The Transportation Safety Board of Canada (TSB) has highlighted major issues with Canada’s marine emergency preparedness in light of its investigation into an incident involving the loss of containers and a fire on the ZIM Kingston containership.
The incident
On 21 October 2021, the container vessel ZIM Kingston, with 21 crew members on board, rolled 36° and lost 109 containers overboard while drifting at La Perouse Bank, about 27 nautical miles south of Ucluelet, British Columbia (BC). A number of containers on deck were also damaged.
The investigation determined that the ZIM Kingston experienced parametric rolling. Parametric rolling occurs when sea conditions converge with vessel-specific factors in a precise way, resulting in dangerous rolling motions. The forces created by the vessel’s extreme motions were the precipitating factor for the container loss.
Around 36 hours later, while the vessel was anchored off Victoria, BC, a fire broke out in a damaged container that held dangerous goods (potassium amyl xanthate). The fire then spread to 5 nearby containers, 2 of which also held xanthates and 3 of which held tires and other consumer items. The fire burned for 5 days before it was declared extinguished.
The on-board fire response followed industry and company guidelines and was conducted in an efficient manner. The ZIM Kingston had a contract with a U.S.-based emergency response company, which meant that the vessel had access to specialists who provided guidance throughout the emergency response and a team of trained personnel who were able to board the vessel to help contain the fire. The use of these shore-based specialized personnel, as well as vessels of opportunity, contributed to limiting the extent of the fire.
In November 2021, 4 of the containers lost overboard were recovered from the shores of northern Vancouver Island, along with various debris from the containers. In July 2023, an underwater survey located 29 containers on the ocean floor in proximity to the occurrence site. Ongoing beach cleanups have found debris that is likely from the ZIM Kingston washing up along large stretches of the BC coastline.
In order to better understand the motions that the ZIM Kingston experienced in this occurrence, the TSB contracted the National Research Council Canada to construct a scale model of the vessel. Testing with the scale model was then conducted in a basin where the occurrence conditions were simulated. The testing found that parametric rolling could develop regardless of whether the model was drifting or underway, and that the largest roll motions were observed when the model was in head and following sea conditions. The testing also found that parametric rolling could occur in significant wave heights as low as 2.6 m.
The investigation identified safety deficiencies that led the Board to issue 2 safety concerns: the first relates to the need for comprehensive guidance for managing the risk of parametric rolling and the second relates to Canada’s preparedness for marine emergencies.
Findings
Findings as to causes and contributing factors
These are conditions, acts or safety deficiencies that were found to have caused or contributed to this occurrence.
- While the ZIM Kingston was holding offshore at La Perouse Bank awaiting a berth at the Port of Vancouver, British Columbia, it encountered environmental conditions that, in conjunction with the specific characteristics of the vessel itself, resulted in the onset of parametric rolling.
- The parametric rolling caused the vessel to roll 36° to both port and starboard. The forces that resulted from these extreme motions were the precipitating factor causing the loss of 109 containers overboard and damage to other containers that remained on board.
- The vessel owner had not developed procedures or provided specific tools to support the bridge crew on the ZIM Kingston in making assessments and managing the risk of parametric rolling; as a result, this risk was not being effectively monitored and no mitigation measures were put in place as the vessel held offshore.
- Water ingress inside a damaged container holding potassium amyl xanthate in bay 14 generated a reaction that caused a fire to ignite inside the container and then spread to 5 other nearby containers.
Findings as to risk
These are conditions, unsafe acts or safety deficiencies that were found not to be a factor in this occurrence but could have adverse consequences in future occurrences.
- If there is no comprehensive, up-to-date guidance to industry in the management of parametric rolling, there is a risk that company policies, procedures, tools, and training in this regard will be inconsistent, ineffective, or absent altogether, leading to continued container loss occurrences and their associated negative outcomes for safety and the environment.
- If masters are provided with loading plans that do not respect the limits set out in a vessel’s cargo securing manual and masters accept the risk of sailing with lashing forces that exceed safe limits, container vessels will sail with a reduced margin of safety to protect against container loss.
- If Canada is not prepared to respond to marine emergencies in Canadian waters, there is a risk that these emergencies will not be managed in a timely and effective manner, endangering vessels, their crews, the environment, and the health and safety of Canadians.
Other findings
These items could enhance safety, resolve an issue of controversy, or provide a data point for future safety studies.
- Model testing by the National Research Council Canada identified that parametric rolling can occur in significant wave heights as low as 2.6 m, far less than those encountered at the time of the occurrence.
- The on-board response to the container fire followed industry and company guidelines and was conducted in an efficient manner. The use of shore-based specialized personnel and vessels of opportunity contributed to limiting the extent of the fire.
- Danaos’s contract with an emergency response company meant that the ZIM Kingston had access to specialists who provided guidance throughout the emergency response and a team of trained personnel who were able to board the vessel to help fight the fire.
