has significant ship recycling capacity, being among the top five world recycling centres. 

Turkey’s proximity to Europe and its location in the Mediterranean and Black Sea, North of Suez canal, presents an ideal destination for recycling ships under a controlled and internationally regulated regime. A recent report by the European Commission’s Environment Directorate-General has identified that “up to 1m ldt/year safe and environmentally sound recycling capacity can be generated in Turkey”.

Similar views have been expressed by the French Inter-departmental Committee on Dismantling of ships — and other EU member countries — who stated that “thanks to [Turkey’s] collaboration with Western countries, especially Germany, some yards [in Turkey] have achieved significant improvements and now meet the Western management standards”.

Turkey is a country that actively participates in the drafting of IMO’s convention, has developed a ship recycling industry that meets or exceeds the proposed standards and procedures with members holding ISO 9001, ISO 14001 and OHSAS 18001 certification.

In this sense Turkey is also critically important particularly as is expected to be among the leading countries to enforce IMO’s Ship Recycling Convention.

D Ayvatoglu

On behalf of Ship Recyclers’ Association of Turkey


Irish lights subsidy must be abolished

SIR, The European RoRo Carriers’ Action Group — EUROCAG — has noticed with great concern your article on Tuesday March 4 (‘Lines fail to make UK see the light over dues rate’).

We have had discussions and communications on the issues of light dues in general and the so-called Irish lights subsidy for some time with both Dr Ladyman and now with Mr Fitzpatrick. We felt that, at last, a common sense approach was being applied to the issue of the Irish lights subsidy. We now learn that this is not to be the case.

Whether there should be any UK light dues charges is one issue that still needs to be addressed, but the fact of the matter is that today the subsidy to Irish lights is inflating the real cost of light dues to UK port users.

We have not received any tangible reason from the UK government as to why the Irish lights subsidy is still ongoing.

Firstly we fail to understand why Irish lights feel the need to be subsidised by the UK, when a more appropriate instrument should be by one of the various funding arrangements that is sponsored by the European Commission, if subsidies are indeed required.

Secondly we fail to understand why the UK government should see fit to take the subsidy from a fund that is supposed to be 100% self-supporting and where its monies are collected solely from those using UK ports.

Any excessive port cost is a financial burden to shortsea shipping operators and every effort, as requested by the European Commission and the European Parliament, should be made to reduce overall operational costs to maintain and also increase the competitiveness of shortsea shipping so as to be able to remain a viable alternative to road transport.

Bearing in mind that apparently the European Commission last year urged the UK government to speed up discussions with its Irish counterpart, we once more call upon the UK government to immediately enter into dialogue with all relevant parties with a view to swiftly ending the subsidy to Irish lights. This will put the government in a position to reduce light dues in the short term, while discussions on the abolition of the charging of UK light dues to UK port users are ongoing.

James W Dempster
Executive Director 
European RoRo Carriers’ Action Group
Rue Ducale 67 bte 2 1000 
Brussels, Belgium


Some practical advice on better ISM Code compliance 

SIR, With reference to your recent article on the ISM Code (“Throwing a lifeline to ship safety”), your readers may wish to know that, for some time now, the International Maritime Organization has been engaged in a multifaceted review of the code aimed at ensuring its improved implementation and enforcement by governments and industry.

The process began in 2004 when we established a group of independent experts (selected from among administrations, organisations, academia and the shipping industry) to carry out a study on the impact and effectiveness of the ISM Code. The group met on three occasions and, with support from the IMO Secretariat and the World Maritime University, analysed data collected from a wide cross-section of stakeholders, including sea-farers and ships’ masters, shore-based personnel, shipping companies and administrations.

It arrived at the overall conclusion that, where the ISM Code had been embraced as a positive step toward efficiency through a safety culture, tangible positive benefits had been evident. The group also concluded, on the basis of feedback, particularly from seafarers, that ISM Code compliance could be made easier by reducing the administrative process. The group also made several practical recommendations which, to date, have resulted in the following further action by the IMO:

• contemplated amendments to the ISM Code relating to requirements for seafarer safety representation — these are being prepared by a human element working group;

• further revision of the Revised Guidelines on implementation of the ISM Code by administrations — the aforementioned working group is also looking into this;

• adoption of guidelines for the operational implementation of the ISM Code by companies — the first-ever guidance issued to companies on this subject; and

• adoption of guidance on qualifications, training and experience necessary for undertaking the role of the Designated Person under the provisions of the ISM Code.

As part of our work on the harmonisation of port state control activities, we will review the reports of the Paris and Tokyo MoUs on their recently concluded concentrated inspection campaigns on the ISM Code, once they are made available to us. We expect that these reports will shed light on issues related to the effective implementation of the code and will be considered by the IMO’s technical bodies, together with the outcomes of any marine accident and incident investigations that may relate to the code.

Should, from the examination of these and other material, the need emerge for further revision of the code or that additional guidance is required, appropriate action will be taken and carried out expeditiously (as evidenced by the measures taken, following the report of the group of independent experts) to improve further global, uniform and effective implementation and enforcement of the ISM Code.

The code is significantly important to us all in our efforts to enhance safety at sea and marine environmental protection, and we are determined to continue improving it in the light of experience gained in its implementation thus far and in the future.

Efthimios Mitropoulos
IMO secretary-general 


Act now to curtail the crewing crisis

SIR, “All progress wiped out in one brief party of booming market urgency and outright negligence towards safety standards”: undoubtedly, Richard Meade gets it right in An unwelcome eighties revival (Lloyd’s List, February 26, 2008).

The complacency abounding in much of the maritime industry in relation to the steadily worsening crewing/competency crisis is almost certainly based on the hope (or even belief) that, come what may, many regulatory bodies (with the probable exception of the USCG) will be “understanding” in light of “the short supply of quality crew, the increasingly difficult retention problems [and] faster promotion” and are unlikely to take any action liable to disrupt today’s frenetic but highly profitable global trade — irrespective of the steady increase in accidents caused by human error.

Predictably, some sectors of the industry belatedly responded to the crisis by throwing money at it — something they will have to continue to do on a regular basis for the foreseeable future.

In the short-term, this may help recruitment and, to a lesser degree, retention. But it will not solve the problem.

In October 2006, the then Transport Minister Stephen Ladyman, at a meeting of The Mission to Seafarers, waxed eloquently about the “welfare charter: a charter setting international standards for the conditions in which seafarers work, and, in many cases, also live”.

He went on to say that “realistically” ratification would take “four to five years” and, more recently, his ‘successor’, Mr Fitz-patrick, opined that the aim was to ratify in 2010 “or earlier, if possible”. Neither mentioned that, after ratification, implementation could take a further 12 months.

The ILO Consolidated Maritime Convention (the culmination of five years of discussion) will consolidate and update all existing maritime labour standards and will go far towards affording seafarers worldwide the terms and conditions of employment they have been denied for so many years — the principal cause of today’s crewing and competence crises.

Someone, somewhere should seek out the Maritime Labour Convention, dust it off and promote its speedy ratification and implementation, in its entirety. Although not a panacea, it might just form a basis for recovery.

