1

Report of the 2010 Concentrated Inspection Campaign

(CIC) on Tanker Damage Stability
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Executive Summary
Over recent years concern had been shown by several Paris MoU members that in some
cases tankers were not being loaded in compliance with IMO damage stability requirements,
which means that in the case of a collision or grounding the ship may not survive, resulting
in possible pollution or even loss of life.

It was decided to instigate a Concentrated Inspection Campaign (CIC) on tanker damage

stability in the Paris MoU region from the 1st September 2010 to 30th November 2010 to
evaluate the situation regarding tanker damage stability.

A CIC questionnaire was devised and was approved by the Paris MoU Port State Control
Committee. The intention of the questionnaire was to lead the Port State Control Officer
(PSCO) through a step-by-step process to establish whether the tanker complied with
damage stability in the loaded condition.

The CIC questionnaire was completed on a total of 1065 tankers (419 oil, 538 chemical and
108 gas tankers).

A total of 4 tankers were detained as a direct result of the CIC for not complying with
damage stability requirements. (2 oil tankers and 2 chemical tankers).

A total of 94 (8.8%) inspections resulted in deficiencies being recorded directly related to the
CIC

A total of 173 tankers, 16.2% (77 oil tankers, 84 chemical tankers and 12 gas tankers) could
not demonstrate that they were normally loaded in accordance with the Stability Information
Book (SIB).

This is a significant number of tankers that during a “spot check” could not show
compliance with stability requirements and thus may pose a risk to the
environment.

It may seem that only 4 detentions was a very small number, considering the number of
ships that could not show that they were loaded in compliance with their SIB. However, it
was agreed that during the CIC, detention was a last resort, and was only for cases where
the ship was loaded for the forthcoming voyage and could not show damage stability
compliance prior to departure. It may have been found that a ship had not complied with
damage stability on it’s previous voyage(s), thus detention would not be appropriate, a
deficiency would have been recorded including a link to ISM where appropriate

Prior to the start of the CIC the Paris MoU issued a press release to inform interested parties.
Due to the complex nature of the subject the CIC questionnaire and PSCO guidance was
placed on the Paris MoU website, along with Questions and Answers raised during the
internal PSCO training and from third parties such as ship owners and class (The Q&A’s are
attached in Annex 1.5). The questions caused some debate and it is felt that clarification is
required regarding application of tanker damage stability.
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Table of Contents
Page
Section 1: Introduction

1.1 Purpose of this Report ………………………………… 4

1.2 Objective of the CIC ………………………………… 4
1.3 Scope of the CIC ………………………………… 4
1.4 General Remarks ………………………………… 4

Section 2:Summary Analysis, Conclusions and Recommendations

2.1 Summary Analysis ………………………………… 5

2.2 Conclusions ………………………………… 5
2.3 Recommendations ………………………………… 5

Section 3: CIC Questionnaire Results

3.1 Summary ………………………… 6

3.2 Results of the CIC Questionnaire ………………………… 7
3.3 Analysis ………………………… 8
3.4 Specification of Related Deficiencies ………………………… 8
3.5 Analysis of CIC-topic Related Deficiencies ………………………… 9
3.6 Results by Ship Type ………………………… 9
3.7 Results by Ship Age ………………………… 10

Annex 1:
Annex 1.1CIC Inspection Questionnaire ………………….. 12
Annex 1.2 Additional Instructions for the CIC …………………… 13
Annex 1.3 Inspections and Detentions per Flag State …………………… 24
Annex 1.4 Inspections and Detentions Per Recognized …………………… 27
Organization
Annex 1.5 CIC Q&A’s 28
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SECTION 1
Introduction

1.1 Purpose of this Report

This report analyses the results from the CIC on tanker damage stability carried out in the Paris
MoU region between 1st September 2010 to 30th November 2010

1.2 Objective of the CIC

The objective of the CIC was to establish to what extent oil, gas and chemical tankers were
complying with the IMO requirements for damage stability from the respective conventions and
codes.

1.3 Scope of the CIC

The CIC applied to only oil, chemical and gas carriers and was carried out during a normal
targeted Port State Control (PSC) inspection. Tankers were not specifically targeted for inspection
simply to carry out the CIC. The intention was to carry out the CIC only once per ship during the
campaign. The concept of the CIC questionnaire was to make it as simple as possible for the
PSCO and to use a step by step approach, firstly establishing the basics, is there an approved
Stability Information Book (SIB) on board, is it in a language understood by the master and does
it cover damage stability. Next can the master demonstrate that the ship is normally loaded
according to damage stability requirements and finally how has the master verified that the ship
is loaded in accordance with damage stability requirements.

1.4 General Remarks

The CIC questionnaire and guidance was presented to several Paris MoU Technical Evaluation
Group (TEG) meetings and went through various iterations until the final version, that met the
approval of the TEG, was presented to the Paris MoU PSC Committee meeting in May 2010. Save
for a few minor comments and amendments the questionnaire and guidance was approved by the
Committee. Thus it was agreed to carry out the CIC for a three-month period staring 1st
September 2010. Two train-the-trainer sessions were carried out in the Hague for PSCOs’ in July
2010. The training raised several questions and a Q&A page was set up on the Paris MoU website.
Due to the complexity of this particular CIC the Paris MoU agreed to make public the CIC
questionnaire and guidance and the Q&As. (see Annex 1.5)

It has to be said that damage stability is a complex subject and that during the discussions at
TEG some members considered the CIC too complex and if it did go ahead felt it could only be
carried out by PSCOs with a specialist knowledge of damage stability. However it was decided if it
was so complex how did the master cope with this issue? It was agreed to try and simplify the
questionnaire so it could be carried out by any PSCO. It was not the intention that the PSCO
would carry out checks on damage stability by calculation, but simply to verify that the master
had considered damage stability.
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SECTION 2
Summary, Conclusions and Recommendations
2.1 Summary
The CIC questionnaire was undertaken on a total of 1065 tankers, 419 oil; 538 chemical
and 108 gas

4 ships (2 oil; 2 chemical), (0.35%) were detained as a direct result of the CIC

94 (8.8%) inspections resulted in deficiencies directly related to the CIC

6 ships (4 chemical tankers and 2 gas carriers) (0.56%) were recorded as not having an
approved Stability Information Book (SIB) on board.

2 ships (chemical tankers) (0.19%) did not have a SIB in a language that could be
understood by the master.

19 ships (8 oil tankers, 3 chemical tankers, and 8 gas carriers) (1.78%) were recorded as
having a SIB that did not cover damage stability.

173 ships (77 oil tankers, 84 chemical tankers and 12 gas carriers) (16.2%) could not
demonstrate that they were normally loaded in accordance the SIB

173 ships (67 oil tankers, 90 chemical tankers and 16 gas carriers) (16.2%) had an on-
board stability computer program that covered damage stability

127 ships (48 oil tankers, 71 chemical tankers and 8 gas carriers) (11.9%) used the on-
board computer program to verify the loading condition

2.2 Conclusions
The CIC showed that 16.2% of tankers inspected could not demonstrate compliance with
their Stability Information Book (SIB), this is a significant number of ships that appeared
not to be taking damage stability into account.

