Gard personnel Satoru Yamashita, Senior Claims Executive, Tokyo, and Cheryl Acker, Senior Claims Executive, New York, present the following best practices in order to avoid liquid cargo contamination claims.
P&I Club, Gard, has handled a number of liquid cargo contamination claims arising from previous cargo residues. As a result of these cases and their experience Gard has issued some helpful advice and guidance to assist the industry to try and avoid future claims.
Liquid cargo contamination claims can be costly and Gard has seen cases arising when the last cargo onboard was coconut oil, palm oil, or other edible oils.
After cleaning the cargo system between cargoes in the above cases, surveyors for charterers/shippers attended the vessels at the load ports and passed the tanks fit to load. First foot samples were taken at the start of loading and did not reveal any visual indications of liquid cargo contamination at that time. The crew should be aware that inspections by third parties are not a reliable indication that the vessel’s complete cargo system is free of contaminants, even after cleaning to required standards.
When cleaning tanks and lines after carrying high melting point cargoes, such as vegetable/edible oils, hot water washing will often be required and the crew should ensure that the water is sufficiently warm. The time between discharge and cleaning as well as the ambient air temperatures experienced may be relevant factors.
Whatever the charterers instructions are with regard to cleaning, owners should make sure that it will be effective in removing previous cargo residues. Holding charterers responsible for a subsequent problem is far from straight-forward and owners will usually have a non-delegable duty to cargo interests to provide a cargo-worthy vessel.
There should be a vessel-specific line cleaning procedure for each stage of washing (e.g. cold-water wash, hot-water wash and chemical recirculation) as well as inspection procedures to ensure all relevant parts of the cargo system are properly inspected and cleaned. Vessel-specific procedures were found to be lacking in one of the above cases.
The crew should also be fully familiar with what is required for proper cleaning and inspection of the cargo system. In one of the above cases the crew had newly joined and were unfamiliar with the system. A written record of the cleaning performed should be kept.
Even after thorough cleaning, it remains important to perform a close-up inspection of tanks and lines to ensure no residues remain (always after following safe tank entry procedures).
It is possible that solidified/frozen residues will remain near the bends/elbows in lines, as well as in manifolds and crossovers. When cargo filtering was performed in the first case above, previous cargo residues were found in the manifold crossovers. Lines in these areas should be closely examined and opened up where possible to aid inspection. Other parts of the system, such as the heat exchangers in the second case, should also be sufficiently inspected. Checklists may help for conducting inspections, but whatever is used, a written record should be kept of inspections performed.
Cargo residues can exist as a film along the inner walls of pipelines, which may be difficult to spot in wet conditions. In dry conditions after ventilating for a couple of hours, the solid film should be more visible to the naked eye. Ideally, the inspection should be carried out during daylight for better visibility.
Photographic evidence of tanks/lines after cleaning can assist in defending a claim and protecting the member’s interests in the event of dispute.
Lines that will not be used for cargo operations should be properly isolated.
It is extremely important that the crew collect and retain samples during loading, including from the vessel’s manifolds after flushing through the sampling point, and from the cargo tanks at first-foot stages, as well as after completion of loading. This will provide evidence of the cargo’s condition throughout the loading operation. See this Gard Insight for further details on the importance of sampling liquid cargoes.
If any visible contamination of samples is noted during loading, operations should be suspended for investigation. If the cargo system does contain a contaminant, the quantity of cargo already loaded will be much less than for a full tank. The first indication of a problem from the shore side will usually be the vessel manifold samples and these should be taken at regular intervals during loading if there are any concerns with the quality of cargo. High melting point cargo residues can remain in sampling points which may contaminate the samples of cargoes next loaded. The crew should ensure that sampling points are thoroughly flushed through before collecting samples of the next loaded cargo.