Ecology Prevention Recommendations on Ship Bunkering (Fueling) Operations

1998-Present (updated May 22, 2008)

The table below contains recommendations made by the Washington State Department of Ecology to ship operators, fuel deliverers, Classification Societies, and government agencies following investigations of spills that occurred during ship bunkering (fueling) operations.  Some recommendations have been made in more than one case and no attempt was made to remove duplicate recommendations.  Readers will note that some recommendations were broad, while others were very specific to the circumstances of the spill.
Recommendation Reference Number Recommendation Text
2008-037 Emphasize the dangers of complacency during oil transfers to crews by publicizing lessons-learned from this spill throughout the company’s fleet.
2008-036 Emphasize to the bunkering team members during pre-bunkering training, the importance of closely monitoring the tank vents of tanks that are being topped-off.
2008-035 Ensure vessel crews that receive pre-bunkering training required by Washington’s procedures for safe bunkering, fully understand these requirements, and are prepared to carry out their duties as part of a bunkering team.
2008-034 Ensure your vessel crews are aware of and fully comply with Washington’s requirements for safe oil transfer.
2008-033 Ensure that pre-loading plans that are prepared are followed.
2008-032 Develop a means to more completely close-off the {ship's} freeing ports during fueling operations to prevent any spilled oil from reaching the water. Ensure those means are incorporated into the {ship's} oil transfer procedures.
2008-031 Modify your oil transfer procedures to prohibit simultaneous transfers (such as lube and fuel oil) when tanks are being topped-off, unless additional personnel are used to ensure both transfers can proceed safely.
2008-030 Regularly monitor the fueling operations of vessels in your fleet to ensure that Persons-in-charge are complying with the oil transfer procedures, especially with regard to the maximum tank fill levels that are established.
2008-029 Determine the safe fill level for each of the {ship's} tanks and ensure these levels are reflected in the ship’s oil transfer procedures. Consider marking the safe fill level on the sight glasses or on the bulkhead adjacent to the sight glasses.
2008-026 Consider revision of WAC 173-180-245 (4) to make allowance for instances where the design of the vessel is neither amenable to fixed vent containment nor automatic shut-off nozzles (as in the case of many tug boats). In the meantime, provide guidance to Ecology oil transfer inspectors as to how to handle such conditions when they observe them during inspections. Also consider approving facility operations manuals that do not incorporate the requirements of WAC 173-180-245 (4) as an interim measure.
2008-025 Ensure the tank truck Person-in-charge coordinates closely with vessel Person-in-charge to ensure that the hose is adequately cleared at the end of the transfer while preventing air from unnecessarily entering the tank.
2008-024 Ensure that your tug crews are aware of and fully comply with Washington’s requirements for safe oil transfer.
2008-023 Ensure the vessel Person-in-charge coordinates closely with tank truck Person-in-charge to ensure that the hose is adequately cleared at the end of the transfer while preventing air from unnecessarily entering the tank.
2008-022 Regularly monitor the fueling operations of tugs in your fleet to ensure that Persons-in-charge are complying with the oil transfer procedures, especially with regard to established maximum tank fill levels.
2008-021 Determine the safe fill level for each of the {ship's} tanks and ensure these levels are reflected in the tug’s oil transfer procedures.
2008-020 Develop a means to more completely close-off the {ship's} freeing ports during fueling operations to prevent any spilled oil from reaching the water. Ensure those means are incorporated into the {ship's} oil transfer procedures.
2008-019 Revise the oil transfer procedures for the {ship} so that they require the Person-in-charge to place containment under every fuel oil tank vent prior to fueling.
2008-018 Revise the oil transfer procedures for the {ship} to indicate correctly that the tug has no fixed containment around the tank vents
2008-011 Examine your inspection program under the Responsible Carrier Program; determine why the potential need for removal or tag-out of the cross-over valve was not identified under that program despite annual inspections.
2008-010 Examine your lock-out/tag-out procedures in light of this spill; determine why they were not applied to the barge day tank cross-over piping, and whether any improvement of lock-out/tag-out criteria can be made.
2008-009 Develop a means to more completely close-off the {ship's} freeing ports during fueling operations to prevent any spilled oil from reaching the water.
2008-008 Ensure that your tug crews are aware of the Washington State requirement to notify both the U.S. Coast Guard’s National Response Center and the Washington State Emergency Management Division in the event of a spill.
2008-007 Ensure that your tug crews are aware of and fully comply with Washington’s requirements for safe oil transfer.
2008-006 Ensure Persons-in-charge of oil transfers aboard your tugs complete an accurate pre-loading plan prior to the start of an oil transfer.
2007-072 Work with tank truck companies delivering oil at your facilities to ensure that they understand the port’s requirement to receive permission prior to starting an oil transfer at a port facility.