From the questions asked prior to and during the CIC there appears to be confusion
regarding the application of tanker damage stability

The deficiency codes used for the CIC did not relate directly to tanker damage stability.

2.3 Recommendations
2.3.1. Clear concise guidance regarding the application of damage stability to oil, gas and
chemical tankers to be provided by IMO and to indicate acceptable alternative
methods that can be used to show compliance with the stability requirements, other
than strict adherence to the standard loading conditions.

2.3.2. Guidance for PSCOs to be provided in the form of a PSC Committee Instruction for
continued monitoring of tanker damage stability during PSC inspections

2.3.3. New deficiency codes established relating directly to tanker damage stability such that
on-going statistics can be produced if necessary
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SECTION 3
CIC Questionnaire Results
3.1 Summary
The total number of ships inspected and the total number of inspections performed during
the CIC are presented in Table 1. The number of ships and the number of inspections are
different because some ships were inspected more than once during the CIC:

TABLE 1 Number of individual ships Number of Number of

inspected during CIC inspections inspections
performed with performed
a CIC without a CIC
questionnaire questionnaire
(Number of individual IMO
numbers)
Total 1,051 1,065 5,083

Detentions 14 N/A N/A

Detentions with CIC- 4 N/A N/A
topic related deficiencies

22 inspections were performed with CIC questionnaire on ship types that are in not the
limited target group of Chemical, Gas and Oil tankers. Those inspections are filtered out
and not included in this analysis and don’t belong to the 1,065 inspections in the table
above.

32 inspections were carried out on ship type “tanker” (defined in the Paris MoU as ship
carrying non hazardous, non-polluting liquids in bulk). When these ships were checked
they were confirmed to actually be oil, gas or chemical tankers and are included in the
1065 inspections

TABLE 2
Inspections during CIC campaign Number of ships % of total
1 1,051 98.69%
2 14 1.31%
Total 1,065 100.00%
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3.2 Results of the CIC Questionnaire

TABLE 3 YES NO N/A BLANK

Number % Number % Number % Number % Total

Q1 Does the ship have an approved stability information book (SIB)? 1,057 99.25% 6 0.56% 0 0.00% 2 0.19% 1,065

Q2 Is the SIB written in a language understood by the master? 1,058 99.34% 2 0.19% 0 0.00% 5 0.47% 1,065

Q3 Does the approved stability information cover damage conditions? 1,039 97.56% 19 1.78% 0 0.00% 7 0.66% 1,065

Q4 Can the master demonstrate that the ship is normally loaded in accordance
with the SIB? (If the answer is YES(A) then questions 5 to 9 should be answered 860 80.75% 173 16.24% 30 2.82% 2 0.19% 1,065
N/A)
Q5 Has the master verified an alternate loading condition by written authority
from flag/class? (Note: for oil tankers there is no option to obtain written authority
from flag/class on alternative loading conditions. Oil tankers shall always be loaded as 59 5.54% 134 12.58% 863 81.03% 9 0.85% 1,065
per approved condition in the stability book ) (If the answer is YES(A) then questions 6
to 9 should be answered N/A)
Q6 Has the master verified an alternate loading condition by assessing loaded
condition against critical damage KG data, included in the approved stability 85 7.98% 101 9.48% 867 81.41% 12 1.13% 1,065
information? (If the answer is YES(A) then questions 7 to 9 should be answered N/A)

Q7 Is there an on-board stability computer program that includes damage

173 16.24% 63 5.92% 812 76.24% 17 1.60% 1,065
stability?

Q8 Has the master verified an alternate loading condition by using the on-board
127 11.92% 56 5.26% 862 80.94% 20 1.88% 1,065
stability computer program for carrying out damage stability checks?

Q9 Was the ship detained as a result of this CIC? (A NO answer to questions 1,2
and-or 3, may result in detention) (A combination of NO answers to 4, 5, 6 and 8 may 21 1.97% 364 34.18% 667 62.63% 13 1.22% 1,065
also result in detention )

Detention data has been misrecorded, although according to questionnaire 21 ships were detained as a result of the CIC when this is analysed
only 4 ships were actually detained as a direct result of the CIC
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Chart 1

3.3 Analysis
The majority of tankers inspected under the CIC complied with the basic stability requirements,
Questions 1,2 and 3. However Question 4, regarding the master showing compliance with the
Stability Information Book (SIB), showed that in 173 cases (16.2%) the answer was “no”, the
master could not show compliance with the SIB in the loaded condition.

173 ships (16.24%) had a computer program that covered damage and in 127 (11.92%) cases
the computer program was used to calculate damage stability.

3.4 Specification of Related Deficiencies

TABLE 4 Inspections Detentions CIC-topic Detentions CIC-topic related
related with RO responsible
Numbers of (Number of inspections (Number of inspections with
inspections with with this deficiency this deficiency recorded as
this deficiency recorded as ground for ground for detention and RO
detention) related)
Deficiency 0120 Load Lines (including 1 1 0
exemptions)
Deficiency 0131 Liqufied Gases in 0 0 0
Bulk (CoF/GC Code, CoF/IGC Code)
Deficiency 0141 Dangerous 3 0 0
Chemicals in Bulk (CoF/BC Code,
CoF/IBC Code)
Deficiency 0150 Prevention of 16 0 0
Pollution by Oil (IOPP)
Deficiency 0930 46 2 0
Stability/Strength/loading information
and instruments
Deficiency 1199 Other (cargo) 2 0 0
Deficiency 1299 Other (load lines) 4 1 0
Deficiency 1799 Other (Marpol I) 13 2 0
Deficiency 1899 Other (Tankers) 16 1 0
Deficiency 2535 Development of 40 2 0
plans for shipboard operations
Total1 119 9 0
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Chart 2

3.5 Analysis of CIC-topic Related Deficiencies

The most common deficiency recorded was 0930 - Stability/Strength/loading information and
instruments (43 deficiencies) closely followed by 2535 - Development of plans for shipboard
operations (40 deficiencies), however there is no way of discerning whether the ISM deficiency
related directly to the CIC. The list of deficiencies that best related to the CIC were not
sufficiently detailed eg there was no deficiency directly related to damage stability. Perhaps
thought should be given to adding new deficiency codes for tanker damage stability.
There is a problem correlating the deficiencies to the actual CIC questionnaire, for instance in
some cases a question was answered “no” but there was no deficiency recorded. The CIC
guidance should be clear to the PSCO in that a “no” answer must result in the recording of a
deficiency.