The full impact of the crewing and competency crises has yet to take its toll of the industry (and recovery will be tortuous), so time is of the essence — 2011 will be much too late.

Captain CR 
Kelso,5 Bursledon Heights, 
Bursledon, Southampton 
SO31 8DB

Save the planet: send world trade by air?

Readers of Wednesday’s Guardian newspaper front page (‘True scale of CO©ü emissions from shipping revealed’) would be forgiven for thinking that shipping is inefficient in terms of CO©ü emissions and should clearly be targeted in efforts to reduce greenhouse gas emissions.

Even aviation is only “responsible for about 650m tonnes of CO©ü emissions a year, just over half that from shipping.” Perhaps we should park all the ships and send the trade by air?

That would be a catastrophe for the environment — as well as a physical impossibility. Air freight produces 100 times as much CO©ü per tonne kilometre. Such a move would quadruple total man-made CO©ü emissions. This is a measure of the carbon-friendly nature of the shipping industry — although the industry is far from complacent and continues to work to reduce CO©ü output.

Previous studies — including the universally acclaimed Stern Report — have suggested that shipping is responsible for between 2%-4% of total man-made CO©ü emissions. The claim that the 4.5% figure is “three times higher than previously thought” is strange. Certainly the shipping industry itself has long recognised the difficulty in obtaining an exact figure on CO©ü emissions due to its complex and global nature. The figures in the report submitted to the International Maritime Organization make a valuable contribution to the development of a baseline figure on which to assess industry efforts to reduce CO©ü emissions as far and as fast as possible.

The real focus of the IMO report however, was the reduction of air pollution from ships (CO©ü is not classed as a pollutant but as a greenhouse gas). The report itself was not concerned with carbon emissions per se, except in terms of assessment of whether efforts to reduce air pollution from ships may actually raise their carbon footprint.

It is a pity that the Guardian missed the main thrust of the report — the impact of practical options to reduce emissions of air pollutants (sulphur oxides and particulate matter) from ships. The report made a major contribution to the revision of air emission legislation by the IMO last week. This should see a considerable lowering of global emissions of air pollutants in force world-wide by 2009. This is good news for the environment and for the health of those people affected by these emissions and industry was proud to have contributed positively and substantively to the debate.

Mark Brownrigg,

Director-General of the Chamber of Shipping

 
Strange way to show appreciation 

SIR, I was interested to read your article ‘Policy shifts threaten stability of UK shipping’. Further, and perhaps of most interest, was the statement by the Shipping Minister Jim Fitzpatrick that “this industry’s contribution to the UK’s economy, our productivity and our competitiveness on a global scale, is well appreciated across government.”

This statement is at odds with my experience.

Having sent an email on the January 8 to the Prime Minister, Treasury, Mr Fitzpatrick and George Osborne which, to summarise, stated:

“... It will not be the Greek shipping community who pay this tax but the Treasury who will pick up the bill for the resultant unemployment caused by the closing or reduction of staff in many ship-owning agencies, broking, insurance, banking and legal firms.

“The departure of the London Greek will be driven by the extended family/support community, it is they who will leave. The uncle, the niece, the Greek engineer/accountant — they do not need to pay this tax. With the extended family and fellow Greek compatriots leaving it will not be long before the actual owner decides to depart as the infrastructure disintegrates.

“As Mr Embiricos, the chairman of the GSCC, eluded to in an article in Lloyds List on January 4, 2008, “there will be a drip-drip Greek desertion from London”.

“As to what is being put at jeopardy [this] was clearly stated by the International Financial Services, London:

“...Overall the sector is estimated to have contributed £1.5bn [$2.9bn] to the UK economy in 2006, with the ship-broking sector accounting for about half of the sector with overseas earnings of £706m.

“Maritime banking is estimated to be worth £240m. Maritime services contribute to the UK economy through the employment of 14,300 people.”

I received no acknowledgement or comment from the Treasury but Mr Fitzpatrick’s department replied: “Unfortunately, the Department for Transport does not have responsibility for the issue raised in your email.”

The implication is that the non-domicile taxation issue is of no consequence and will not affect the Department of Transport’s forward thinking or planning in relation to shipping.

I can only assume the minister will rubber stamp whatever the Treasury wants and therefore avoid upsetting the Prime Minister.

For me, in the twilight of my career, this may not be a major issue (I’ve seen the almost total demise of the British ship-owner and shipbuilding industry) but for the future young men and women and those who are currently employed in the many aspects of this diversely interesting industry, this ill-conceived tax will turn out to be very short sighted and the beginning of the end for many a career here in London.

Meanwhile the other major shipping centres around the world are rubbing their hands with glee at the intended absurdity of this proposed legislation.

The Greek Shipping Minister George Voulgarakis warned “that the new UK tax proposals may cost London more in lost business than the Exchequer is likely to gain”.

I couldn’t have put it better myself but I doubt somehow Mr Voulgarakis will be presenting his concerns in a formal submission to the Treasury.

MJ Thomason


We should have learned from Kodima

SIR, Peter Cardy quite properly responded to the comments regarding scavenging of flotsam after the MSC Napoli beaching, and the lessons learned and subsequently applied to the Ice Prince sinking.
What is forgotten is that the stranding of the Kodima off southeast Cornwall in 2002, and the subsequent scavenging of its timber deck cargo, provided all concerned with sufficient knowledge and experience to apply to the Napoli incident. The frenzied looting on Branscome Beach could have been avoided.

Devon County Council plans to hold a public enquiry into the MSC Napoli incident, I trust those involved with Kodima will be asked to participate.

Tim Charlesworth 
Chief executive and harbour master 
Cattewater Harbour Commissioners 
Port of Plymouth 


Code exists for timber cargoes

SIR, With reference to your editorial of February 4 on the problems with timber deck cargoes, there is a longstanding international standard on the safe stowage and carriage of such cargoes.

The International Maritime Organization’s Timber Deck Cargo Code was first published in 1974. It was revised in 1981 and the current edition dates from 1992.

The Maritime Safety Committee of IMO recently authorised a thorough review of the code and that process started last October. The code is not mandatory, although some nations that export timber have adopted it within their maritime laws for their flag ships and all flag ships loading in their ports. Some have even made it mandatory for an independent organisation to certify that the loading and stowage complies with the code before the ship is permitted to sail.

If masters are under the pressures that you indicated, one or other of the aforesaid measures would eliminate that. Patrik Granstam, IMO co-ordinator of the work, tells me interested readers can contact him at patrik.granstam@sjofartsverket.se

Mike Compton
Technical adviser, 
ICHCA International 
Romford, Essex


Doing what it says on the tin 

SIR, Michael Grey’s suggestion to “rebrand the tanker” (Viewpoint, February 4), in an effort to make it rather more politically acceptable as means of transport has much merit. What about an EOC — an Essential Oil Carrier? It does what it says on the tin.

Yours etc

Capt Anthony Baker Douglas, 
IOM IMI 4NY


MCA staff exit ‘planned’ 

SIR, Your report (‘High profile MCA staff ask to quit’, February 1) gives the impression of an unexpected brain-drain during the planned restructuring of the administrative centre of the Maritime and Coastguard Agency.

