Picture of the Month - May 2010 - "I think he missed the point of the point-of-transfer watch.”

An Ecology oil transfer inspector came upon this tranquil scene while conducting a bunkering inspection aboard a foreign ship that called in Washington.

The crew member’s face is blurred out in these photographs, but believe us, he was asleep. The Ecology inspector took some photographs, checked the paperwork, and in about four to five minutes, this point-of-transfer watch stander awoke and insisted he wasn’t asleep! The Ecology inspector told him it was his job to stay awake by doing things that keep him alert or to tell the Chief Engineer that he needed relief. The crew member gave an embarrassed smile.

The Ecology inspector then went to see the Chief Engineer and told him he had observed the sleeping point-of-transfer watch to which the Chief Engineer replied, “He wasn’t asleep.”

The Ecology inspector told the Chief and Second Engineers that their point-of-transfer watchman was on duty for almost six hours, which was a long time for any one task. The Ecology inspector also suggested it is a good idea to rotate crewmembers around so they do not get so bored. The Ecology inspector also suggested removing the chair at the point-of-transfer and having the deck-rover watch check more often on the point-of-transfer watch.

Washington Administrative Code (WAC) 317-40, “Bunkering Operations,” (pdf) requires a point-of-transfer watch during bunkering:

317-4-050 (4) Watchstanders. The vessel's oil transfer procedure must designate a point-of-transfer watch and a deck-rover watch. Each watch must be equipped with two-way communications to communicate with the person in charge and vessel master or officer in charge.
(a) A point-of-transfer watch must remain at the point of connection with the delivering vessel during bunkering.

The WAC also addresses crew work hours in order to help reduce fatigue during bunkering operations:

317-40-085 Work hours. Receiving and delivering vessel personnel involved in bunkering may not work more than 15 hours in any 24-hour period nor more than 36 hours in any 72-hour period except in an emergency or spill response operation. For purposes of this section, "emergency" means an unforeseen situation that poses an imminent threat to human safety, or the environment, or substantial loss of property.

Fatigue is a serious and all-too-common issue for the maritime industry and in one survey was a top concern of ship masters.

Ecology has attributed bunkering spills in Washington State to fatigued Chief Engineers or crew members making errors. Ecology inspectors have observed that the first order of business of some ships entering Washington State is bunkering. This occurs immediately after a lengthy transit from sea to a Washington port during which the Chief Engineer, the person most often in charge of the bunkering operation, is typically awake.

Ecology inspectors and investigators have encountered internationally-required (STCW) work hour log books that upon closer inspection and questioning clearly did not reflect the hours actually worked. Some Masters and Chief Engineers do not maintain a record of their work hours because of their operating company interpretation of the international requirement.

Ecology reminds ship owners and operators that Washington State’s bunkering requirements contain work hour limitations that will be checked during bunkering inspections. Likewise, Ecology inspectors will check work hour records during substantial risk inspections.

Oil spills are expensive. The Washington State Legislature increased the maximum allowable penalties for spills and maximum resource damage assessments. Ship owners and operators should ensure that their ship crews—including the Master and Chief Engineer—have opportunity to get adequate rest as insurance against oil spills caused by fatigue.