3.6 Results by Ship Type

TABLE 5 Number of Inspections Detentions Detentions as Detentions Detentions CIC-

Ship type individual % of CIC-topic topic related as %
ships inspections related of inspections

Chemical
tankers 529 538 8 1.49% 2 0.37%
Gas carriers 107 108 1 0.93% 0 0.00%
Oil Tankers 415 419 5 1.19% 2 0.48%
Total 1,051 1,065 14 1.31% 4 0.38%

Chart 3
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3.7 Results by Ship Age

TABLE 6 Number of Number of Detentions Detentions Detentions Detentions
Ship age individual inspections as % of CIC-topic CIC-topic
ships inspections related related as %
of
inspections

< 6 years 361 365 3 0.82% 1 0.27%

6-11 years 341 344 2 0.58% 1 0.29%
12-17 years 161 161 3 1.86% 0 0.00%
18- 23 years 109 112 4 3.57% 1 0.89%
24- 29 years 42 43 2 4.65% 1 2.33%
30-35 years 20 21 0 0.00% 0 0.00%
>35 years 17 19 0 0.00% 0 0.00%
Total 1,051 1,065 14 1.31% 4 0.38%

It is interesting to note that the majority of tankers inspected were less than 11 years of age and
two out of the 4 detentions that were directly related to the CIC were on ships less than 11 years
of age. There is probably little correlation with age, as stability is more of an operational aspect.

Chart 4
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ANNEX 1
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Annex 1.1 CIC Inspection Questionnaire

TANKER DAMAGE STABILITY QUESTIONNAIRE
Name
IMO Number
Type: Gas, Chemical, Oil

No Question Yes No N/A

1 Does the ship have an approved stability information
book (SIB)?
2 Is the SIB written in a language understood by the
master?
3 Does the approved stability information cover
damage conditions?
4 Can the master demonstrate that the ship is normally
loaded in accordance with the SIB?1
5 Has the master verified an alternate loading
condition by written authority from flag/class?2 4
6 Has the master verified an alternate loading
condition by assessing loaded condition against
critical damage KG data, included in the approved
stability information?3
7 Is there an on-board stability computer program that
includes damage stability?
8 Has the master verified an alternate loading
condition by using the on-board stability computer
program for carrying out damage stability checks?

9 Was the ship detained as a result of this CIC?

1 If the answer to Qu 4 is “yes” Qus 5 – 9 should be answered “N/A”, if “no” move onto Qu 5
2 If the answer to Qu 5 is “yes” Qus 6 - 9 should be answered “N/A”, if “no” move onto Qu 6
3 If the answer to Qu 6 is ”yes” Qus 7 – 9 should be answered “N/A”, if “no” move onto Qu 7
4 Note: for oil tankers there is no option to obtain written authority from flag/class on alternative loading conditions. Oil
tankers shall always be loaded as per approved condition in the stability book.
A “no” answer to questions 1,2 and/or 3, may result in detention. A combination of “no” answers to 4, 5, 6 and 8 may
also result in detention. See attached guidance.
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Annex 1.2 Additional Instructions for the CIC

PARIS MOU CIC ON TANKER DAMAGE STABILITY

GUIDANCE NOTES

1. Purpose of this Questionnaire

The purpose of this questionnaire is:

• To gather information regarding the application of damage stability to tankers

• To ensure existing IMO instruments are enforced in a consistent manner

• To minimise risks to tankers and the seafarers who operate them

• To minimise risks to the environment from loss of marine pollutants

• To ensure non-compliant vessels are identified and brought into compliance

2. Guidance for Completing the Questionnaire

All questions should be answered with “yes”, “no” or “N/A” as appropriate.

The questionnaire is designed to lead the PSCO through the questions in a step-by-step approach
to establish if and how the master has taken into consideration damage stability.

The first three questions are to establish that the ship has stability information on board that is
understood by the master and relevant officers and that it includes damage stability.

Question 4 onwards is to establish if and how the master has ensured actual compliance with
damage stability requirements, either by loading the ship to known conditions (as per the SIB)
(Qu 4) or has written approval from flag/class to load outside these known conditions (Qu 5) or
has verified these alternate conditions using critical damage KG data (Qu 6) or finally used a
computer program to verify damage stability in the loaded condition (Qu 8).

Thus from question 4 onwards a “yes” answer means damage stability has been taken into
account and the remaining questions can be answered as “N/A”.

Enforcement: There may be situations where detention is warranted.

A “no” answer to Questions 1, 2 and/or 3 may result in detention as per normal PSC procedures.
However a combination of “no” answers to Questions 4, 5, 6 and 8 may also result in detention.

If the PSCO has proved conclusively that the ship is not loaded in compliance with damage
stability requirements in answering the questions and the ship is due to sail in that condition then
detention should be considered.

However, whether or not detention is appropriate there is a failure of the on-board SMS and this
should be recorded on the Report of Inspection either as a Non-conformity, Code 18 or a Major
Non-conformity, code 19 and code 30 Detention and use Deficiency code 2535:

Code 2535 - Sec 7 DEVELOPMENT OF PLANS FOR SHIPBOARD OPERATIONS - Incomplete

“The Company should establish procedures for the preparation of plans and instructions, including
checklists as appropriate, for key shipboard operations concerning the safety of the ship and the
prevention of pollution. The various tasks involved should be defined and assigned to qualified
personnel.”
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3. Guidance on the Questions

Qu 1. Does the ship have an approved stability information book (SIB)?

SOLAS Chapter II-1 Part B-1 Regulation 5-1 - Stability information to be supplied to the
master

“The master shall be supplied with such information satisfactory to the Administration as is
necessary to enable him by rapid and simple processes to obtain accurate guidance as to the
stability of the ship under varying conditions of service. A copy of the stability information shall
be furnished to the Administration.”

The International Convention on Load Line 69 Annex I Regulation II/10.3.(d) & (e)
states:
“(d) have such information* supplied for the use of its master as is necessary to enable
the master, by rapid and simple processes, to obtain accurate guidance as to the stability
of the ship under all conditions likely to be encountered in normal service; and
(e) carry on board at all times its approved stability information together with evidence
that the information has been approved by the Administration.”

The ship should be supplied with stability information approved by the flag State. This is
commonly provided by one of the Classification Societies who would stamp and date the book
with “[Approved on behalf of [flag State]”. In some cases the stability book may only have
provisional approval, which may be because a ship has recently changed flag or is a new ship.
This would be considered acceptable and the “yes” box should be ticked.

The SIB should cover intact and damage stability.

If there is no stability book on board or it does not at least have provisional approval the answer
to this question is “no”.
Although it would be unlikely that there would not be a SIB, if this was the case then the PSCO
should consider detention. (Use Sirenac Code 0930 “Stability/strength/loading information and
instrument” Convention references as above)

Qu 2. Is the SIB written in a language understood by the master?

It is possible to find that the SIB is not in the working language of the ship, possibly due
to change of flag etc. The SIB should at least be in English, French or Spanish or any
other language the Administration may require.

If the master confirms that he/she can understand the SIB answer “Yes”
If it is found that the SIB cannot be understood by the master the answer should be “No”.
If it is found that the master does not understand the SIB but a responsible officer (eg the
Chief Officer, who may have responsibility for loading) can understand the SIB the
question should still be answered “No”, as the master has overall responsibility.

If the answer is “No” then the PSCO should consider detention as the SOLAS and ILL
requirements as in Question 1 are not being met if the master cannot understand the SIB.