The unexpected part is that only about half of the number anticipated have applied for a severance package.

The departures will be taking place over the rest of this year as originally scheduled and business will continue uninterrupted. The movement of some senior staff will, of course, create opportunities for their talented younger colleagues.

Although doomsayers can always be found to talk to the press, the actual behaviour of our staff does not bear this out.

Our sickness absence rate remains one of the lowest in the Department for Transport, general staff turnover remains unchanged and we continue to do our job normally, as the handling of this winter’s series of shipping casualties demonstrates.

We cannot, of course, foresee the outcome of the strike ballots and resulting action by our trades unions, but we continue to work constructively with them on plans to ensure that safety at sea is not compromised.

Peter Cardy
Chief executive
Maritime & Coastguard Agency 


Joint Hull Committee initiative must be embraced 

SIR, I was disappointed and surprised to read Anthony Delderfield’s criticism of the Joint Hull Committee and its current chairman, Simon Stonehouse (Lloyds List, January 18), following the Lloyds List article of the December 10 where Simon had made a case for hull underwriters supporting the shipping industry more actively.

It is self evident to me that underwriters (and brokers) should be supporting the shipping industry. It must be in our interests to contribute in seeking resolutions to issues such as shortages of qualified crew; criminalisation of seafarers; ports of refuge for vessels in distress; common structural rules and goal based standards.

This is in addition to questioning some of the more esoteric ideas emanating from the EU such as an EU coastguard, new liability regimes which threaten to break up limited liability concepts, implementing IMO directives-even transferring flag state control completely to the EU, ship machinery certification widened from IACS members to unspecified authorising authorities, and so on.

There is no doubt that the major marine markets are very much more professional than in both Mr Delderfield’s time and my own 40 years in the market.

Individual operators have rating guidelines approved by their executive and there is a vast range of information available and utilised. For example, risk management applications now include such pre-risk analysis as management operations, engine room evaluation, office procedures and port state control information is widely available, while new software programmes provide ‘drill down’ opportunities to research individual vessel history to name but a few.

The function of Joint Hull Committee has been adapted to encompass the changing environment and legislation, moving from a quasi cartel-type body to an advisory and technical authority to the market, whose advice and knowledge can be utilised or ignored in the evaluation of risk-the choice left to the individual underwriting operator.

I believe the Joint Hull Committee under the last few chairmen has greatly assisted the market in focusing on the dramatic changes we have seen in the shipping world, particularly over the last 10 years. The current Joint Hull initiative to interface more with, and provide greater support to, the shipping industry and for us to better understand their business (and vice-versa), is not only to be applauded but embraced by all hull underwriter’s who want to see their industry flourish in the future.

Membership of Joint Hull is voluntary and involves considerable amounts of underwriters own time. To suggest this may impinge on safeguarding members interests (and presumably company shareholder interests) is frankly derisory. Having been a member for over 10 years some long time ago, I have rarely seen any constructive praise for this invaluable institution and I am sad that someone with such a long association with the market should be so be so out of touch with current reality.

Keith Potter, 
FCII Chartered Insurer
Sanderstead, Surrey 


Sinking feeling on lack of maritime eco-leadership 

SIR, What a shame you had to spoil your piece (and show your true colours) on the differences between maritime and aviation disasters (Lloyd’s List January 28).

The nasty little reactionary paragraph at the end seems to suggest environmental activism can’t co-exist with justice and commonsense. What tosh!

The aviation industry itself seethes with ‘environmental activists’ (whatever they are) and more power to their elbows.

Your subtext is a blatant appeal to the neo-con right wing free market agenda which got us into this mess in the first place.

Some of the latest observation and research in leadership discourse detects a move (in the corporate world and elsewhere) towards ‘eco-leadership’, which would be in keeping with moves in society at large.

So, far from seeing off environmental activism, we’re actually seeing industry embracing it.

I’m guessing, but I expect your preferred models of leadership probably haven’t moved on since Nelson, so I don’t expect too much buy-in there!

On a final note, you also manage some breathtaking hypocrisy by, on one hand, espousing a blame-free culture, while at the same time laying into the Spanish authorities (Prestige) “which (sic) are arguably culpable”.

Quite enjoyed it otherwise...

Chris Haughton
Haughton Maritime Ltd, 
Inversanda, Rosslyn Avenue, Preesall, Poulton-le-Fylde 
Lancashire FY6 0HE


Why too much personnel service is bad for the MCA 

SIR, In recent weeks your paper has run a number of articles on the present restructuring of the MCA. This letter is a further, but unattributable, contribution on this subject for your information.

The intended new organisational structure of the agency has been announced to all employees. It is clear from this that there is to be an absolute and disproportionate increase in personnel branch (human resources if one must) staffing at high grades, at the expense of others perceived as being less useful.

The new personnel establishment appears to the writer as a kind of praetorian guard to surround the person of the chief executive who, of admitted little relevant experience, proceeds to dismiss his generals while leaving his infantry disorganised.

The similarity disappears, however, when one considers that personnel branches cannot organise campaigns.

During a full career in shipping on both sides of the regulatory divide, I always recognised owners, seafarers and government as those most reliant on MCA advice.

That the present confusion here in Spring Place is likely to persist is not only regrettable, but it will come to be regretted by all these.

‘Resigned’Maritime and Coastguard Agency


Ice Prince proves Napoli lesson has been learned 

SIR, Your report (‘Review urged after MSC Napoli’, January 30) suggests that the law should be reviewed in response to the scenes of scavenging that following the beaching of the ship.

In fact, the lesson of the MSC Napoli did not go without notice.

A similar situation was prevented in the aftermath of the sinking of the Ice Prince by prompt action by the Receiver of Wreck, who conferred the appropriate powers on the coastal police forces along the expected trajectory of the deck cargo of timber.

The police have taken the appropriate action and some arrests have been made: though some timber has been removed, there has been no repetition of the disorder of January 2007.

The insurers have also accepted responsibility for the shoreline cleanup, another lesson from the MSC Napoli.

Peter Cardy
Chief Executive Maritime & Coastguard Agency


Fair treatment for seafarers is essential in every situation 

SIR, it is difficult to judge an accident even with all the details on the table. The same goes for the unfortunate Hebei Spirit accident.

What we do know is that seafarers have been detained and later charged for violation of anti-pollution laws. It seems that the two barge captains have been in a difficult situation, while the crew of the tanker appear not to have had real possibilities to prevent the accident.

My role is not to judge the case, but to stress the complexity in these matters and to encourage the authorities to fair treatment for the seafarers involved in this and other incidents.

Luckily, no seafarers were injured in this accident, but the environmental impact is very unfortunate in itself.

The IMO/ILO guidelines on the Fair Treatment of Seafarers from June 2006 should be followed by authorities all over the world.

In this connection, BIMCO feels it is necessary to highlight that the guidelines state that the coastal state should take steps to conduct the case in a fair and expeditious manner, and the coastal state should minimise the physical presence of the seafarers. While we have no reason to suspect that this is not the case already, it should, nevertheless, be stressed here more than 50 days since the incident took place and the three masters are still detained in South Korea.