2007-071 Commend {personnel} for their efforts, in conjunction with the crew of the {ship}, to respond to contain and clean up the oil spill.
2007-070 Ensure your Persons-in-charge remain at the scene of an oil transfer from which a spill occurs until receiving approval to depart by the state on-scene coordinator.
2007-069 Ensure your Persons-in-charge provide an air horn to the vessel receiving oil during the pre-transfer conference as a back up to radio and voice communication.
2007-068 Ensure that your Persons-in-charge are aware of the Washington State requirement that a transfer shut down due to a spill not be restarted until after receiving approval from the state on-scene coordinator.
2007-067 Ensure that your response plan gives adequate information regarding the source of response materials and how to gain access to those materials in the event of a spill, when the transfer operation is dependent on a third-party source for those response materials.
2007-066 Ensure your operations manual requires that the Person-in-charge make positive contact with the owner of, or operator of, or local authority responsible for the location at which a transfer will take place to ensure that they have permission to conduct the transfer operation.
2007-065 Ensure your Persons-in-charge are adequately trained on the use of the company’s operations and response manuals, and are prepared to implement the manuals’ requirements.
2007-064 Ensure your operations and response manuals are kept up to date and that a copy of each is available in each tank truck for reference by your Persons-in-charge.
2007-063 Ensure your Persons-in-charge notify the U.S. Coast Guard and Washington Emergency Management Division when a spill occurs during an oil transfer involving one of your tank trucks.
2007-062 Ensure that your Persons-in-charge are aware of the Washington State requirement that a transfer shut down due to a spill not be restarted until after receiving approval from the state on-scene coordinator.
2007-061 Ensure that any facility from which the vessel takes fuel is aware that the ship’s fuel capacity is above the 10,500 gallon threshold above which federal and Washington State oil transfer regulations apply, by providing the ship’s fuel capacity to the facility Person-in-charge during the pre-transfer conference.
2007-060 Consider using the Washington State requirements for safe bunkering (Washington Administrative Code 317-40) as a guide to further enhance the safety of fueling operations aboard the {ship}.
2007-059 Ensure that Persons-in-charge of fueling operations aboard the ship carefully and completely prepare a pre-loading plan for discussion with the delivering Person-in-charge during the pre-transfer conference.
2007-058 Ensure that Persons-in-charge of fueling operations aboard the {ship} utilize the communication systems available to them to make immediate and positive notification to the delivering Person-in-charge when an oil spill occurs.
2007-057 Ensure that crew members that have assigned bunkering duties, including the Person-in-charge, get sufficient time off to get adequate rest prior to conducting fueling operations, and that they understand the importance of adequate rest and the dangers of working while fatigued.
2007-056 Review the {ship's} fuel system design to determine exactly why the bow-down starboard-list condition contributed to this spill despite the four-foot vent height, and, if necessary, undertake additional steps to prevent recurrence of a fueling spill under similar circumstances.
2007-055 Ensure the changes to the {ship's} oil transfer procedures proposed by the Captain are implemented. That is:
Take care when loading the vessel with fuel to avoid a list.
Station a crew member near the fuel tank vents.
2007-054 Ensure the ship’s Captain and Person-in-charge of an oil transfer is aware of the Washington State legal requirement for them to call the U.S. Coast Guard and Washington Emergency Management Division in the event of a spill from their vessel.
2007-053 Ensure ship’s crews visiting Washington waters are aware that they must conduct bunker training within 48 hours of the scheduled bunkering operation, and encourage them to conduct refresher training within 48 hours of any delayed bunkering operation.
2007-052 Evaluate the usefulness of the vent valves at each of the bunkering stations aboard ships of this class, and determine if they should be maintained or removed. [Ships typically break the vacuum in a fuel transfer hose for draining back oil to the delivering barge or shore facility by loosening the bolts at the flange, not by opening a vent valve.]
2007-051 Check other vessels of the same class to ensure that the vent valve spindles at the port and starboard bunkering stations are not painted in such a way to prevent them from being fully closed.
2007-050 Review the deck rover procedures to ensure the rover is frequently checking all possible locations for a spill, i.e. tank vents, opposite bunker station, water around the ship.
2007-049 Commend the crew of the {ship} for promptly reporting the spill of oil to authorities.
2007-048 Ensure that facility Persons-in-charge (PICs) work closely with their vessel counterparts to ensure that the transfer system alignment has been correctly made and independently checked.
2007-047 Review your procedures for inputting Advance Notice of Transfers (ANTs). Ensure it is reliable and has redundancy so if an entry is forgotten, the oversight is caught and fixed as soon as possible.
2007-046 Install lights to properly illuminate the valves and manifold system.
2007-045 Post a permanent line diagram of the oil transfer system at the valve location.
2007-044 Ensure all (oil transfer system) markings are kept clean and conspicuous.