- Canada does not have a program to monitor and assess the long-term impacts of lost containers or the debris from lost containers, and the impacts on marine ecosystems are relatively unknown.
- Electronic inclinometers provide more data about a vessel’s roll angles than analog inclinometers and also provide data about a vessel’s roll period, making them more useful for safe navigation and accident investigations.
Comprehensive guidance for managing the risk of parametric rolling
Managing the risk of parametric rolling is complex. Not only is it difficult to predict exactly when a parametric rolling event will occur, but once extreme rolling starts, it may not be possible to stop the dangerous motions before negative consequences occur, such as container loss. For this reason, there must be a focus on monitoring for the conditions that give rise to parametric rolling so that preventive measures can be taken when the conditions are present. Doing so requires bridge crew to have formal policies, comprehensive procedures, and effective tools for managing this risk.
The vessel owner had not developed procedures or provided specific tools to support the bridge crew on the ZIM Kingston in making assessments and managing the risk of parametric rolling; as a result, this risk was not being effectively monitored and no mitigation measures were put in place as the vessel held offshore.
The International Maritime Organization (IMO) is generally recognized as the international body best positioned to develop and disseminate guidance to the marine industry; however, its circular addressing the risk of parametric rolling has not been updated in over 17 years. Furthermore, the circular has only minimal operational guidance on parametric rolling and does not offer any guidance with respect to policies, procedures, training, tools, or services related to the management of risk associated with parametric rolling. Lastly, the circular also characterizes parametric rolling as a heavy weather phenomenon, whereas model testing of the ZIM Kingston conducted for the investigation determined that it could occur in moderate sea states.
The IMO recently published its Interim Guidelines on the Second Generation Intact Stability Criteria, which will minimize the risk of parametric rolling and will provide a consistent approach to address risk across the international shipping industry. However, the timeline for incorporation of these guidelines into the International Code on Intact Stability, 2008 is uncertain, and it is not clear whether the guidelines will apply to existing vessels. The guidelines also do not address the training of crew with respect to this issue.
The Board is concerned that the absence of up-to-date comprehensive industry guidance for the management of parametric rolling may cause company policies, procedures, tools, and training to be inconsistent, ineffective, or absent altogether, which could lead to more container loss occurrences, along with their associated negative outcomes for safety and the environment.
Canada’s preparedness for marine emergencies
On commercial vessels, crew are trained and equipped to handle many marine emergencies with on-board resources. However, an emergency can quickly shift to one where outside resources are needed. The occurrence involving the ZIM Kingston demonstrated some of the challenges involved in responding to a marine emergency in Canadian waters. It also raised questions about the availability and capability of Canadian resources to do so.
After the fire broke out on the vessel, it was largely due to fortuitous circumstances that a rapid and effective response using outside resources could be initiated. These same circumstances may not necessarily be present when responding to future occurrences, underscoring the need for a careful look at Canada’s preparedness.
Canada does not require pre-arranged plans for fire response or marine salvage, unlike the U.S. In addition, the Canadian Coast Guard does not directly participate in marine fire suppression activities as part of incident response, nor does it have fire suppression capabilities to directly respond to a vessel fire. While this occurrence took place at sea, previous TSB investigations have shown that there are also issues around preparedness when vessel fires occur in Canadian ports. Outside of ports and harbours, the options for responding to shipboard fires are even more limited should the on-board fire response be unsuccessful in suppressing the fire.
Canada’s preparedness for other types of marine emergencies, such as occurrences involving hazardous and noxious substances (HNS) is also a concern. Canada does not have a plan for how to respond to occurrences involving HNS, although it does have a plan for occurrences involving oil. Recognizing a need for improvement, the federal government has announced that it intends to develop a single system to respond to all marine pollution incidents regardless of their source, with a goal of responding to these incidents in a timely manner that minimizes impact on human health and the environment. In addition, Transport Canada (TC) intends to develop regulations to strengthen preparedness requirements for industry, for example, by requiring vessels to have arrangements for firefighting and salvage services, and by having a response specialist who could work with the federal departments and other partners to manage any incident.
This occurrence, and many others, have shown that while the Canadian Coast Guard has the capacity to evacuate crew members that are injured or at risk, there are systemic gaps in other aspects of responding to emergencies on vessels. While TC is proposing the above-noted changes to address these gaps, in practice the only concrete action that has been taken so far is the 2023 amendment to the Canada Shipping Act, 2001 that gives the Governor in Council the ability to make regulations regarding emergency arrangements. At June 2024, TC indicated that work to develop these regulations is expected to continue over the next 4 years, subject to the government’s regulatory priorities.
In the interim, the Board is concerned that there are gaps in Canada’s preparedness for marine emergencies that exceed the response capacity of a vessel’s crew, posing a risk to vessels, the environment, and the health and safety of the general public.