Ref. Res / Assembly / Res. A.749(18) Amended by Res.MSC.75(69)

Code on Intact Stability for all types of ships covered by IMO instruments
 15

2.1 Stability booklet

Amended by Resolution MSC.75(69) (adopted on 14 May 1998)

RECOMMENDS Governments to implement the annexed amendments to the IS Code.

"2.1.1 Stability data and associated plans should be drawn up in the working language of the ship
and any other language the Administration may require. Reference is also made to the
International Safety Management (ISM) Code, adopted by the Organization by resolution
A.741(18). All translations of the stability booklet should be approved.
2.1.2 Each ship should be provided with a stability booklet, approved by the Administration, *
which contains sufficient information to enable the master to operate the ship in compliance with
the applicable requirements contained in the Code. The Administration may have additional
requirements. On a mobile offshore drilling unit, the stability booklet may be referred to as an
operating manual. The stability booklet may include information on longitudinal strength. This
Code addresses only the stability-related contents of the booklet. "

Qu 3. Does the approved stability information cover damage conditions?

Oil Tankers:

Title MARPOL 04 Amend / I / Reg. 28

This regulation applies to every oil tanker of 150 gross tonnage and above delivered after
31 December 1979. Especially, paragraph 6 applies to oil tankers of 20,000 tonnes
Note
deadweight and above delivered on or after 6 July 1996. (This regulation enters into force
on 1 January 2007)
Regulation 28
Subdivision and damage stability
1 Every oil tanker delivered after 31 December 1979, as defined in regulation 1.28.2, of
150 gross tonnage and above, shall comply with the subdivision and damage stability
criteria as specified in paragraph 3 of this regulation, after the assumed side or bottom
damage as specified in paragraph 2 of this regulation, for any operating draught reflecting
actual partial or full load conditions consistent with trim and strength of the ship as well as
relative densities of the cargo. Note: Paragraph 2 has not been copied here as it relates to
the extent of the side and bottom damage.

Chemical Tankers:

Title IBC 83 IBC / II / 2.1

For Ships Constructed From 1-7-1986 Up to 1-1-2007
CHAPTER 2 - SHIP SURVIVAL CAPABILITY * AND LOCATION OF CARGO TANKS
* Reference is made to the Guidelines for the Uniform Application of the Survival
Requirements of the Bulk Chemical Code and the Gas Carrier Code.
2.1 General
2.1.1 Ships subject to the Code should survive the normal effects of flooding following assumed
hull damage caused by some external force. In addition, to safeguard the ship and the
environment, the cargo tanks of certain types of ships should be protected from penetration in
the case of minor damage to the ship resulting, for example, from contact with a jetty or tug, and
given a measure of protection from damage in the case of collision or stranding, by locating them
at specified minimum distances inboard from the ship's shell plating. Both the damage to be
assumed and the proximity of the cargo tanks to the ship's shell should be dependent upon the
degree of hazard presented by the products to be carried.

Gas Tankers:
 16

Title IGC 83/90 Amend / II / 2.1

For Ships Constructed From 1-7-1986
CHAPTER 2 - SHIP SURVIVAL CAPABILITY* AND LOCATION OF CARGO TANKS
* Reference is made to the Guidelines for Uniform Application of the Survival
Requirements of the Bulk Chemical Code and the Gas Carrier Codes, set out in the
Appendix.
2.1 General
2.1.1 Ships subject to this Chapter should survive the normal effects of flooding following
assumed hull damage caused by some external force. In addition, to safeguard the ship and the
environment, the cargo tanks should be protected from penetration in the case of minor damage
to the ship resulting, for example, from contact with a jetty or tug, and given a measure of
protection from damage in the case of collision or stranding, by locating them at specified
minimum distances inboard from the ship's shell plating. Both the damage to be assumed and the
proximity of the tanks to the ship's shell should be dependent upon the degree of hazard
presented by the product to be carried.

Also, IGC and IBC Certificates of Fitness states:

“That the ship must be loaded:

.1 in accordance with the loading conditions provided in the approved loading manual,
stamped and dated and signed by a responsible officer of the Administration, or of an
organization recognized by the Administration (RO)

General

In some cases the approved SIB will include approved damage calculations which demonstrate
damage stability compliance for each condition of loading if the ship suffers side or bottom
damage. However, most tankers will have separate damage stability information with approved
calculations for each intact condition of loading from the SIB if the ship suffers side or bottom
damage.

The important criteria here is that all the “standard” loading conditions in the approved stability
information should have been verified for damage stability compliance.

In some cases where there is no separate damage stability calculation and no damage results in
the stability information, the only indication that the damage stability has been assessed is the
fact that the stability information is stamped as complying with Marpol, which is then taken to
imply that damage has been covered. A separate approved damage calculation is not a
mandatory requirement.

If there is approved documentation on board which demonstrates that the loading conditions
included in the SIB also meet damage stability then the answer to this question is “yes”.

If there is no approved damage stability information on board the answer will be “no”.

This means that the ship is unlikely to comply with damage stability requirements of MARPOL, for
oil tankers and IGC and IBC Code for gas and chemical tankers and the PSCO should consider
detention.
(Use deficiency code 1899 – Other tankers. Convention Ref: for oil tankers MARPOL ANNEX I
Regulation 28(5); gas tanker IGC Code Chap 2; chemical tanker IBC Code Chap 2)

Qu 4. Can the master demonstrate that the ship is normally loaded in accordance with
the SIB?
 17

The master should be able to demonstrate that the loaded condition of the ship always
complies with an approved condition of loading from the SIB and therefore has intact and
damage stability approval. If this is the case answer “yes” and the rest of the questions
will be “N/A” as the master is fully complying with damage stability requirements.

A sailing condition is deemed to be approved IF the filling of each cargo and ballast tank
lies within 1% of the weight in the approved condition AND GMf lies within 2 cm of the
approved condition GMf

However if the answer is “no” the master needs to show how the ship is able to comply
with damage stability requirements by continuing with the questionnaire.

Qu 5. Has the master verified an alternate loading condition by written authority from
flag/class?

Where the master has not loaded the ship as per an approved condition in the stability
book, (as per Qu 4), for gas carriers and chemical tankers it is permissible to obtain
written authority from flag/class that this alternative loading condition is acceptable.

For oil tankers there is no option to obtain written authority from flag/class on alternative
loading conditions. Oil tankers shall always be loaded as per approved condition in the
stability book.

Gas carriers and Chemical tankers

Gas tankers and Chemical tankers are very clear on this issue and on the Certificate of
Fitness it states:

“Where it is required to load the ship other than in accordance with the above instruction,
then the necessary calculations to justify the proposed loading conditions should be
communicated to the certifying Administration who may authorise in writing the
adoption of the proposed loading conditions.”

If this option has been used and the master can show written authority the answer to this
question is “yes” and the rest of the questions will be “N/A” as it has been established that
the master is complying with the damage stability requirements.

If the answer is “no” the master needs to show that another acceptable alternative
method to verify compliance with damage stability has been used by continuing with the
questionnaire Q6.