As we know, most people around the world are not aware of the fact that ships carry 90% of all goods and that shipping is a prerequisite for global trade and, indeed, the way we live today. Ships are run by people. It is key to the shipping industry that seafarers are given fair treatment. This is not only to improve recruitment, which reflects a complex challenge with many elements involved, but first and foremost to give our present seafarers proper working conditions and treatment even in difficult times, as when they are involved in an accident. We owe that to one of our industry’s most precious assets — the seafarers.

Philip Embiricos
BIMCO President
Bagsværdvej 161
BagsværdDK-2880
Denmark


Captains lose out in the blame game 

SIR, I’ve been reading with interest the Hebei Spirit case. I wonder if less than one hour is sufficient time for action by the anchored tanker of more than 260,000 dwt to avoid collision with the barge. The captain may be responsible for collision only if he anchored the ship in position which is dangerous for safe passage of other vessels.

I am very concerned about the captain’s future, because if the captain of the anchored vessel is going to be responsible for some collision, then the captain of the berthed vessel in port may be responsible for collision too some day.

A captain’s job is not an easy job and it is full of unpredictable surprises. Whatever happens to the ship, everybody is asking the same question: “Who was the captain?” It is also easiest to blame the captain for everything.

Those captains who want to be successful masters need to have a lot of skills, continuous concentration and, of course, they should have a lot of luck.

Captain Doctor Ivica Tijardovic,
PhD Split-Croatia


Working for peanuts? You’ll have to hire monkeys 

SIR, At a time when the rapidly increasing shortage of competent crew threatens the safety of global maritime trade routes, it is worrying to read ‘MCA braces itself for industrial action’ (Lloyd’s List January 17).

Happily, the majority of those working for the Maritime and Coastguard Agency are professionals and can be relied upon not to take any action that would endanger the lives of those they serve or the ships in which they sail.

The emasculation of this vital maritime safety agency started long before Peter Cardy appeared on the scene and many of us, reading his assurances shortly after he took office, were hopeful that he could be relied upon to stem the growing discontent and steady loss of talent.

Unfortunately, this does not appear to be the case.

Most of the reports of discontent concentrate on the capping of the public sector pay awards, but this is only part of the story.

The recent decision to grant UK registration to vessels that do not comply with Solas undoubtedly divided the agency and reinforced the long-held view that registration and legislative enforcement are unhappy bedfellows — and many still have reservations about the success of the unified coastguard/regulatory body structure.

More transparency and less political interference would be welcomed.

Money undoubtedly is a concern and it is almost unbelievable to read that “many experienced staff are set to see pay increases of under 1% ... coastguard watch assistants earn basic pay rates only £0.01 an hour higher than the legal minimum wage”.

Surely, in the nine months that he has worked with the agency, Mr Cardy has recognised the worth and dedication of these men and women and he will not, as his spokesman suggests, conveniently allow “his hands to be tied” by the public sector pay cap?

Leadership and management are all about standing up for one’s employees. It is ironic that the rewards of those who strive to prevent accidents are so inferior to those who investigate accidents after they have happened — and the latter are not overpaid.

Mr Cardy has suggested elsewhere that the ‘Nintendo’ generation of game-playing teenagers possess the skills needed by the shipping industry — and the UK Coastguard.

Apparently, these game players “have developed an ability to see, comprehend and analyse multiple sources of information.

“They then use that information to make the best decision.”

I suggest that that is precisely what the majority of his employees do on a day-to-day basis and they expect to be rewarded (and valued) for it — as will the Nintendo generation.

Captain CR Kelso
5 Bursledon Heights
Bursledon, Southampton
SO31 8DBHants


Not so fast, Jim

SIR, Although I cannot claim to have served my ‘learner’ time quite so far back as my respected friend Jim Davis (Lloyd’s List, January 17) nor in the familiarity of the London Royal Docks, our mutual employer (P&O/BI) sent me ‘to learn on the job’, which took me directly into the bewildering ways of life in the Far East.

While canvassing for cargo from Japanese keiretsu, I learned very quickly that the speed of our liner services to Australia, the Middle East or, say, Europe was always highly critical.

Of course, exactly the same applied back in the days of sail, as illustrated best by memories of the famous tea clippers like Cutty Sark.

It would be logical if the EU allowed the Box Club to agree to restrict their services at set lower speeds if the exercise suggested by Jim supports it.

But without robust conference systems, and human nature being what it is, I fear it would be too easy for the need for profit to confound common sense and for some renegade(s) to upset the apple cart.

Michael Farlie
Vancouver
British Columbia


JHC’s limited mandate

SIR, I have just read James Brewer’s report on his interview with Simon Stonehouse, chairman of the London Joint Hull Committee, entitled “Underwriters are urged to support shipping industry” (Lloyd’s List December 10, 2007).

Mr Stonehouse makes some very sensible and valid points, but I am not aware of any mandate the JHC has to concern itself with the many complicated issues facing our mercantile industry.

As a practising underwriter, Mr Stonehouse’s prime interest should be the safeguarding of his members’ financial interests and encouraging all marine underwriters to support the rules and encourage the members to publicise their insurance products and available markets in London specialising in various innovative policies. All other matters should be the responsibility of the transport minister.

Throughout my senior lifetime I have watched with frustration successive British governments weaken and anger the British Mercantile Marine.

In 1935 there were about 7,000 vessels under British flag representing a grt of 17,000. In 1965 there were 4,500 vessels with a grt of nearly 22,000. Due to larger vessels being built in 1975, only 3,622 vessels registered with a grt of 33,000.

In the past 30 years Greek and Hong Kong shipowners controlled approximately 60% of the world tonnage.

While British shipowners were being forced to pay corporation tax the Greeks adopted the more sensible tonnage tax, later improved on by the Dutch.

All this forced British owners to set up foreign companies and fly flags of convenience. As a devout Tory it pains me to write that in the year 2000 John Prescott bullied and badgered all the right people and forced the Government to change to the Greek system of tonnage tax. Since then there has been an increase of 300% in trading fleets and an increase of 350% dwt flying the British flag.

During my broking years I have had numerous uncomfortable interviews with various JHC chairmen in my quest to obtain what I knew to be uneconomical rates. Fortunately the London market is much more disciplined today than it was when I rejoined Lloyd’s in 1947 after army service.

Brokers, underwriters, protection and indemnity clubs, the Salvage Association, Lloyd’s Register and the Chamber of Shipping are providing a very important service with many others to the British Mercantile Marine.

In spite of all this, if I find an underwriter prepared to cut my competitors’ rates I will of course do what is best for the owners paying my commission.

Antony Delderfield
Arthur J. Gallagher (UK) Limited
9 Alie Street
London E1 8DE 


No decision on distillates

Sir, I refer to the report ‘Distillates win green fuel debate’ in your issue dated 16 January, which states that the IMO’s Expert Panel studying shipping’s impact on the environment “has concluded that increased use of distillate fuel is the most practical way to comply with tough new emissions regulations”.

