Ecology Prevention Recommendations on Ship Bunkering (Fueling) Operations 1998-Present

Updated September 22, 2009

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
2009-016	Initiate an educational effort aimed at improving fishing vessel operators’ understanding and compliance with fuel oil piping testing requirements in 33 CFR 156.170. After an appropriate period of education, begin enforcing the requirements aboard vessels to which they apply.
2009-015	In light of the fact that neither the uninspected fishing vessel examination requirements in 46 CFR, nor the Coast Guard’s Alternative Compliance and Safety Agreement (ACSA) program, address inspection of fuel piping and other structures for excessive corrosion in spaces adjacent to the processing deck, it is recommended the Coast Guard specify these spaces for detailed periodic examination within the ACSA to prevent similar incidents from occurring on processing vessels subject to that program.
2009-014	Encourage your surveyors to locate and inspect corrosion prone areas and hard to inspect locations during inspections of fishing vessels.
2009-013	Add requirements for operators of fishing vessels classed by {classification society} to identify and document specific areas of corrosion concern, such as hard to inspect locations. Target these areas during {classification society} class inspections.
2009-012	{Classification Society} Work with {fishing vessel operator} to address the corrosion issues in the area below the processing deck aboard the {fishing vessel}.
2009-011	Annually test fuel transfer piping as described in 33 CFR 156.170.
2009-010	Work with {classification society} to address the corrosion issues in the area below the processing deck aboard the {fishing vessel}.
2009-009	Incorporate a check of the piping beneath the processing deck into an annual pre-season checklist for the {fishing vessel} in accordance with Navigation and Vessel Inspection Circular (NVIC) 5-86 recommendations.
2009-008	Identify any corrosion areas of concern aboard the {fishing vessel} based on operational experience and subject them to more frequent tests and inspections.
2009-007	Re-examine your planned maintenance program for the {fishing vessel} to ensure that all safety and oil handling systems and structures are regularly inspected and repaired.
2008-133	Ensure that tank truck Persons-in-charge document orders for pumping rate changes on the delivery paperwork (i.e. Declaration of Inspection, Freight Delivery Ticket) or in a log book.
2008-132	Ensure that all scuppers are adequately plugged and that all containments are intact.
2008-131	Ensure that tank locations and sequence of filling tanks are confirmed between the two Persons-in-charge and that they match the pre-load plan.
2008-130	Do not proceed with transfers unless all required items on the pre-load plan are filled out.
2008-129	Recommend that the {ship's operator's} procedures include a Declaration of Inspection checklist to be used by vessels for all bunkering operations.
2008-128	Recommend that orders for pumping rate changes be documented.
2008-127	Ensure that all bunker team members have adequate rest and are not fatigued prior to commencing bunkering operations. The numerous record-keeping errors associated with this bunkering, and subsequent spill, indicate the possibility that attention, alertness and situational awareness may have been compromised by fatigue factors.
2008-126	Ensure that work/rest hour records are accurately kept without discrepancies. Examination of Chief Mate work/rest records versus deck log book entries for watch standing and vessel evolutions do not match.
2008-125	Ensure that all documents are correctly filled out. The Declaration of Inspection had wrong names associated with the Chief Mate & Chief Engineer. The pre-load plan was missing sounding levels.
2008-124	Future internal investigation reports should include critical details such as specific locations of events, actions taken, and times for all activities. The vessel investigation statement and the Safety Management System Internal Investigation Report were cursory and lacked detail. The vessel statement was not dated.
2008-123	In the {ship's operator} Safety Management System Bunkering Procedures, create clear, practical guidance for monitoring and calculating tank levels and rates.
2008-122	Ensure all scuppers are fully and mechanically plugged prior to commencing bunkering operations.
2008-121	Consider fixed containment be installed (if possible) at the individual fuel tank fill stations. If fixed containment is not practical then devise a means of portable containment for the fill stations.
2008-120	While proper oil spill notifications were ultimately made through the agent, the notifications were not properly made per Washington State contingency plan requirements. Ensure that personnel aboard your vessels clearly understand the proper oil spill reporting requirements when in Washington waters.
2008-119	Ensure that the oil transfer procedures specify by position/title the duties of each person involved in fueling operations.
2008-118	Ensure that the names and positions of designated Persons-in-charge are filled out and are kept current in the oil transfer procedures.
2008-117	Ensure oil transfer procedures are updated when changes to the ship’s fueling configuration occur and when procedures for safer oil transfers are developed.
2008-116	Create written oil transfer procedures that meet Code of Federal Regulation (CFR) requirements for transferring petroleum products in the United States. Ensure those procedures provide detailed guidance to persons conducting oil transfers aboard the ship. Specifically, include the following guidance: 1.The topping-off and maximum safe fill levels for each fuel oil tank. 2.The maximum safe filling rate and safe topping-off rate for each fuel oil tank. 3.Any peculiarities of the fuel tanks, the associated filling or vent piping, and sounding tubes of which personnel should be aware. 4.A pre-loading plan form that includes the items contained in Washington Administrative Code (WAC) 317-40, and a requirement to complete all elements of the pre-loading plan before each oil transfer.