2007-043 Mark all oil transfer system valves, manifolds, and piping with large and contrasting letters or numbers.
2007-042 Review {company's} spill notification procedures. Ensure the contingency plan is activated before other state and federal notifications are made.
2007-041 Ensure company procedures require tanks are sounded with sufficient frequency at the start of bunkering operations to verify that fuel is being received by the intended tanks.
2007-040 Ensure that personnel assigned duties during bunkering know what is expected of them and understand the importance of their role in preventing oil spills.
2007-039 Ensure the PIC of the transfer understands how to correctly fill out the forms provided by {company} to help ensure a safe fuel transfer.
2007-038 Amend the {ship's} pre-transfer checklist to include verification of the valve alignment by another person before beginning any fuel oil transfer.
2007-037 Commend the Tankerman-PIC and the crew of the {tug} for quickly making notifications and initiating response efforts once the oil spill was discovered.
2007-036 Ensure that company policies and procedures require tankermen to consider any unexpected shutdown during an oil transfer as a potential emergency and, if unable to safely and quickly gather additional information from the receiving or delivering party as to the cause, request assistance from the tug’s crew.
2007-035 Undertake a special International Safety Management (ISM) Code audit to ensure {company's} Safety Management System (SMS) is effective in light of the failures to conform to various standards, including the company’s own standards, found aboard the {ship}.
2007-034 Emphasize the dangers of complacency during oil transfers by publicizing lessons-learned from this spill throughout the company’s fleet.
2007-033 Ensure that crews aboard company ships are aware of their obligations to quickly notify their contingency plan provider, the U.S. Coast Guard, and Washington State, when oil spills occur in Washington State.
2007-032 Ensure, through regular internal auditing procedures incorporated into the company’s Safety Management System (SMS), that the Oil Record Book of vessels in the company’s fleet fully and accurately reflect activities that must be recorded under MARPOL, Annex I.
2007-031 Investigate the reason(s) that the oil spill at Seattle, Washington on {date} was not logged in the {ship's} Oil Record Book in accordance with MARPOL, Annex I requirements.
2007-030 Ensure that crew members are given sufficient time off to get adequate rest prior to conducting bunkering procedures, that they understand the importance of adequate rest and the dangers of working while fatigued, that they comply with work hour limitations, and that sufficient personnel are available to allow for compliance.
2007-029 Ensure crew members conduct soundings and record innages at regular intervals and that Persons-in-Charge use the information to calculate and record the rate of transfer. Ensure that the calculated rate is compared to the planned rate, and if the rate of transfer is not what is expected, that Persons-in-Charge of a bunkering operation are instructed to investigate the discrepancy immediately.
2007-028 Ensure that the company’s bunkering procedures emphasize quick communication with Persons-in-Charge of delivering vessels or facilities in the event of a discharge or other unexpected event during bunkering.
2007-027 Review your maintenance program to ensure that it requires adequate oversight of repairs and testing of any equipment that may impact the safety of the ship and the marine environment.
2007-026 Ensure the company’s bunkering procedures and all federal and state regulations regarding bunkering and oil transfers are understood and complied with by ships’ crews.
2007-025 Review the Pre-Fueling Checklist for the {ship} to ensure it is correct and consistent.
2007-024 Undertake a fleet-wide survey to identify “problem” fuel oil tanks. Identify the cause of the problems observed by ship personnel, and undertake steps to fix the problems or reduce the possibility they will result in a spill.
2007-023 Ensure that personnel assigned duties during bunkering know what is expected of them and understand the importance of their role in preventing oil spills.
2007-022 Amend the vessel’s pre-loading plan and/or oil transfer procedures to have detailed policies and procedures regarding monitoring the tanks levels.
2007-021 Ensure that any Person-in-Charge (PIC) has had adequate time to familiarize (or re-familiarize) themselves with the ship’s oil transfer procedures (OTPs), fuel piping system, and fuel piping system status prior to undertaking an oil transfer.
2007-020 Ensure that you are consulted on any modification made to the {ship's} light oil transfer system to make the transfer of diesel or marine gas oil easier.
2007-019 Ensure that any modification made to the {ship's} light oil transfer system to make the transfer of diesel or marine gas oil easier, be in consultation with your classification society.
2007-018 Ensure crew members conduct soundings and record innages at regular intervals and that Persons-in-Charge use the information to calculate and record the rate of transfer. Ensure that the calculated rate is compared to the planned rate, and if the rate of transfer is unacceptable, ensure Persons-in-Charge of the bunkering operation are instructed to contact the delivering vessel or facility immediately to adjust the transfer rate as appropriate.
2007-017 Commend the crew of the {ship} for promptly reporting the spill of oil to water to authorities.
2007-016 Ensure your company policies, procedures, and training materials place safety over commercial considerations in order of precedence.