Both the statement and the headline over the article are incorrect and misleading. The IMO report does not draw conclusions nor — as you rightly state — make recommendations. It sets out the findings of its expert groups. While some of these findings address the use of distillate fuels, many others explore alternative solutions. Your article makes no mention of these. It is entirely wrong to suggest that the IMO has concluded that distillate fuel is the most practical way of dealing with new emissions regulations. It has not.

The IMO has undertaken a thorough study of the options facing the shipping industry in this regard, one of which relates to the use of distillate fuels.

No decisions will be made, or conclusions drawn, until the other options explored by IMO have been thoroughly debated.

Ian Adams
Secretary-General
International Bunker Industry Association,
Southampton


Why need for speed is ill-conceived 

SIR, I was interested to read that Mr Miyahara, president of NYK, has made a decision to slow down vessel speeds. This initiative should reduce bunker costs by some 25% and significantly reduce the dreaded carbon footprint.

But I have a sense of déjà vu on this resolution. In my days in the 1950s when I was serving my ‘learner’ time in the London Royal Docks, I was puzzled over the need to rush freight liner tonnage at 20-plus knots from the Far East or Australia, only for that cargo often to stand undelivered for weeks. What a waste it seemed.

Nowadays, containerisation has nearly overcome these delivery hang ups, but is not the whole concept of high speed freight vessels ill-conceived? The great innovator of container shipping, Malcolm McLean, decided that his Sealand ships should be “big, fat and slow”.

The old arguments of cost of money/letters of credit, do not, to my mind, hold water. The ‘just in time’ management that is today’s norm (ie, elimination so far as possible of holding stock) can be perfectly well served by steady instead of high speed deliveries. Furthermore if the huge cost of bunkers simply to speed transit time were to be passed on to shippers/consignees, it would heartily surpass the few days extra interest notionally charged.

It would be, I suggest, thoroughly worthwhile for major container lines to work out and exhibit the real cost per container involved between carriage on a high speed container ship and one operating more slowly.

Jim Davis 
Chairman
International Maritime Industries Forum 
c/o The Baltic Exchange
38 St Mary Axe
London EC3A 8BH


Use our pilots to guide vessels safely into port 

SIR, I read with interest the comments in the letter from Captain Kayser in Lloyd’s List (January 4, 2008).
We are one of the deep sea pilot agencies operating in northern Europe, and have been offering the services of licensed Trinity House sea pilots to many of the responsible shipping owners and charterers who see the benefit and value in using the service we have offered for over 60 years.

Our agency offers licensed deep sea pilots who will join a vessel on its approach to Europe at either Brixham, off the UK south coast, or Cherbourg, France. The pilot has a great deal of experience and knowledge, gained over the very many regular transits he makes in and around the English Channel and North Sea. They are effectively an extra navigation officer on the bridge at all times when the vessel is on a sea passage.

Not being a member of the ship’s crew gives them the opportunity to get adequate rest when the ship is on a river passage and in port, and be fully rested when taking the vessel onwards to the next port.

A pilot is fully aware of the constraints and of any changes to navigation in the area, and of all reporting procedures.

He can liaise with the local pilot stations and make correct and safe approaches to where they hand over to local pilots. A deep sea pilot will have served as a master on a vessel for a minimum of three years, with the majority of pilots having at least 10-15 years in command before coming ashore, training, sitting an examination and obtaining their licence from Trinity House. They are fully aware of the importance of keeping a vessel to the schedule, and the stress and fatigue experienced by masters and crews.

A pilot is also aware that the master’s job is not finished when he arrives in port, as he is required to undertake paperwork, deal with the numerous demands made upon him on his arrival in port from the likes of immigration, agents, port state control and owners’ and charterers’ representatives.

The master and crew are then expected to be adequately rested and ready to be on the bridge for the passage down the river, and on the sea pasage to the next port, to undergo all the same duties again.

Some of these container vessels are making three to four port calls in four to five days.

The cost of a deep sea pilot for the LT Cortesia would have been in the region of £2,500-£3,000 ($4,900-$5,900), a mere drop in the ocean compared with costs involved in the grounding of the vessel on the Varne bank.

We would also welcome a dialogue between the P&I Clubs, who we would like to see encouraging the use of pilots and some incentive being given to shipping companies and charterers who use or would consider using our services.

It would also be of benefit if the profile and availability of pilots was more strongly promoted by governments and the various maritime organisations within the UK and Europe.

Patricia Brooks
Managing Director
Deep Sea & Coastal Pilots Ltd
Gravesend Kent 
DA12 3WB 


An extra hand makes economic sense

SIR, I agree with your view that too many owners and their operations departments are ignorant in respect of navigational necessities securing a safe and economic outcome of a voyage.

I do, however, also believe that incidents such as the unfortunate accident of LT Cortesia are also manipulated by the simple imbalance of container terminal capacity versus cargo throughput.

The consequences of missing a berthing window for a ship the size of LT Cortesia are significant and can reduce any profit generated by the total voyage and that increases pressure on the master and navigators. It is also well-known that the European part of large containership schedules is taking its toll on officers, especially the less experienced.

One solution, which in my opinion makes sense to an operator, is to increase the number of navigators, either by an officer employed for the European part of the voyage or by a permanent extra hand.

With the lack of officers, more officers with less experience will be placed in charge of these huge vessels, and one way of retaining experienced officers could be to employ them on shorter trips, enabling them more time at home while sharing their experiences on top of what the present senior officers already do (if they have time for it).

I understand that most tankers are now required by the charterers or cargo owners to employ extra officers with the exact reason being to avoid accidents. With the cost the LT Cortesia incident will accumulate, an extra hand seems a very manageable insurance.

Captain FJ Kayser
Address supplied


Cheap cover 

SIR, The article ‘Cheap Cover to continue for soft German market’ (December 6) reports “price drops in 2008…are partly due to new providers entering the market...such as Mitsui Sumitomo Insurance Co (EU) [my company] and Mapfre...”

Such a statement is misleading, as it is very unlikely, probably unrealistic, to assume that such ‘new kids on the bloc’ can have any impact on what is a €19bn ($27.2bn) market!

The fact is the two major players, AGCS and HDI Gerling, are driving the market down for their fierce competition against each other. AGCS, having two former Gerling board members in charge for Germany, aims to lure what have been Gerling clients (such as BMW) to Allianz. Whereas the merged HDI Gerling is desperately trying to retain — at whatever cost — its client base in lieu of preparing for the expected IPO of its parent Talanx.

Despite rate reductions for the last three years (not four years), the results in the industrial segments remain positive. Just look at what was the former Gerling/ GKA company on a standalone basis producing its best ever underwriting result in the industrial sectors for 2005 and 2006.

Reiner K Gleiss
Hauptbevollmächtigter and general manager
Mitsui Sumitomo Insurance Co (EU) Ltd
Niederlassung für Deutschland
An den Dominikanern 11-27, 50668 Köln


Why have shipowners jilted their husbands? 

SIR, With reference to Dr Hughes’ most helpful letter of Lloyd’s list December 6 (‘Befriending the master’), what has become of the concept of the Ship’s Husband?

