PIC of the facility and/or tank barge often fails to follow key Operating Manual procedures
Recent casualties involving explosions aboard barges conducting tank cleaning operationsalongside marine terminals have resulted in serious injuries to vessel crews and facility workers,catastrophic property damage, as well as harm to the environment.
A review of related casualtieshas revealed that vessel personnel, facility personnel and shore side managers failed to ensurethat established procedures and safe practices were followed. Specifically, the OperationalManuals and regulatory requirements were not routinely followed by those involved. As a resultunintended and disastrous consequences occurred.
The USCG has issued safety alert toraise awareness regardingthis issue and highlightcritical lessons learned fromthese incidents. Facility andvessel managers andoperators, both ashore andafloat, responsible for theoversight of, or specificallyinvolved in tank cleaning,stripping or gas freeing offlammable cargoes, shouldtake note and ensure thewidest distribution to allpersonnel.
Title 33 Code of Federal Regulations (CFR) Part 154 – Facilities Transferring Oil or HazardousMaterial in Bulk; requires facilities to submit for approval to the Captain of the Port (COTP), anOperations Manual that provides facility details, types of cargos handled, duties/knowledgerequirements of specific personnel, locations of emergency shutdowns, descriptions of tankcleaning procedures, emergency procedures, and other requirements for each type of cargoevolution, tank cleaning, and vapor control processes.
For facilities that conduct tank cleaning,stripping, or gas freeing operations on tank vessels, the Operations Manual must contain adescription of their procedures that are consistent with the International Safety Guide for OilTankers and Terminals (ISGOTT). Specific sections of the Fifth edition are referenced in 33 CFRPart 154.
The most common causal factor associated with these tank barge explosions is that the Person inCharge (PIC) of the facility and/or tank barge failed to follow key Operating Manual procedures.
As a result of these casualties theCoast Guard strongly recommends that facility and vessel managers,operators and PIC’s performing tankcleaning, stripping, or gas freeing offlammable cargos on board any vesselreview ISGOTT Fifth edition and fullycomply with all related regulations andOperating Manuals while also ensuring(among many other items):
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Facility and vessel operators may submit a written request for the COTP to consider alternativeprocedures, methods, or equipment standards than those established within the ISGOTT orregulations. The COTP will evaluate any proposed alternative to ensure it provides an equivalentlevel of safety and pollution protection as required by the regulations.
Source: USCG / Marine Safety Alert 10-14