Britannia P&I Club presents ways to ensure proper cargo hold cleaning that meets the regulatory standards, so operators avoid relevant claims.
According to Britannia, ensuring cargo holds are cleaned to appropriate standards is an essential for shipowners operating bulk carriers. Failure to meet these standards can lead to cargo damage, noncompliance with regulations, pollution, and significant delays in operations, all of which can lead to claims.
Understanding the hold cleanliness requirements is often instrumental when analysing major claims, Britannia notes. The P&I club also presents suggestions including, but not being limited to, the following:
Hold inspections
Regular inspections and maintenance of the cargo hold should be conducted as part of a documented planned maintenance system within the Safety Management System (SMS). After every discharge and subsequent cleaning, holds should also be inspected by a responsible officer with any defects noted and repaired promptly. Typical areas of inspection include:
- Hold framing
- Structural access points (ladders, handrails etc.)
- Condition of hatch covers and all associated parts (trackways, hatch rubbers etc.)
- Paint coating condition
- Bilge system
- Light fittings
- Tank top areas
- Pipework within the hold
- Fixed firefighting systems
Managers should establish effective practices for cleaning areas that may be difficult to access or inspect, such as stiffeners under the deck in hold ends, which may require specialist equipment such as cherry pickers.
Cleanliness standards
Figure 1 delineates industry-standard cleanliness levels and their associations with various cargoes. These levels, such as “Hospital clean” (the highest), are crucial for compliance with Charterer’s instructions and IMSBC Code standards. Hospital clean is typically achieved by vessels exclusively trading specific cargoes and is rare in tramp trades. “Grain clean” is a common requirement, especially when the ship is unfixed for the next cargo. Notably, adhering to “load on top” standards may leave cargo residues hindering a full hold inspection for damages. The text also outlines procedures for “swept clean” and “shovel clean” scenarios, emphasizing the need for proper residue disposal to meet delivery standards.
Hold washing
The process of hold washing on ships involves critical considerations for safety and effectiveness. A comprehensive risk assessment by the ship’s master is essential, encompassing chemical usage, provision of accurate data (SDS), and adherence to safety measures. During paused cargo operations, crew members may access upper cargo hold areas after a risk assessment and permission from authorities.
Cleaning starts with hatch covers and deck areas, with attention to potential water entry and compliance with local wash water regulations. Sweeping debris, using appropriate cleaning chemicals, and considering cargo residues’ impact on bilge systems are emphasized.
Adequate fresh water for a final rinse is crucial to prevent chloride traces, which can lead to failed cleanliness inspections and coating issues. The text provides a detailed guide for efficient and compliant hold washing procedures.
Preventative measures
To protect their position and avoid disputes or claims, shipowners should consider the following:
- Conduct pre-loading inspections to ensure that the hold is clean and free from any residues or contaminants. This helps in identifying any potential issues before loading cargo.
- Maintain accurate records of hold cleaning activities, inspections, and any communication with charterers regarding hold cleanliness. These records can serve as evidence in case of disputes or claims.
- Maintain open and transparent communication with charterers regarding hold cleanliness. Inform them of the cleaning procedures followed, any issues identified during inspections, and any necessary remedial actions taken.
- Chartered entries should consider the differential in hold dimensions and hatch size when fixing a ship. The differential may mean that both a grab and bulldozer are required to discharge the cargo, considerably increasing discharge time.
- Remove as much cargo residue as possible at the discharge port, with local and MAPROL regulations always considered. This will better prepare shipowners in the event unforeseen circumstances, such as adverse weather.
- Local requirements may be more stringent than those typically experienced. Australia and the US are known to be areas with more strict requirements and shipowners should consult their local agents for up-to-date information on requirements in discharge ports.