Oil tankers
However for oil tankers this is not so clear. MARPOL Annex I Regulation 28 (1) on
Subdivision and damage stability simply states:
“Every oil tanker delivered after 31 December 1979, as defined in regulation 1.28.2, of
150 gross tonnage and above, shall comply with the subdivision and damage stability
criteria as specified in paragraph 3 of this regulation, after the assumed side or bottom
damage as specified in paragraph 2 of this regulation, for any operating draught reflecting
actual partial or full load conditions consistent with trim and strength of the ship as well as
relative densities of the cargo.”

Oil tankers shall always be loaded as per approved condition in the stability book. The
answer is “N/A” in case of an oil tanker. Continue with Q7.
 18

Qu 6. Has the master verified an alternate loading condition by assessing loaded

condition against critical damage KG data, included in the approved stability
information?

It is also permissible for the master to assess an alternate loading condition by referring to
critical damage KG or GM data in the approved Stability Information Book. If this option
has been used the answer to this question is “yes” and the rest of the questions will be
“N/A”.

However, the answer “yes” is also conditional upon the critical data being presented in a
clear manner and with sufficient guidance to ensure it is being correctly applied. If critical
data is being used outside the boundaries used to derive them, or are not used due to
insufficient guidance, the answer to this question should be given as “no”.

If the answer is “no” the master needs to show that another acceptable alternative
method to verify compliance has been used by continuing with the questionnaire.

Qu 7. Is there an on-board stability computer program that covers damage stability?

The most reliable method for verifying alternate loading conditions is the use of an
approved stability program or loading instrument. Most loading instruments will undertake
longitudinal strength calculations to Class requirements for any loading condition and most
will also verify intact stability compliance. Damage stability verification is not commonly
included in such instruments.

Where the master has not loaded the ship as per an approved condition in the stability
book and has used an on-board stability program to verify stability compliance he/she
needs to confirm the stability program covers damage stability. If the answer to this
question is “yes” then move on to the next question.

If it is confirmed that the on-board stability program does not undertake damage stability
then the answer is “no”. The master probably does not have an approved alternate
way to assess damage stability. Question 8 should also be recorded as “no”.

If the result of the above shows that it appears that the master/owner does not take into
account damage stability for the ship then they are not complying with the requirements
of MARPOL, IGC Code or IGC Code.
It needs to be pointed out to the master that from the information obtained from
completing the questionnaire the ship is not complying with damage stability
requirements.

It depends on the situation as to whether detention should be considered, if the ship is

loading and it is obvious the it is going to depart without considering damage stability then
the ship should be prevented from sailing until the situation is resolved, either loading to a
known condition from the SIB or written approval from flag/class that the loaded condition
is acceptable. Detention should be considered.
If the situation is that the ship is discharging and it hasn’t met the damage stability
requirements for the previous voyage then detention is not really an option. However it
should be recorded as a deficiency and followed up with flag/RO. It should also be
recorded as an ISM deficiency under 1.2.3 of the Code - 1.2.3 “The safety and
management system should ensure: .1 compliance with mandatory rules and regulations”

If the results of the questionnaire reveal that the master/owner regularly do not comply
with damage stability then this should be recorded as a deficiency and followed up with
the flag/RO as above.
 19

Qu 8. Has the master verified an alternate loading condition by using an on-board

stability computer program for carrying out stability checks?

Can the master confirm that a stability program provided to verify damage stability is
being used for this purpose, by retaining a printout showing the loaded condition and
confirmation of compliance. If the answer is “yes” it may be concluded that the master
has taken damage stability into account.

If the answer is “no” this means that there is a means on board for verifying damage
stability but the master has chosen not to verify damage stability. Detention
should be considered as per Qu 7

Qu 9 Was the ship detained as a result of this CIC?

If it is proved conclusively that the ship does not comply with the requirements of damage
stability then the answer should be “Yes”. If the ship is detained for other reasons then the
answer is “No”. If the ships is not detained for any reason then the answer should be
“N/A”

Abbreviations:

SIB: Approved Stability Information Booklet

IBC Code: International Code for the Construction and Equipment of Ships carrying Dangerous
Chemicals in Bulk . Carriage of chemicals in bulk is covered by regulations in SOLAS
Chapter VII - Carriage of dangerous goods and MARPOL Annex II - Regulations for the
Control of Pollution by Noxious Liquid Substances in Bulk. Both Conventions require
chemical tankers built after 1 July 1986 to comply with the International Code for the
Construction and Equipment of Ships carrying Dangerous Chemicals in Bulk
IGC Code: The International Code for the Construction and Equipment of Ships Carrying Liquefied
Gases in Bulk. Applies to gas carriers constructed on or after 1 July 1986. Gas carriers
constructed before that date should comply with the requirements of the Code for the
Construction and Equipment of Ships Carrying Liquefied Gases in Bulk or the Code for
Existing Ships Carrying Liquefied Gases in Bulk.
KG: Distance from Centre of Gravity to Keel
GM: Distance between Centre of Gravity and Metacentre

Annex I (of guidance)

TANKER DAMAGE STABILITY BACKGROUND INFORMATION

All ships must comply with longitudinal strength, intact stability and damage stability
requirements. For tankers (oil, gas, chemical) they must comply with the following mandatory
instruments:

Longitudinal Strength – Load Line ILLC Annex I, Chap I, Reg 1 Strength of Hull
Intact Stability – Load Line/MARPOL. ILLC, Chap I “The Regulations also assume that
where there are international requirements relating to stability or subdivision, these
requirements have been complied with.”

Damage Stability – Oil Tankers MARPOL Annex I Reg 28

 20

Gas Tankers IGC Code Chap 2

Chemical Tankers IBC Code Chap 2

Basic pre-departure checks should ensure compliance with the above.

Typical stability approval at build comprises intact and damage stability:

Approved Intact Stability Information Book (SIB)

• Contains sample intact loading conditions
• On approval, these intact loading conditions are themselves deemed to be “approved” for
use
• Normally this will only demonstrate that the approved intact loading conditions will
survive the extent of damage required by the applicable Convention (MARPOL) or Code
(IGC, IBC) and achieve the minimum residual stability standard.
• Occasionally the damage stability submission will take the form of critical KG or GM data
which are intended to permit any condition of loading (including those in the SIB) to be
assessed against pre-determined tables. Where such data is provided it is essential that
their correct usage should be explained, particularly in relation to any assumptions used in
their preparation which must also be met when loading the vessel. Minimum tank fillings
for example.

Every tanker should have approved stability information on-board which details intact loading
conditions and damage calculations for different conditions of loading and should have relevant
certification:

Oil Tankers – IOPP Certificate and Form B

Gas Tankers – Certificate of Fitness
Chemical Tankers – Certificate of Fitness

Marpol Annex 1, reg 28(1) states:

“Every oil tanker delivered after 31 December 1979, as defined in regulation 1.28.2, of 150 gross
tonnage and above, shall comply with the subdivision and damage stability criteria as specified
in paragraph 3 of this regulation, after the assumed side or bottom damage as specified in
paragraph 2 of this regulation, for any operating draught reflecting actual partial or full
load conditions consistent with trim and strength of the ship as well as relative
densities of the cargo.”