When I joined this industry in the 1950s, the Blue Funnel Line always appointed one of its most senior directors as the Ship’s Husband. This executive was intended to create and to preserve precisely the personal and concerned contact with the ships to which Dr Hughes refers.

I recall that it was explained to me at the time that this executive held himself and was held by his colleagues to be legally responsible for the safe conduct of the fleet.

Many years later, I recall asking who was the Ship’s Husband at P&O in the case of the Herald of Free Enterprise disaster? And I believe that the answer was that there wasn’t one.

Sic transit gloria mundi.

Geoffry Lucas
Shipbroker
London SW3


Hebei Spirit rattles communication chains 

SIR, Your article in Lloyd’s List of December 13, 2007 (Repairs to Hebei Spirit prove tricky but on track) rattled an old ghost, particularly: ‘Questions continue to be asked about the inability of the barge’s towmaster to establish VHF communications with the shore VTS station, which appear to have been caused by the failure of the lead tug to monitor Channel 16 as required.’

In my former role of senior radio adviser with the MCA, I was once asked whether vessels operating in a (port) VTS area are required to monitor Channel 16. My response: it all depends. It must be remembered that the principal reason for monitoring Channel 16 watch is distress and safety.

The relevant legislation is buried in the small print of the International Telecommunications Union Radio Regulations.

Although the number may have changed in recent years, to the best of my knowledge, the following ITU regulation is still in force:

‘3060 (4) Ship stations, when incommunication with a coast stationin the ship movement service and subject to the agreement of the administrations concerned, may continue to maintain watch on the appropriate ship movement service frequency only, providedthe watch on 156.8 MHz (Channel 16)is being maintained by that coaststation.’

A ship movement service is defined by the ITU as “a safety service, other than a port operations service, between coast stations and ship stations, or between ship stations, in which messages are restricted to those relating to the movement of ships, that is, VTS”.

A port operations service is a radio service in or near a port, between coast stations and ship stations, or between ship stations, in which messages are restricted to those relating to the operational handling, the movement and the safety of ships and, in an emergency, to the safety of persons.

This may also be viewed to describe VTS. However, there is a similar dispensation in the ITU regulations apropos Channel 16 monitoring.

Thus, providing the VTS (or another coast station) is monitoring Channel 16 for distress and safety calls, vessels need not.

The regulation is quite pragmatic:

• If a ship is communicating with a VTS, its crew are likely fully occupied with managing navigational safety and should not be otherwise distracted by ‘chit chat’ on Channel 16; and, in any event,

• A ship within a VTS area is probably not in a position to go to another vessel in distress, or would otherwise be required to do so — and any safety information to be sent would largely be irrelevant — so what purpose can there be in keeping the distress and safety watch on Channel 16?

Consequently, when asked, my general advice on this subject was along thelines of: unless information to the contrary is published by the port or other authority responsible for the VTS (theUS requires a continuous watch on Channel 16 be maintained), and providing the VTS channel is monitored at all times, Channel 16 need not be monitored by vessels in a VTS area where viewed (by the master) to be detrimental to navigational safety.

This would not explain why the lead tug in Korea did not respond to calls on the VTS channel, presuming these were made in addition to calls on Channel 16.

Perhaps it is also worth noting that, in line with US practice, the ITU recommends vessels monitor Channel 13 (not Channel 16) at all times for bridge-to-bridge communications related to collision avoidance; Channel 16, strictly speaking, ceased to be a general marine calling channel with the full implementation of GMDSS. (Yes, I am fully aware that I am quoting regulations from a mythical IMO/ITU-world that does not exist.)

Incidentally, in the days when GMDSS false alarms were a big issue, if they are not now, taking the aforementioned interpretation one stage further, my ‘unofficial’ advice was that any vessel passing through the Dover Straits, in GMDSS sea area A1 and in the coverage area of CNIS, was quite at liberty to isolate all GMDSS equipment other than VHF DSC and NAVTEX hence removing, at a stroke, the hazard of false alerts and the consequential interference to navigational safety.

Not that everyone agreed with this opinion, of course.

Forgive the self-publicity, but if you have not already picked this up, the MCA has made available my (and others’) recent report on international recreational vessel safety regulation.

This may be of some interest particularly in light of the brouhaha over the loss of the yacht Ouzo. Perhaps it is worth noting that, in general terms, there are now more people being killed at sea on, orby, recreational vessels than commercial vessels.

Steve Harding MRIN
Senior consultant
Marico Marine NZ
Wellington


IMO green agenda driven from within

SIR, I refer to Jamie Dale’s article (November 19) on the International Maritime Organization’s ongoing efforts to reduce greenhouse gases from ships.

I would like to clarify that the IMO’s work in this regard is in pursuance of the related policies approved by the IMO Assembly in 2003 (resolution A.963 (23)) and the consequential action plan and timetable agreed by our Marine Environment Protection Committee (MEPC).

In carrying out its work on this important matter, the IMO is doing its duty, as decided by its membership, and by so doing, is contributing to the international community’s efforts to control greenhouse gas emissions worldwide.

It was because of the IMO’s commitment to ensuring an appropriate response from international shipping to the challenges of climate change and global warming that the aforementioned policies, action plan and timetable were adopted. They are fully in line with the priority that the organization’s strategic high-level action plans place on the protection and preservation of the environment.

And it was with that same strategic vision, together with his desire to expedite the IMO’s ongoing efforts in this regard, that last week IMO Secretary-General Efthimios Mitropoulos informed the IMO Council of his intention to submit to the MEPC a proposal by which we might accelerate certain elements of our work and, thereby, facilitate and bring forward the decision-making process.

For, as your editorial so rightly states, what the maritime community needs and has asked for are “solid, scientifically based and practical solutions, devised internationally by the IMO”, which are, indeed, infinitely preferable to having a patchwork of different unilateral measures around the globe.

The IMO’s agenda has not been driven by outside pressures as your article suggests. Indeed nothing could be further from the truth — without disregarding the initiatives taken in other decision-making centres, which we commend, the protection of the marine environment is a task on which we spare no effort.

Lee Adamson
Head of Public Information Services
International Maritime Organization


Clarifying NPX capacity

SIR, We read with great interest your articles relating to the lock sizes for the Panama Canal’s third waterway and the possible need to raise the Bayonne Bridge outside the Port of New York and New Jersey (November 8, 2007). One of the articles suggests that classification societies, among other parties, are calling for the locks to be made wider. Lloyd’s Register would like to clarify its position on this issue.

The expansion of the canal has raised questions concerning optimal ship designs and capacities at a time of significant investment in ever larger capacity containerships. The predominant driver behind both the canal expansion and the issue of the height of the Bayonne Bridge in the Port of New York and New Jersey is the rapid increase in containership size.