2007-015 Review the use of camlock couplings aboard your tank barges, and ensure your procedures and tankermen training adequately address any special considerations regarding their use.
2007-014 Ensure that supervisors and more experienced personnel actively assist less experienced personnel to ensure safe operations when indicators are present that such assistance is called for.
2006-036 Ensure that personnel assigned duties during bunkering know what is expected of them and understand the importance of their role in preventing oil spills.
2006-035 Amend the vessel’s pre-loading plan and/or oil transfer procedures to have detailed policies and procedures regarding monitoring the tanks levels.
2006-034 Amend your company’s vessel pre-transfer checklist to include a test of any fuel tank high-level alarms.
2006-033 Amend your company’s vessel pre-transfer checklist to include a visual check of the piping alignment before beginning any fuel oil transfer.
2006-032 Ensure that tankermen inform the receiving vessel’s person-in-charge of any non-conformities with Federal or State regulations for bunkering they observe while conducting the pre-transfer conference and signing the Declaration of Inspection (DOI).
2006-031 Implement the plan developed in consultation with USCG Sector Portland pollution investigators and Ecology investigators to have the tankerman aboard the barge calculate the transfer rate based on soundings of the barge and convey that transfer rate to the ship’s person-in-charge via posting on a white or chalk board.
2006-030 Emphasize the dangers of complacency during oil transfers to crews by publicizing lessons-learned from this spill throughout the company’s fleet.
2006-029 Ensure your company policies and procedures place safety and environmental protection over commercial considerations in order of precedence.
2006-028 Emphasize teamwork during bunkering training to help maintain situational awareness.
2006-027 Undertake a special International Safety Management (ISM) Code audit to ensure your company’s Safety Management System (SMS) is effective in light of the failures to conform to various standards, including the company’s own standards, found aboard the {ship} on two separate occasions.
2006-026 Ensure Persons-in-Charge of bunkering are aware of the Washington State requirement that the training session occur within 48 hours prior to the start of the bunkering operation.
2006-025 Ensure Persons-in-Charge of bunkering are aware of the U.S. Federal requirement that each item on the Declaration of Inspection (DOI) form must be initialed prior to starting a transfer.
2006-024 Modify the {company's} checklist ‘Intake of Hydrocarbons in Bulk - Safety Verification List’ to include a requirement that the transfer rate be periodically calculated, recorded and monitored by the Person-in-Charge during the transfer.
2006-023 Ensure crew members conduct soundings and record innages at regular intervals and that Persons-in-Charge use the information to calculate and record the rate of transfer. Ensure that the calculated rate is compared to the planned rate, and if the rate of transfer is unacceptable, ensure Persons-in-Charge of the bunkering operation are instructed to contact the delivering vessel or facility immediately to adjust the transfer rate as appropriate.
2006-007 Emphasize the dangers of complacency during oil transfers to crews by publicizing lessons-learned from this spill throughout the company’s fleet.
2006-006 Ensure that personnel involved in an oil transfer are aware of, and fully understand, their duties and duty stations.
2006-005 Undertake a special International Safety Management (ISM) Code audit to ensure your company’s SMS is effective in light of the failures to conform to various standards, including the company’s own standards, found aboard the {ship}.
2006-004 Ensure that work hour records are maintained up-to-date for all bunkering team members, including the Chief Engineer, and that they accurately reflect the hours actually worked and rest periods.
2006-003 Ensure the company’s procedures for bunkering contained within the company’s Safety Management Manual and all federal and state regulations, are understood and complied with by ships’ crews.
2006-002 Ensure that bunkering personnel understand the importance of following procedures, and do not become complacent about using standard checklists.
2006-001 Ensure crew members conduct soundings and record innages at regular intervals and that Persons-in-Charge use the information to calculate and record the rate of transfer. Ensure that the calculated rate is compared to the planned rate, and if the rate of transfer is unacceptable, ensure Persons-in-Charge of the bunkering operation are instructed to contact the delivering vessel or facility immediately.
2005-054 Ensure the company’s “Procedures for Bunkering and Internal Oil Transfers” contained within the company’s Safety Management Manual and all federal and state regulations are understood and complied with by ships’ crews.
2005-055 Modify item 18 under “Preliminary Arrangements” of the {company's} checklist “Checklist for Bunkering Reception During Port Stay” to clearly reflect the requirement of Section 5.3.1 of the {company's} Safety Management Manual section “Procedure for Bunkering and Internal Oil Transfers.” Section 5.3.1 requires that “containment trays” be empty and “plugged” (or in this case secured by closing the valves) prior to starting the bunkering operation.
2005-056 Ensure crew members conduct soundings and record innages at regular intervals and that Persons-in-Charge use the information to calculate and record the rate of transfer. Ensure that the calculated rate is compared to the planned rate, and if the rate of transfer is unacceptable, ensure Persons-in-Charge of the bunkering operation are instructed to contact the delivering vessel or facility immediately.