With regard to the term ‘‘any operating draught reflecting actual partial or full load conditions’’,
the information required should enable the damage stability to be assessed under conditions the
same as or similar to those under which the ship is expected to operate.

MARPOL Annex I, Reg 28(5) states:

The master of every oil tanker to which this regulation applies and the person in charge of a non-
self-propelled oil tanker to which this regulation applies shall be supplied in a approved form with:

.1 information relative to loading and distribution of cargo necessary to ensure

compliance with the provisions of this regulation; and
.2 data on the ability of the ship to comply with damage stability criteria as
determined by this regulation, including the effect of relaxations that may have
been allowed under subparagraph 1.3 of this regulation.

IGC and IBC Certificates of Fitness states:

“That the ship must be loaded:

 21

.1 in accordance with the loading conditions provided in the approved loading manual,
stamped and dated ............................................................. and signed by a responsible
officer of the Administration, or of an organization recognized by the Administration(RO); or

.2 in accordance with the loading limitations appended to this Certificate.

Where it is required to load the ship other than in accordance with the above
instruction, then the necessary calculations to justify the proposed loading conditions
should be communicated to the certifying Administration who may authorize in writing
the adoption of the proposed loading condition.

In the majority of cases this approach is therefore conditional upon the assumption there is no
significant variation in the following parameters in the loaded vessel, otherwise damage results
may be adversely affected and a full check of the loading condition would be required for damage
stability:

• Cargo SG
• Draught and or Trim
• Slack/Empty Cargo Tanks
• Cargo or Ballast Distribution
• Use of Deck Tanks

Variation in Loading

This may be of little significance on a VLCC fulfilling a long term charter where it usually carries a
full cargo with the same SG in every tank, but it could prove problematic for a small coastal
parcel tanker where tanks are loaded to different levels with cargoes of different SG.

It is often considered that alternate loading conditions are acceptable where these do not vary
‘significantly’ from the approved intact loading conditions, but there is no safe basis for this
conclusion unless such variation is controlled. (Note “significant variation” is deemed to be IF the
filling of each cargo and ballast tank lies within 1% of the weight in the approved condition AND
GMf lies within 2 cm of the approved condition GMf

Depending on the shipyard the loading conditions for damage stability may or may not be
comprehensive, it may be a brief document with only a few loading conditions or it may be a
comprehensive document with many permutations of loading conditions.

Thus, there are specific approved loading conditions, as documented in the Stability Information
Book (SIB), and if the ship is loaded outside these conditions then:

• the alternate loading condition must be authorised by the certifying Administration, or

• the alternate loading condition must be assessed against critical damage KG data included
in the approved stability information, or
• the alternate loading condition must be assessed using an on-board damage stability
program

In reality the first 2 bullets above would be unlikely in practice and the third bullet offers the most
reliable way of ensuring compliance with damage stability if the ship is loaded outside the
approved loading conditions,

There are 3 types of stability program under IACS URL5 – “Onboard Computers for Stability
Calculations”, Type 1: Software calculating intact stability only (for vessels not required to meet a
damage stability criterion)
Type 2: Software calculating intact stability and checking damage stability on basis of a limit
curve (typically for vessels applicable to SOLAS Part B-1 damage stability calculations, etc.) or
previously approved loading conditions and
 22

Type 3: Software calculating intact stability and damage stability by direct application of
preprogrammed damage cases for each loading condition (for some tankers etc.)

Only Type 2 and Type 3 programs can both be used for ensuring compliance with damage
stability for each condition of loading, but Type 3 programs are more suited to verification of tank
vessels.

The documentation required to demonstrate adequacy of damage stability verification on tankers

could be any one of the following :

1. Permanent record that an alternate loading condition has been assessed against critical
damage KG/GM data included in the approved stability information, ie a record of the checks
made using a standard calculation sheet or a copy of the critical KG/GM data with the operational
conditions spotted on, or

2. Written authorisation stating that the that an alternate loading condition is authorised by the
certifying Administration (or an appointed certifying authority acting on its behalf), ie an
endorsement that the proposed sailing condition (which is not included in the SIB) has been
separately assessed and found to comply, or

3. Permanent record that the vessel is loaded in accordance with an approved loading condition,
to fulfil this option there would require to be limits set by the company or the Administration
within which the actual condition should lie relative to the standard condition, or

4. Permanent record that an alternate loading condition has been verified using an on-board
damage stability program. ie A printout retained on board which shows that the condition has
been assessed and complies. This option requires that the program in use is approved, noting
that the program may calculate stability directly (by applying all statutory damages) or use
critical KG/GM curves stored within the program.

4.1 There is no flag State requirement for approval of any form of stability computer program,
the use of onboard computers is not a requirement. The same applies to class, the use of
computers is not a requirement. However, a stability software installed onboard shall cover all
stability requirements applicable to the type of ship, thus for tankers it should include damage
stability.

4.2 For Classification Societies that are IACS members they should comply with IACS Unified
Requirement (UR) L5 “Onboard Computers for Stability Calculations”. UR L5 requires only
software approval, not hardware approval. UR L5 includes: calculation systems; types of stability
software (Types 1,2 or 3); functional requirements; acceptable tolerances; approval procedure;
operation manual; installation testing; and importantly periodical testing. It is the responsibility of
the master to check the accuracy of the system at each annual survey by applying at least one
approved test condition.

4.3 There are 3 types of stability program under UR L5:

Type 1: Software calculating intact stability only (for vessels not required to meet a
damage stability criterion)
Type 2: Software calculating intact stability and checking damage stability on basis of a
limit curve (typically for vessels applicable to SOLAS Part B-1 damage stability
calculations, etc.) or previously approved loading conditions and,
Type 3: Software calculating intact stability and damage stability by direct application of
pre-programmed damage cases for each loading condition (for some tankers etc.)

Only Type 2 and Type 3 programs can be used for ensuring compliance with
damage stability for each condition of loading, but Type 3 programs are more
suited to verification of tankers.
 23

4.4 It is common for programs to be approved for only some of the operations they perform.
So it is not unusual to find a program which assesses damage to be approved only for intact
stability, or for a program which verifies intact stability to be approved for longitudinal strength
only.

These are the only four options available to demonstrate compliance with any form of damage
stability requirement. The generally accepted method for demonstrating stability compliance on
SOLAS ships is option 1, noting that this can be used to show both intact and/or damage stability
compliance.

The actual statutory provisions that apply in any particular case will be stated in the original
stability approval documentation and stability information, noting that these can vary (or even
become non-applicable) depending upon the cargo which is being carried at the time.

The general rule is that any vessel operating under Marpol, IBC or IGC certification must be able
to meet the damage requirement that applies to it and it is up to the loading officer and master to
demonstrate, through one of the four options above, that this has been duly verified.