Research undertaken by Lloyd’s Register indicates that the ability of the canal to transit larger containerships will increase the importance of US east coast ports — particularly New York and New Jersey — hence the significance of the Bayonne Bridge. The current width of the Panama Canal locks is 33.53 m and the maximum permitted beam for transit today is 32.3 m, leaving a very modest clearance of 1.2 m. In the new locks (the third set of locks, which will be 55 m wide) we understand that the Panama Canal Authority (ACP) will require substantially more clearance — 3 m either side of a 49 m wide ship. Because of this substantial difference there has been some speculation that, in time, the ACP might relax the clearance requirements relating to the third set of locks and allow ships with an increased beam, and therefore the potential for greater container capacity, to transit.

This needs to be distinguished from speculation about the construction of a potential (fourth) set of locks.

The expanded ship size dimensional constraints now specified by ACP — length 366 m, beam 49 m, draught 15 m — should enable most ships in service today and on order, as demonstrated in the table below, to transit the new locks. A very large number of ships fall into the current post-panamax-to-new panamax size range; these will benefit directly from the canal expansion.

There are very few ships (see table below) that will not be able to transit the new locks. Indeed, a modest increase in the size of the lock basins would have very little effect on the number of ships which would be ‘NPX compatible’ and this is entirely consistent with the view expressed by Mr Sabonge in your article.

Our analysis indicates that future NPX containerships will have maximum capacities of about 12,500 teu. With an expected doubling in global container trade volume by 2015, we anticipate very strong demand for canal transits by ships of this size.

It is clear that ACP has specified new lock dimensions which allow the transit of 49 m beam ships, to accommodate a large proportion of the current and future fleet. We believe that ACP’s decision is correct.

David Tozer
Lloyd’s Register Business manager, containerships


Class involvement key to proper repairs

SIR, I read with interest the article “Yards encouraged to guarantee standards of steel repair work” (Lloyd’s List, October 16). You report that the European Union-funded ALERT (Assessment of Lifecycle Effect of Repairs on Tankers) project is looking at repairs to tankers in response to the loss of the Prestige. The project team includes a flag state, an owners’ association, a classification society, a shipyard and a university.

There are two issues on which I would like to comment.

First, MME, one of the ALERT project partners, reports that weld testing is not done by marine experts, who would know where a ship would be subjected to higher stresses.

It is a surprise no mention is made of the role of classification and classification society surveyors, who are in the best position to oversee repairs to classed ships and provide guidance to owners.

Owners’ associations are able to provide guidance to owners. With safety as a priority, I would suggest that owners’ associations may want to examine the numbers of repairs carried out without any class involvement and to investigate the consequences of such unsupervised repairs.

Second, the project team states that “there has been very little research into repair work” and they “are trying to find out best practices for the industry”.

I would direct interested readers to the following publications: the International Association of Classification Societies’ Shipbuilding and Repair Quality Standard, 1996 and the Guidance Manual for Tanker Structures, 1997, published by the Tanker Structure Co-operative Forum (whose participants include Intertanko, OCIMF and IACS members).

Both publications cover the repair of ship structures. MME could be directed to the sections that clearly show where high stresses occur in tanker structures.

Class is able and willing to identify typical locations for high sensitivity to fatigue failure and to provide owners and yards with optimum strategies, solutions and supervision to help ensure effective maintenance and repair are carried out.

Alan Gavin
Marine Director 
Lloyd’s Register


MCA safety is not being compromised 

SIR, Your leader (October 31) entitled ‘Efficiency at all costs?’ paints a pessimistic picture about changes in the MCA. Readers of Lloyds List should be reassured that these changes to our administrative systems and management mean our work on the safety of seafarers and ships will be enhanced, not compromised, as a result.

Many of the MCA’s back-office functions are being centralised to South Wales, along with those carried out by the other executive agencies in the Department for Transport family. This has been known to the MCA staff for almost two years.

However, in contrast with your rather gloomy outlook, this change in the way we manage our business gives us a rare opportunity to review the agenda for the MCA, in anticipation of the challenges we will face in the shipping world of the 21st century and beyond.

Bigger and faster ships, new operations in severe conditions, more demanding standards, more sophisticated technology on ships and ashore, competition between navigation and renewable energy, and climate-driven extreme weather are among the factors that will shape our future work.

The issues of fatigue and manning, safety, carbon emissions and emergency response still need proper resourcing. By identifying clear priorities and sticking with them, the MCA can have a bigger impact to the benefit of all in our industry.

Peter Cardy, chief executive
Maritime and Coastguard Agency


IMO risks missing the emissions boat 

SIR, While the intervention in Lloyd’s List (October 11) of the International Maritime Organization in the shipping emissions debate (triggered by your coverage of Waterfront’s recent conference) is welcome, it is a pity it was not able to accept our invitation to participate in the conference itself, and engage at first hand with European stakeholders from the European Commission, industry and non-governmental organisation stakeholders.

The IMO’s Mr Palomares may think his statement that action will be agreed in 2009 will reassure us, but clearly the EU and many stakeholders think that is simply not fast enough. Nor is there any guarantee that the outcome will be the internationally binding international agreement to limit or cut greenhouse gas (GHG) emissions that is now necessary.

After all, the IMO was asked 10 years ago, in the Kyoto protocol, to pursue the limitation and reduction of GHG emissions. Since then, according to the European Commission, international shipping emissions have increased by more than 20%, the second fastest-growing source of GHG after aviation.

No wonder the Commission’s Blue Book on Maritime Policy, published on Wednesday, makes it clear Europe will not wait much longer for the IMO, nor will the EU accept a sub-standard deal.

The parallels with the aviation world are striking. The International Civil Aviation Organisation (ICAO), the UN body responsible for international aviation agreements, failed two weeks ago to deliver a binding international agreement of GHG emissions. The EU, and all the European Aviation Conference states, were unanimous in signalling their intention to go it alone.

The UK government is now leading that EU unilateral initiative, which will mean the inclusion of all flights leaving EU airports in the EU Emission Trading Scheme by 2010. It is not hard to work out what the EU is preparing for international shipping.

We would prefer a legally binding international agreement under the auspices of the IMO, but the IMO must bring forward its deadline or risk missing the boat.

Mark Watts, 
Director,
Waterfront Europe


IMO and gas emissions: putting the record straight 

SIR, It was disappointing to read, in yesterday’s article under the title ‘Brussels in carbon cut hint’, the negative comments made by various sources (who should certainly know better) on the International Maritime Organization’s work to contribute to the world efforts to reduce gas emissions. I, therefore, take this opportunity to put the record straight and thus leave your readers in no doubt as to the seriousness IMO attaches to the issue.

Our work to reduce ship-source atmospheric pollution is being progressed along two distinct paths, namely, control of greenhouse gas emissions generated from shipping operations and having the potential to contribute to global warming, and revision of the regulations for the prevention of air pollution from ships contained in Marpol Annex VI.

As regards GHG emissions, in October 2006, the Organization’s Marine Environment Protection Committee (MEPC 55) approved a work plan to identify and develop the mechanisms needed to achieve the limitation or reduction of CO©ü emissions from international shipping.

The work plan aims at improving the GHG indexing scheme, considering methodology for CO©ü emission baselines and considering technical, operational and market-based methods for dealing with GHG emissions.