2005-057 Emphasize teamwork during bunkering training to help maintain situational awareness.
2005-058 Ensure that crew members that have assigned bunkering duties, including the Chief Engineer, are given sufficient time off to get adequate rest prior to conducting bunkering operations, and that they understand the importance of adequate rest and the dangers of working while fatigued.
2005-059 Examine your procedures for transferring oil (internal and over-the-rail) to ensure that tank vent containment is checked prior to transfers.
2005-060 Ensure that work hour records are maintained up-to-date for all bunkering team members, including the Chief Engineer, and that they accurately reflect the hours actually worked and rest periods.
2005-061 Ensure your company policies and procedures place safety and environmental protection over commercial considerations in order of precedence.
2005-062 Emphasize the dangers of complacency during oil transfers to crews by publicizing lessons-learned from this spill throughout the company’s fleet.
2004-001 Ensure the company’s bunkering procedures and all local regulations regarding bunkering and oil transfers are understood and complied with by ships’ crews.
2004-002 Emphasize teamwork during bunkering training to help maintain situational awareness.
2004-003 Ensure that bunkering personnel understand the importance of following procedures, and do not become complacent about using standard checklists.
2004-004 Investigate, in cooperation with {the ship's Classification Societies, the revision of the set point for the high-level alarm on the upper portion of the {automated engineering status} display for the port fuel oil storage tank and determine how the improper setting occurred and how it apparently went un-corrected despite a requirement that it be checked prior to a transfer. Take steps, if necessary, to modify the company’s Safety Management System (SMS) to ensure proper functioning of {automated engineering status} alarms following any maintenance or testing.
2004-005 Ensure your company policies and procedures place safety and environmental protection over commercial considerations in order of precedence.
2004-006 Ensure crew members that act as Persons-in-Charge (PICs) of oil transfers manually record innages/ullages at regular intervals and do not rely solely on automated fuel oil tank alarms or displays during bunkering.
2004-007 Ensure that work hour records are maintained up-to-date for all bunkering team members and that they accurately reflect the hours actually worked and rest periods.
2004-008 Emphasize the dangers of complacency during oil transfers to crews by publicizing lessons-learned from this spill throughout the company’s fleet.
2004-009 Investigate, in cooperation with {the ship's operating company}and {the ship's other Classification Society}, the revision of the set point for the high-level alarm on the upper portion of the {automated engineering status} display for the port fuel oil storage tank and determine how the improper setting occurred and how it apparently went un-corrected despite a requirement that it be checked prior to a transfer.
2004-010 Undertake a special International Safety Management (ISM) Code audit to ensure {company's} SMS is effective in light of the failures to conform to various standards, including the company’s own standards, found aboard the {ship}.
2004-011 Investigate, in cooperation with {the ship's operating company} and {the ship's other Classification Society}, the revision of the set point for the high-level alarm on the upper portion of the {automated engineering status} display for the port fuel oil storage tank and determine how the improper setting occurred and how it apparently went un-corrected despite a requirement that it be checked prior to a transfer.
2004-026 Ensure that the revised ship’s Oil Transfer Procedures (OTPs) are available to the crew in the crew’s working language, and that they reflect the current vessel bunker piping configuration.
2004-027 Ensure that the revised ship’s plans showing any changes made in the shipyard, are available to the crew, including plans showing details of various critical systems and safety subsystems.
2004-028 Ensure that all shipboard crew receive familiarization training, including training in bunkering procedures, when they report to the ship.
2004-029 When familiarization training cannot be accomplished because of crew turnover, ensure that newly hired crew have sufficient time and documentation to familiarize themselves with the ship, before they undertake duties that may pose a risk to personnel, property, or the environment.
2004-030 Emphasize to crew that items on checklists such as the Declaration of Inspection (DOI) must not be checked and signed as completed until all tasks on the checklist are, in fact, completed.
2004-031 Ensure that maintenance policies require that all system labels and ship’s placards are protected during maintenance painting.. Establishing a policy to temporarily mask labels and placards prior to painting may suffice.
2004-032 Ensure that any vessel 300 gross tons or larger which you own or manage is covered under the Washington State Maritime Cooperative (WSMC) or covered under an approved Washington State contingency plan on file with the Department of Ecology before the vessel enters Washington State waters.
2004-033 Ensure appropriate personnel are trained to report spills and utilize the ship’s contingency plan in the event of an oil spill. Ensure they know the location of, and have read and understood, the Washington State Maritime Cooperative’s (WSMC) “Covered Vessel Field Guide.”
2003-037 Ensure the company’s bunkering procedures and all federal and state regulations regarding bunkering and oil transfers are understood and complied with by ships’ crews.