Masters and Owners Responsibilities

• SOLAS Reg 22.1 & 25-8 –(where MARPOL/IBC/IGC does not apply)…The master shall be
supplied with such information satisfactory to the Administration as is necessary to enable
him by rapid and simple processes to obtain accurate guidance as to the stability of the
ship under varying conditions of service…”

• MARPOL – Annex 1 – Reg 28.5 “The master of every oil tanker…shall be supplied in an
approved form with; information relative to loading and distribution of cargo necessary to
ensure compliance with the provisions of this regulation….”

• IBC Code - 2.2.5 (IGC Code has similar requirement). The master of the ship shall be
supplied with a loading and stability information booklet. This booklet shall contain details
of typical service and ballast conditions, provisions for evaluating other conditions of
loading and a summary of the ship’s survival capabilities. In addition, the booklet shall
contain sufficient information to enable the master to load and operate the ship in a safe
and seaworthy manner.

Conclusion

Tankers should be loaded to ensure compliance with intact and damage stability requirements.
The SIB contains some loading conditions verified to ensure that the ship will survive bottom or
side damage as per the applicable requirements of either MARPOL/IBC/IGC Codes depending on
the type of ship.

If the ship is loaded outside these conditions then the master needs to be able to
demonstrate that the ship will still survive damage, ideally this would be proved using
the printout from a stability program that includes damage.

Annex 1.3 Inspections and Detentions per Flag State

 24

Table 7 Number Inspections Detentions Detention Detentions Detentions BGW

of as a % of CIC-topic CIC-topic list*
individual inspections related related as
ships % of
inspections

Flag

Algeria 2 2 0 0.00% 0 0.00% Grey list

Antigua and 6 6 0 0.00% 0 0.00% White

Barbuda list
Bahamas 67 68 0 0.00% 0 0.00% White
list
Barbados 2 2 0 0.00% 0 0.00% White
list
Belgium 4 4 0 0.00% 0 0.00% White
list
Bermuda. UK 2 2 0 0.00% 0 0.00% White
list
Bulgaria 1 1 0 0.00% 0 0.00% Grey list

Cambodia 1 1 0 0.00% 0 0.00% Black list

(hr)
Cayman Island, UK 11 11 0 0.00% 0 0.00% White
list
China 6 6 0 0.00% 0 0.00% White
list
Croatia 3 3 0 0.00% 0 0.00% White
list
Curacao 1 1 0 0.00% 0 0.00% Grey list

Cyprus 34 34 0 0.00% 0 0.00% White

list
Denmark 34 34 0 0.00% 0 0.00% White
list
Dominica 1 1 0 0.00% 0 0.00% Black list
(mr)
Estonia 1 1 0 0.00% 0 0.00% White
list
Faroe Islands 1 1 0 0.00% 0 0.00% Grey list

Finland 5 5 0 0.00% 0 0.00% White

list
France 6 6 0 0.00% 0 0.00% White
list
Georgia 2 2 0 0.00% 0 0.00% Black list
(hr)
Germany 17 17 0 0.00% 0 0.00% White
list
Gibraltar, UK 26 26 1 3.85% 1 3.85% White
list
Greece 44 44 1 2.27% 1 2.27% White
list
Hong Kong, China 19 19 0 0.00% 0 0.00% White
list
India 6 6 0 0.00% 0 0.00% White
list
Ireland 1 1 0 0.00% 0 0.00% White
list
Italy 47 49 0 0.00% 0 0.00% White
list
Kuwait 2 2 0 0.00% 0 0.00% Not
classified
Latvia 1 1 0 0.00% 0 0.00% Grey list

Table 7 Number Inspections Detentions Detention Detentions Detentions BGW

of as a % of CIC-topic CIC-topic list*
individual inspections related related as
ships % of
inspections
 25

Liberia 109 110 2 1.82% 0 0.00% White

list
Luxembourg 4 4 0 0.00% 0 0.00% White
list
Malaysia 6 6 0 0.00% 0 0.00% Grey list

Malta 114 116 3 2.59% 2 1.72% White

list
Man, Isle of, UK 26 27 0 0.00% 0 0.00% White
list
Marshall Islands 89 89 1 1.12% 0 0.00% White
list
Netherlands 29 30 0 0.00% 0 0.00% White
list
Norway 58 58 1 1.72% 0 0.00% White
list
Panama 76 77 0 0.00% 0 0.00% Grey list

Philippines 2 2 0 0.00% 0 0.00% White

list
Poland 3 3 0 0.00% 0 0.00% White
list
Portugal 9 9 0 0.00% 0 0.00% White
list
Quatar 3 3 0 0.00% 0 0.00% White
list
Romania 1 1 0 0.00% 0 0.00% Not
classified
Russian Federation 9 9 0 0.00% 0 0.00% White
list
Saudi Arabia 2 2 0 0.00% 0 0.00% Grey list

Seychelles 2 2 0 0.00% 0 0.00% Not

classified
Sierra Leone 2 2 0 0.00% 0 0.00% Black list
(vhr)
Singapore 59 60 3 5.00% 0 0.00% White
list
Spain 4 4 0 0.00% 0 0.00% White
list
St Vincent and the 1 2 0 0.00% 0 0.00% Black list
Grenadines (mr)
St. Kitts and Nevis 3 3 0 0.00% 0 0.00% Black list
(mthr)
Sweden 11 11 0 0.00% 0 0.00% White
list
Switzerland 1 1 0 0.00% 0 0.00% Grey list

Tunisia 1 1 0 0.00% 0 0.00% Grey list

Turkey 38 40 1 2.50% 0 0.00% White

list
Tuvalu 1 1 0 0.00% 0 0.00% Grey list

Ukraine 1 1 0 0.00% 0 0.00% Black list

(mr)
United Kingdom 31 31 1 3.23% 0 0.00% White
list
United States of 1 1 0 0.00% 0 0.00% Grey list
America.
Vanuatu 1 1 0 0.00% 0 0.00% Grey list

Viet Nam 1 1 0 0.00% 0 0.00% Black list

(mthr)
Total 1,051 1,064 14 1.32% 4 0.38%

The official BGW-list of ParisMoU is published in the annual report. The scope of this table is only the CIC.
 26

Table 8 Inspections Inspections CIC detentions Inspectio Percentage Percentage Percentage

BGW with ns with CIC inspections detentions
deficiencies def % detentions
per
inspection
Black list (hr) 3 3 0 100.00% 0.00% 0.28% 0.00%

Black list (mr) 4 3 0 75.00% 0.00% 0.38% 0.00%

Black list 4 3 0 75.00% 0.00% 0.38% 0.00%
(mthr)
Black list (vhr) 2 2 0 100.00% 0.00% 0.19% 0.00%