The work plan is progressing in accordance with an agreed timetable and will culminate at MEPC 59 in July, 2009, enabling the IMO member states to agree on the action to be taken within the first commitment period under the Kyoto Protocol.

As part of this process, IMO is updating its 2000 GHG study to provide the factual basis needed for future decisions.

A correspondence group is currently working to compile and consider different approaches on technical, operational and market-based measures to address GHG emissions from ships and will present a report to MEPC 57 (March 31 to April 4, 2008), with a view to providing input to the considerations in accordance with the GHG work plan.

Progress is also being made on enhancing the GHG indexing scheme and a GHG module, being incorporated into the IMO’s Global Integrated Shipping Information System, will be in operation from November this year to make the information accessible for comparison and further studies by member states and the shipping industry.

From the above it is more than obvious, not only that an action plan has already been agreed by IMO but also that work to implement it is well under way — contrary to the statement in your article that “IMO could fail to have an action plan prepared by 2009”.

On the matter of air pollution from ships and the continuing review of Marpol Annex VI, your readers may recall that a cross government-industry scientific group of experts was established by the secretary-general in July to comprehensively review the impacts on the environment, on human health and on the shipping and petroleum industries of applying any of the proposed fuel options to reduce SOx and particulate matter generated by shipping and the consequential impact on other emissions, including CO©ü emissions from ships and refineries.

The final report of the group will be completed by mid-December for submission to MEPC 57 through BLG 12 (February 4-8, 2008).

Meanwhile, the BLG air pollution working group will be meeting in Berlin from October 29 to November 2 this year to consider other matters relating to the review of Annex VI, in particular NOx limits for new engines and introduction of control of particulate matter.

After consideration of the reports of the scientific group of experts and the air pollution working group, the BLG sub-committee will be able to develop a complete set of amendments to Marpol Annex VI, which will be submitted to MEPC 57 for approval and, subsequently, to MEPC 58 for final adoption in the autumn of 2008.

It should be apparent, therefore, that, contrary to some perceptions, IMO is working, and will continue to work, speedily and thoroughly on reducing emissions from international shipping, a transport industry that is vital to world trade and sustainable development.

The organization intends to maintain its leading position by purposely fostering the protection of the marine environment from all possible threats through close co-operation with other relevant United Nations bodies, governmental and non-governmental organisations and, naturally, the shipping industry, thus rendering unilateral action, either on a regional or national level, redundant in all respects.
M Palomares
Director
Marine environment division
International Maritime Organization 


Accidents waiting to happen

SIR, Having watched this topic for some time and been actively involved in finding a solution to known problems for several years, I feel it is about time for us to hear of yet another lifeboat accident involving the maiming and killing of more seafarers.

The more superstitious of your readers will no doubt feel very uneasy about my saying this, but I would suggest my sense of doom is linked less to luck and more to seeing no satisfactory proposal by regulators of any solution to the problem.

I am certain that the tinkering that has taken place to date has done little or nothing to improve the situation and it may even have made matters worse.

As a mariner who now works in risk assessment, I feel frustrated that the problems of on-load release gear in particular, but also a host of other less fatal issues in lifeboats, have apparently never been subjected to a proper risk assessment. If they had the real killer hazard would have been positively identified and effective mitigation could have been put in place.

The killer hazard is the uncontrolled descent of the boat to the water’s edge, which usually means a free fall.

Unfortunately on-load release, side-launched boats are not designed for free fall. The problem with most investigations is that they dwell on factors such as so-called crew competence and maintenance rather than the hazard, which plays into the hands of the blame culture. We know that never benefited anything, except perhaps the bank balances of lawyers.

The irony is that the solution already exists and is familiar to seafarers and regulators across the world. In many states it is part of their legislation. In the UK, for example, it takes the form of the Lifting Operations and Lifting Equipment Regulations, known in the industry as LOLER.

This statute forbids the lifting of personnel by any equipment unless it has substantial safeguards against the carrier falling. Lifting equipment and loads are defined and include personnel. There are no exemptions for lifeboats and davits.

There is advice — very bad advice — that in the opinion of certain regulators life saving appliances are not considered lifting equipment, but no explanation is given as to why. It is as though the lifeboats are expected to have powers of levitation. Unfortunately there is overwhelming evidence to the contrary.

Under LOLER, on-load release gear is surely illegal until the boat reaches the water’s edge. It should therefore be rigidly disabled with a pin or other direct intervention in the hook, or by-passed with a resilient fibre safety strop, both of which can be easily removed just prior to the boat becoming waterborne. The so-called safeguards should not rely on over-complex mechanisms with hidden workings that have engineering tolerances far too fine for shipboard use, and which are usually made of unsuitable materials.

Perhaps those responsible for enforcing the bad advice might ponder the ultimate consequences of their actions. You know, or should know, that exercising a lifeboat launch could, if the unthinkable happens, result in the death of one or more persons and, incidentally, in risk assessment that alone would make the risk intolerable. You also know how to prevent such calamity (I have just told you how).

If you then insist on going ahead with the procedure without safeguards, or require a master to do it on your behalf, and the unthinkable does occur and you are left with a failed boat in the water with maybe two or more dead seafarers aboard, is that not manslaughter? If the case came before a judge it would be interesting to see how he or she interpreted the law — statute or advisory notice.

We can turn round and start acting rationally or we can sit on our hands and watch more seafarers die. I personally am sickened every time I hear of yet another accident when I know the solution and am very willing and eager to show anyone how to implement it, as I regularly do when inspecting ships. Will anyone join me?

Captain Dennis Barber. FNI. MRIN
Ship Inspector
Consulting Partner
Marine and Risk Consultants (Marico Marine)


Ban passengers from ro-ros and save lives 

SIR, In your leader ‘Festival of Ferries’ (Lloyd’s List September 18, 2007) you raise the possibility that “an acceptable safety level is often missing” in ferry operations owing to a lack of “technology transfer between the wealthy, technology-rich industrial world and developing nations”. Thus it seems that you are suggesting ferry losses reflect the wealth of the nation operating them. This is a serious matter and it is good that you recognise it as such for it threatens to involve, as you write, the loss of “many hundreds of people”.

In reality, the loss of lives arising from ro-ro ferry operations reflects the laws of physics and not the wealth of the managing nation. Even the so-called wealthy nations still have their ro-ros capsizing and sinking with such regularity that there should be more concern. The Sea Diamond (an ex-ro-ro), Tricolor, Queen of the North, Herald of Free Enterprise and Estonia are in this category.

The truth is that ro-ros are prone to capsizing because their athwartship watertight bulkheads are no higher than the main vehicle deck level. This is just a little above the water line. The design has been developed for the convenience service as roll on -roll off ferries. The commercial benefit of easy cargo handling has taken precedence over safety through the need to raise the bulkheads to the top of the hull.

The Titanic sank for the same reason. The tops of its internal watertight bulkheads were too low so the water of the initial flooding over-flowed successive watertight bulkheads to sink the ship. This defect was recognised by Solas and the bulkheads on all ships built subsequently were raised to the top of the hull with one startlingly exception, ro-ros, even though they often have hundreds of passengers onboard.

Of relevance, on the ro-ro ferr