2003-038 Ensure crew members that act as Persons-in-Charge (PICs) of oil transfers conduct soundings and record innages at regular intervals and use the information to calculate and record the rate of transfer. If the rate of transfer is unacceptable they should be instructed to contact the delivering vessel or facility immediately.
2003-039 Emphasize teamwork during bunkering training to help maintain situational awareness. In particular, ensure that the engine room watch is given a role in monitoring tank levels where high level alarms are fitted to alert in the engine control room.
2003-040 Ensure that the crewmember stationed in the engine control room has an effective means of communication with the rest of the bunkering team.
2003-041 Ensure that bunkering personnel understand the importance of following procedures, and do not become complacent about using standard checklists.
2003-042 Ensure that crew members are given sufficient time off to get adequate rest prior to conducting bunkering procedures, that they understand the importance of adequate rest and the dangers of working while fatigued, that they comply with work hour limitations, and that sufficient personnel are available to allow for compliance.
2003-043 Ensure that work hour records are maintained up-to-date for all bunkering team members and that they accurately reflect the hours actually worked and rest periods.
2003-044 Develop standard procedures for the {ship} to ensure that the possibility of a cold plug developing in the on-deck fuel oil piping is minimized.
2003-045 Investigate the maintenance history of the on-deck fuel oil pressure relief valve and determine how the improper assembly apparently went un-detected for about ten months. Take steps, if necessary, to modify the company’s Safety Management System (SMS) to ensure proper oversight and documentation of equipment repair, maintenance and regular testing.
2003-046 Investigate, in cooperation with {the company's Classification Societies}, how the addition of the on-deck fuel oil piping for the forward fuel oil tank went undocumented in the ship’s fuel system diagrams.
2003-047 Investigate the reason(s) that the oil spill at Port Angeles, Washington on {date} was not logged in the {ship's} Oil Record Book in accordance with International Convention for the Prevention of Pollution from Ships (MARPOL), Annex I requirements.
2003-048 Ensure, through regular auditing procedures incorporated into the company’s Safety Management System (SMS), that the Oil Record Book of vessels in the company’s fleet fully and accurately reflect activities that must be recorded under International Convention for the Prevention of Pollution from Ships (MARPOL), Annex I.
2003-049 Ensure that crews aboard company ships are aware of their obligations under International Convention for the Prevention of Pollution from Ships (MARPOL), and that they are given the support necessary to meet those obligations.
2003-050 Emphasize the dangers of complacency during oil transfers to crews by publicizing lessons-learned from this spill throughout the company’s fleet.
2003-051 Undertake a special International Safety Management (ISM) Code audit to ensure {the company's} Safety Management System (SMS) is effective in light of the failures to conform to various standards, including the company’s own standards, found aboard the {ship}.
2003-052 Investigate, in cooperation with {the ship operator} and {the other Classification Society involved}, how the addition of the on-deck fuel oil piping for the forward fuel oil tank went undocumented in the ship’s fuel system diagrams.
2003-053 Investigate, in cooperation with {the ship operator}and {the other Classification Society involved}, how the addition of the on-deck fuel oil piping for the forward fuel oil tank went undocumented in the ship’s fuel system diagrams.
2003-059 Immediately undertake measures to ensure the {ship}, and other vessels in the {company's} fleet, conduct bunkering operations in compliance with Washington’s Safe Bunkering Procedures contained in Washington Administrative Code (WAC) 317-40.
2003-060 Ensure that the ship’s bunkering procedures clearly specify that the Person-in-Charge (PIC) of the operation is to have no other duties during the bunkering process.
2003-061 If using a vacuum truck for the transfer of fuel oil to the ship, consider additional precautions to offset the increase in risk posed by the potential addition of compressed air from the vacuum truck into the ship’s tanks (i.e. in additional to the required personnel for the transfer, add an additional deck rover watch).
2003-079 Ensure the company’s bunkering procedures and all federal and state regulations regarding bunkering and oil transfers are understood and complied with by the ship’s crew members.
2003-080 Ensure that crew members are given sufficient time off to get adequate rest prior to conducting bunkering procedures, that they understand the importance of adequate rest and the dangers of working while fatigued, that they comply with work hour limitations, and that sufficient personnel are available to allow for compliance.
2003-081 Ensure that work hour records are maintained up-to-date for all bunkering team members and that they accurately reflect the hours actually worked and rest periods.
2003-082 Consider taking additional precautions whenever the {ship} is bunkering to minimize the potential for spill (i.e. add additional personnel to monitor for spills during the transfer) and to minimize impact should a spill occur (i.e. routinely request that the ship be boomed prior to transfer and remain boomed throughout the transfer operation).