2008-115	Evaluate the Shipboard Oil Pollution Emergency Plan (SOPEP) response and drill procedures for a spill on deck. The bunker tank vents are amidships between the hatches. If a procedure and appropriate drill were developed to contain a tank vent overflow to the deck area between the hatches, this would reduce the likelihood of oil flowing out to the gunwale and into the water. Containing the oil there would also assist in recovering the oil through portable pump or scoop.
2008-114	Ensure full understanding and comprehension of the Safety Management System (SMS) by the engineering officers Ensure all engineering officers assigned to company vessels are fluent in English, OR Provide dual language version of SMS with English and Chinese language.
2008-113	Audit your ships on a regular basis to ensure actual use and compliance with the Safety Management System Bunker Checklist and oil transfer procedures.
2008-112	Review all "alternative measures" equipment and booming arrangements to ensure their adequacy to meet environmental conditions in the event an oil spill occurs above the safe and effective pre-booming threshold. Particular focus should be directed at those facilities and vessels that have an "oil transfer shutdown" threshold that exceeds their safe and effective thresholds (below which the operation should be pre-boomed). Effective alternative measures should provide protection to cover or mitigate this operational risk.
2008-111	Ensure that bunkering operations not conforming with the Bunkering Standard of Care are brought to the attention of the appropriate parties.
2008-110	The Coast Guard’s anchoring/bunkering regulations and the applicable Puget Sound Harbor Safety Plan Standards of Care should be reviewed for adequacy in consideration of the content of this report. Ensure the newly-revised Bunkering Standard of Care within the Puget Sound Harbor Safety Plan gets the maximum distribution possible.
2008-109	Undertake an inventory of critical deck equipment aboard your tugs and ensure that your planned inspection and maintenance program adequately addresses each piece of equipment identified as required by Section 10 of the International Safety Management Code.
2008-108	Commend the Captain of the {tug} for quickly asking for assistance once control of the barge was compromised and for making prompt notifications once the barge grounded.
2008-097	Follow up with {fuel truck operator} to ensure transfer Person-in-charge has access to clean up equipment in a timely manner without having to wait to unlock the equipment trailer.
2008-096	Ensure vessel inspectors are looking for containment under vents, and scuppers and freeing ports blocked, as per Washington Administrative Code (WAC 173-180-245). Inspectors should have procedures/policies to stop transfer operation if WAC 173-180 rules are not being followed.
2008-095	Consider expanding federal requirements for plugging overboard discharge points (scuppers and freeing ports) and providing fuel oil tank vent containment to vessels with an oil capacity of less than 10,500 gallons and to vessels of under 100 gross tons, respectively.
2008-094	Ensure that you comply with Washington’s requirement that delivering facilities using alternative measures have sufficient recovery equipment on site.
2008-093	Ensure that your crews are aware of and fully comply with Washington’s requirements for safe oil transfer.
2008-092	Revise your preloading plan so that it provides a column for starting and planned final sounding levels.
2008-091	Revise your Declaration of Inspection form so that it provides space for the initials of both Persons-in-charge for each item.
2008-090	Determine why the tank truck Person-in-charge allowed the transfer to go forward without providing containment for the {fishing vessel’s} fuel oil tank vents.
2008-089	Consider the trim of the vessel when fueling and lower the "fill to" mark on the sight glass.
2008-088	Verify the capacities of the fuel tanks and retain this information on board.
2008-087	Ensure that your crew members are aware of and fully comply with Washington’s requirements for safe oil transfer.
2008-086	Ensure that containment such as buckets or vent bags are available for use on the {fishing vessel’s} fuel oil tank vents.
2008-085	Ensure oil transfer procedures are updated when changes to the ship’s fueling configuration occur and when procedures for improving the safety of oil transfers are developed.
2008-084	Develop oil transfer procedures that include the elements listed in 33 Code of Federal Regulations (CFR) 155.750 and provide additional guidance to persons conducting oil transfers aboard the ship. At a minimum, include the following additional guidance to the oil transfer procedures: 1.The location of fuel oil tank vents and containment to be provided under each prior to the start of an oil transfer. 2.The location of scuppers and freeing ports, a requirement that they be plugged/blocked, and the method of plugging/blocking them. 3.The topping-off and maximum safe fill levels for each fuel oil tank. 4.The maximum filling rate and topping-off rate for each fuel oil tank. 5.A pre-loading plan form that includes the items contained in WAC 173-180-230, and a requirement to complete all elements of the pre-loading plan before each oil transfer.
2008-078	Ensure the {fishing vessel’s} procedures for readying the vessel for sea following a shipyard stay require the identification and inspection of watertight closures for integrity.
2008-077	Regularly audit the fueling operations of vessels in your fleet to ensure that Persons-in-charge are complying with the oil transfer procedures.
2008-076	Develop a means to close-off the {fishing vessel’s} freeing ports (scuppers) during fueling operations to prevent any spilled oil from reaching the water. Ensure those means are incorporated into the {fishing vessel’s} oil transfer procedures.