2003-083 Undertake a thorough review of the maintenance status of the {ship}, engaging both the deck and engineering departments in the review. Consider using the results of the review as the basis for a comprehensive planned maintenance program that: identifies critical systems and equipment; assesses the present condition of systems and equipment; identifies an appropriate maintenance interval; establishes a process for scheduling maintenance; creates a permanent record of maintenance accomplished; and, incorporates a mechanism for acting on unanticipated maintenance issues as they arise.
2003-084 Emphasize the dangers of complacency during oil transfers to crews by publicizing lessons-learned from this spill throughout the company’s fleet.
2001-003 Incorporate a second check of oil transfer system alignment, by a second qualified engineer, following changes to the system alignment.
2001-004 Ensure that oil transfer procedures include the requirement that fuel tanks already filled continue to be sounded for some time to ensure that tank levels do not change as additional fuel is transferred.
2001-010 Bring company vessels into compliance with Washington State Procedures for Safe Bunkering (Washington Administrative Code [WAC] 317-40).
2001-011 Update the ship’s Oil Transfer Procedures (OTPs) to comply with State and Federal regulations, and to ensure adequate deck containment for any oil spilled during fuel transfers.
2001-012 Ensure that all Persons-in-Charge are aware of the requirement to report all spills to State and Federal authorities.
2001-013 Ensure that any Person-in-Charge (PIC) has had adequate time to familiarize (or re-familiarize) themselves with the ship’s Oil Transfer Procedures (OTPs), fuel piping system, and fuel piping system status prior to undertaking an oil transfer.
2001-014 Ensure that personnel involved in an oil transfer are aware of, and fully understand, their duties and duty stations.
2001-015 Consider the installation of containment under the settling tank vent.
2001-016 Consider re-attaching the sight glass tops for the settling tank and lube oil tank back to the tanks to limit the potential for oil to spray/splash on hot equipment in case of a tank over-flow.
2001-059 Implement the Oil Transfer Procedures (OTPs) developed for the ship and approved by the U.S. Coast Guard.
2001-060 Ensure that Persons-in-Charge (PICs) are fully aware of their responsibilities under the new Oil Transfer Procedures (OTPs).
2001-061 Bring the ship into compliance with Washington’s Procedures for Safe Bunkering (Washington Administrative Code [WAC] 317-40).
2001-062 Bring the ship into compliance with Washington’s Contingency Planning requirements (Washington Administrative Code [WAC] 317-10).
2001-063 Ensure Persons-in-Charge (PICs) are trained in the use of their contingency plan and are aware of their responsibility to implement it in case of a spill.
2001-064 Ensure Persons-in-Charge (PICs) are aware of their responsibility to notify Washington State authorities (specifically Washington Emergency Management Division) in the event of a spill.
2001-065 Ensure tanks are sounded before, during, and after loading to confirm available tank capacity, transfer rate and remaining capacity, and a static tank condition, respectively.
2001-066 Avoid scheduling bunkering operations immediately upon arrival in port, especially following difficult sea passages and prolonged passages in pilotage waters, in order to allow the crew sufficient rest to comply with work hour restrictions.
2001-067 Incorporate good ergonomic principles, to the maximum extent possible, in ship system design decisions, and carefully consider the influence of design decisions on operations safety.
2000-060 Ensure that Persons-in-Charge (PICs) complete a pre-loading plan and comply with other federal and state regulations prior to bunkering.
2000-061 Provide the {ship} with tank sounding tables that allow for adjustment of tank capacity calculations for trim and list.
2000-062 Ensure that all Persons-in-Charge (PICs) understand the importance of taking soundings to determine remaining tank capacity, and that fuel metering systems are not a substitute for accurate tank sounding information.
1999-040 Ensure that work hour limitations are complied with, and that sufficient personnel are available to allow for compliance.
1999-041 Ensure that bunkering personnel understand the importance of following procedures, and do not become complacent about using standard checklists.
1999-042 When switching bunker tanks, ensure that tanks are sounded after being filled to confirm that oil is no longer flowing to them.
1999-043 Consider options for making the starboard diesel oil tank valve more accessible, or, at least, less likely to be overlooked.
1998-001 Ensure the company bunkering procedures, and all applicable regulations, are understood and complied with by ships’ crews and complied with.
1998-002 Ensure the Bunkering Procedures Manual is available on every company vessel and that the crew is familiar with it and its contents.
1998-003 Ensure crew members conduct soundings and record innages at regular intervals and use the information to calculate and record the rate of transfer. If the rate of transfer is unacceptable, crew members should be instructed to contact the delivering vessel or facility immediately.
1998-004 Emphasize teamwork during bunkering training to help maintain situational awareness.
1998-005 Emphasize the dangers of complacency during oil transfers to crews by publicizing lessons-learned from bunkering spills and near-spills.
1998-006 Ensure that all Persons-In-Charge (PICs) complete the Declaration of Inspection (DOI), not as a matter of routine, but as an important check on transfer readiness.
1998-007 Ensure that the crewmember tasked with controlling tank valves has an effective means of communication with the person on deck conducting soundings of tanks.
1998-008 Ensure that crew members are given sufficient time off to get adequate rest prior to conducting bunkering operations, and that they understand the importance of adequate rest and the dangers of working while fatigued.
1998-009 Ensure that spill investigators request drug and alcohol tests of involved personnel as soon as possible following a spill that has a potential to be a serious marine incident. [It was noted that no drug or alcohol tests were conducted following the spill in this case.]
1998-010 Consider modifying Washington Administrative Code [WAC] 317-40 to require that the Declaration of Inspection (DOI) is reviewed jointly, and re-initialed, by the receiving vessel and delivering vessel Persons-in -Charge (PICs) before each change of watch. Requiring such a meeting would provide a second opportunity for information exchange, ensure that personnel involved in the bunkering are introduced, and prevent miscommunication.
1998-011 Ensure crew members conduct bunkering operations in accordance with special instructions established by the Chief Engineer.
1998-012 Adopt a policy that requires a Person-in-Charge (PIC) coming on shift to personally check the transfer rate before taking over the transfer watch.
1998-013 Ensure that the crewmember designated as the deck-rover watch is equipped with a radio, is fully involved in the bunkering process, and understands the importance of his/her participation.
1998-014 Ensure that crew members are given sufficient time off to get adequate rest prior to conducting bunkering operations, and that they understand the importance of adequate rest and the dangers of working while fatigued. Consider the effect of changes in work / rest patterns on personnel assigned to the bunkering team.
1998-015 Consider modifying Washington Administrative Code (WAC) 317-40 to require that the Declaration of Inspection (DOI) is reviewed jointly, and re-initialed, by the receiving vessel and delivering vessel Persons-in-Charge (PICs) before each change of watch. Requiring such a meeting would provide a second opportunity for information exchange, ensure that personnel involved in the bunkering are introduced, and prevent miscommunication.
1998-024 Consider appropriate enforcement actions based on the violations of State and Federal regulations cited in this report.
1998-025 Following completion of any enforcement and Natural Resource Damage Assessment (NRDA) actions, consider publication of a Prevention Bulletin to publicize the lessons-learned from this spill.
1998-026 Adopt procedures to require that a tankerman coming on watch review and sign the Declaration of Inspection (DOI) with the receiving vessel’s Person-in-Charge (PIC) before taking over the transfer watch.
1998-027 Modify the company’s Oil Spill Prevention Plan, Chapter 3, to indicate that the “Fueling Precaution Guidelines” have replaced the “Safety Transfer Bunkering Procedures.”
1998-028 Ensure that any information provided to the ship explicitly states that transfer rates may vary from the agreed upon rate and that the receiving vessel should contact the tankerman immediately if they note any problem with the transfer rate.
1998-029 Ensure that any problems experienced with very-high frequency (VHF) radios used for transfer operations are reported and corrected promptly.
1998-030 Ensure tankermen take precautions to ensure at least one reliable means of being contacted by the vessel is always available.
1998-031 Emphasize the dangers of complacency during oil transfers to barge personnel by publicizing lessons-learned from bunkering spills and near-spills.
1998-032 Ensure the company’s Bunkering Procedures Manual and all federal and state regulations are understood and complied with by ship’s crews.
1998-033 Adopt a policy that requires a tankerman coming on shift review and sign the Declaration of Inspection (DOI) with the receiving vessel’s Person-in-Charge (PIC) before taking over the transfer watch.
1998-034 Adopt a policy that requires a tankerman coming on shift to personally check the transfer rate before taking over the transfer watch.
1998-035 Ensure that tankerman understand the importance of adequate rest and the dangers of working while fatigued. Consider the effect of changes in work / rest patterns on personnel assigned to bunkering operations, and endeavor to notify tankermen of upcoming bunkering assignments as early as possible to allow them to adjust their sleep schedule in advance.
1998-036 Publicize lessons-learned from this spill throughout the company’s fleet.
1998-037 Consider appropriate enforcement actions based on the violations of State and Federal regulations cited in this report.
1998-038 Ensure that the Chief Engineer is satisfied that the fill valve for number 4 port double bottom tank no longer leaks.
1998-039 Ensure that all tank vents match the piping color coding scheme posted aboard the ship.
1998-040 Place fixed containment beneath all fuel oil tank vents.
1998-041 Update the diagram of the ship's fuel oil system and ensure copies are available to the ship's crew.
1998-042 Update your oil transfer procedures to cover bunkering operations.
1998-043 Review your engineering policies to ensure they require the maintenance of complete and current documentation (diagrams and procedures) for all ship's systems.
1998-044 Examine your procedures for transferring oil (internal and over-the-rail) to ensure that tank vent containment is checked prior to transfers.

For additional information contact:  Michael Lynch, (360) 407-7482