2008-075	Determine the safe fill level for each of the {fishing vessel’s} tanks and ensure these levels are reflected in the tug’s written oil transfer procedures. The maximum safe fill level of a fuel oil tank should not be exceeded.
2008-074	Revise your oil transfer procedures to require that vessel crews complete an accurate pre-loading plan, and follow the pre-loading plan unless there is an over-riding reason not to.
2008-073	Consider not allowing internal transfers to occur while bunkering/fueling is occurring, or requiring additional personnel assigned to the internal transfer.
2008-072	Take a lessons-learned approach to {ship's} tank arrangement. Determine if other vessels in {company's} fleet could have their overboard vents piped to overflow tanks.
2008-071	Require your vessels’ engineering crews to keep detailed hand-over notes, so that a vessel taken out of lay-up has historical notes on its operation that the new crew can refer to.
2008-070	Clarify your bunkering checklist to require the draining and plugging of all fuel tank vent containments, including those for fuel tanks not listed on the pre-load plan.
2008-069	Review your oil transfer procedures for internal oil transfers and determine if some of the requirements for external transfers should be applied to internal transfers. Examples include: sounding the tank you intend to transfer fuel to, plugging the containment and/or scuppers, filling out a pre-transfer checklist, and having a deck rover watch assigned.

2008-068	Ensure a person is specifically assigned as a deck rover to monitor the deck and vents for oil spills.
2008-067	Discuss the fuel oil system layouts of your tugs with the experienced captains and chief engineers in your fleet. If those discussions indicate that the locations of fuel oil tank valves make their operation difficult, consider modifications to make the valves more accessible.
2008-066	Regularly audit the fueling operations of tugs in your fleet to ensure that Persons-in-charge are complying with the oil transfer procedures.
2008-065	Develop a means to more completely close-off the {tug’s} freeing ports (scuppers) during fueling operations to prevent any spilled oil from reaching the water. Ensure those means are incorporated into the {tug’s} oil transfer procedures.
2008-064	Revise your oil transfer procedures to require that oil tanks already filled are monitored after the valves to them are closed to ensure the level does not change.
2008-063	Determine the safe fill level for each of the {tug's} tanks and ensure these levels are reflected in the tug’s written oil transfer procedures. The maximum safe fill level of a fuel oil tank should not be exceeded.
2008-062	Revise your oil transfer procedures to require that vessel crews complete an accurate pre-loading plan, and follow the pre-loading plan unless there is an over-riding reason not to.
2008-061	Investigate further why your Qualified Individual did not directly notify the Washington Emergency Management Division of the spill, and undertake corrective action.
2008-051	Consider prioritizing the {ship} for boarding when they enter their next U.S. port to examine the suitability of the tank gauging system as configured for the No. 3 fuel oil tanks and to verify operation of the overflow tank alarm.
2008-050	Consider prioritizing the {ship} for boarding should they bunker during their next Washington State port call. Verify operation of the overflow tank alarm before bunkering begins.
2008-049	Consider sending a letter commending the NRCES personnel for their actions with regard to their quick response to the oil spill.
2008-048	Consider sending a letter commending the tankerman-PIC for his actions with regard to this bunkering operation and the oil spill.
2008-047	Commend the tankerman-PIC for taking the time to ensure that the scuppers aboard the ship were plugged to his satisfaction prior to starting the pumps aboard the barge. This action may have prevented additional oil from entering the Columbia River.
2008-046	Commend the tankerman-PIC for being alert to the oil spilling from the ship’s deck and for his quick actions to shut down the transfer, to begin notifications, and to start cleanup.
2008-045	Review, with {ship's operator}, the installation of the magnetic tank level gauging system installed on the No. 3 fuel oil tanks in light of the spill and the sticking float. Help the company develop procedures to ensure the floats do not stick or, if one should stick, that the condition is quickly detected. Consider, with the company, modification of the gauging system to allow for heating of the fuel oil in the float housing to prevent the fuel oil from becoming too viscous for the float to operate.
2008-044	With {ship's operator}, investigate why the overflow tank alarm failed to sound prior to the spill. Ensure repairs, if necessary, are made and documented under your supervision.
2008-043	Emphasize the dangers of complacency during oil transfers by publicizing lessons-learned from this spill throughout the company’s fleet.
2008-042	Ensure crew members conduct soundings or take tank level readings 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.
2008-041	Review the installation of the magnetic tank level gauging system installed on the No. 3 fuel oil tanks with {classification society} in light of the spill and the sticking float. Develop procedures to ensure the floats do not stick or, if one should stick, that the condition is quickly detected. Consider modification of the gauging system to allow for heating of the fuel oil in the float housing to prevent the fuel oil from becoming too viscous for the float to operate.
2008-040	Add an item to the company’s bunkering checklist that requires the overflow tank alarm be tested prior to each bunkering and internal transfer operation.
2008-039	If it has not already been done, investigate further why the overflow tank alarm failed to sound prior to the spill. Ensure repairs, if necessary, are made, documented, and submitted to {classification society} for review and approval.
2008-038	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.
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