Grey list 96 30 0 31.25% 0.00% 9.01% 0.00%

Not Classified 5 1 0 20.00% 0.00% 0.47% 0.00%

White list 951 365 4 38.38% 0.42% 89.30% 100.00%

Total 1,065 407 4 38.22% 0.38% 100.00% 100.00%

 27

Annex 1.4 Inspections and Detentions per Recognized

Organization
Table 9 Inspection Detentions CIC-topic
Issuing authority related with RO
responsibility
Number of inspections where the certificate is recorded as issued Number of inspections
by the RO where the RO issued
the certificate related
to CIC-topic and a
deficiency covered by
that certificate was
recorded as detainable
and RO relate
Liguiefied Dangerous Prevention of
Loadlines gases in chemicals in Pollution by
bulk bulk Oil
0120 0131 0141 0150
American Bureau of
140 2 36 139 0
Shipping (ABS)
Bureau Securitas 0 1 0
Bureau Veritas (BV) 164 17 59 156 1
China Classification
7 0 0 7 0
Society (CCS)
Croatian Register of
2 0 1 3 0
Shipping (CRS)
Det Norske Veritas
232 10 90 235 0
(DNVC)
Germanischer Lloyd
94 10 46 91 0
(GL)
Indian Register of
4 0 0 1 0
Shipping (IRS)
International
Register of Shipping 2 0 0 2 0
(IS)
Korean Register of
7 0 4 7 0
Shipping (KRS)
Lloyd's Register
175 11 46 170 0
(LR)
Nippon Kaiji Kyokai
68 1 28 67 0
(NKK)
Other (Class Not
1 0 0 1 0
Specified)
Phoenix Register of
2 0 0 2 0
Shipping
Polski Rejestr
4 0 0 4 0
Statkow (PRS)
Registro Italiano
57 1 24 55 0
Navale (RINA)
RINAVE Portuguesa
1 0 0 1 0
(RP)
Russian Maritime
Register of Shipping 22 0 3 21 0
(RMRS)
Turkish Lloyd (TL) 5 0 1 5 0
Universal Shipping
1 0 0 1 0
Bureau
Total 988 52 339 968 1
 28
Annex 1.5 CIC Q&A’s
Questions, remarks, queries (version dated 29/09/10)
New additions are included in RED
General
- G1 What should be the language of the SIB? Working
Language / English or French or Spanish or a combination
of WL and one of the three?
- G2 In case of different arrival and departure conditions,
what does a PSCO take into consideration primarily?
- G3 In case of deficiencies with this CIC, does a PSCO
write 1 deficiency in case of multiple NO’s? If Q7 is yes,
the NO’s on Qs 4-6 are cancelled as def? At what point
can ISM be taken into consideration, with this CIC?
- G4 There is a difference in the range of gravities for
crude oil, how is this to be dealt with in accordance with
the SIB?
- G5 There are cases where the product is referred to as
“African Crude”, without further details, how is this to be
dealt with?
- G6 It is still unclear for us if the stability program should
be approved by class? If not, should the PSCO check this
on board with standard approved condition out of the
damage stability booklet?
- G7 There are cases where it is required that during the
voyage the water content of the cargo is “decanted” to the
sloptank. This would change the damage stability because
it is more then 1%, how is this to be dealt with?
Response
- This requirement comes from the Code on Intact
Stability that, at the moment, are only
recommendations
- Departure
- In the case of multiple “NOs” this would imply that the
master is not compliant with damage stability
requirements which would result in 1 deficiency
- Yes but Qu 8 has to be answered “YES”
- If it is confirmed that the master in not complying with
- Stability information for crude oil tankers often only
quotes names of different crudes, not SG. The master
would have to know what the SG if for the cargo the
ship is carrying.
- Without further details the specification, including the
SG is unknown, as above the master will have to verify
the SG?
- The reference to Class approval has been removed form
the questionnaire. There is no flag State requirement for
approval of any form of stability computer program, the
use of onboard computers is not a requirement. The
same applies to Class, the use of computers is not a
requirement. However, a stability software installed
onboard shall cover all stability requirements applicable
to the type of ship, thus for tankers it should include
damage stability. There is no need for the PSCO to check
for Class approval or check a computer program against
the approved conditions. The PSCO may ask the question
of the master “How is it confirmed that the program is
checked for accuracy?” The master may show that a
check is carried out on a regular basis, possibly under the
SMS. If the answer is no the PSCO could record as an
observation that a check should be carried out.
- In principle there is no specific difference between this
process and that of ballasting the ship mid-voyage to
compensate for fuel consumption, or undertaking a
ballast exchange. If there is to be any significant change
in the distribution of tank contents, all stages should be
assessed for damage stability compliance to ensure that
stability is met throughout the transfer process (if there
are multiple free surfaces created on a temporary basis)
and in the final condition. The premise behind the CIC is
that the departure condition should have been assessed
and verified compliant with damage. It is possible that
 29
- G8 In a comb carrier that complies with both MARPOL
Annex 1 and the IBC code which code takes precedence in
establishing damage stability?
- G9 What if an oil tanker does use a PC to calculate
alternative loading conditions?
- G.10 What is the criteria of 'alternate loading condition'?
(Is it same as the criteria of the survey which was
undertaken by U.K.? "the filling of each cargo and ballast
tank lies within 1% of the weight in the approved condition
and GMf lies within 2cm of the approved condition GMf")
(question from RO)
- G.11 How and what is your action if the ship has not
confirmed the damage stability when the ship is loaded as
per alternate loading condition? (question from RO)
- G12 Is this CIC questionnaire applicable on the previous
voyage or on the intended voyage? I know this item has
been discussed and the outcome was I believe for the
intended voyage
- G.13 Not all questions is given a Deficiency Code, should
we use 0930 for those?
Question 1 Does the ship have an approved stability
information book (SIB)?
- 1.1 Deficiency reference in case of detention (specifically
the PSC inspector could follow this up with a question
about how in-voyage changes are assessed, or indeed if
they are assessed at all. In any of the above scenarios it
should be possible to see from records whether such in-
voyage checks are regularly being made.
- It is my understanding that IBC is the higher standard,
and that Marpol products can be carried in an IBC ship,
but not vice-versa. Consequently, for any vessel which is
carrying polluting chemical cargo covered by the IBC
code, IBC damage will rule even if there is more
deadweight of oil products on board. Even if you
assessed both, the IBC standard is higher so this will
always give the limiting case anyway
- Oil tankers are not permitted alternate loading
conditions. The master may use a program on a PC to
calculate intact stability which would include damage
conditions. See Qu 4.11
- Yes
- The limits were a pragmatic approach to allow a slight
deviation in loading. I don’t think this will be much of an
issue with oil tankers where SGs of the cargo do not vary
much, the main concern is with chemical tankers where
there is wide range of SGs, for instance some of the
muds used in the North Sea can be up to a density of
2.2, such that the tanker could be down to her marks
with slack tanks etc. and would be very different to any
known loading condition in the SIB. We have defined an
alternate condition as one that is not defined in the SIB,
if the ship has been loaded to a known condition but is
slightly out by the above allowance of 1%/2cm then this
would be considered acceptable and not be treated as an
alternate condition.
- If the ship is loaded for departure and is an alternate
loading condition the master MUST show that the ship
complies with damage stability requirements. The PSCO
may consider detention until such times the loading
condition has been confirmed
- The main concern is with the intended loaded voyage,
however if the ship is discharging and will depart in
ballast, the PSCO will have to ask to see evidence that
damage stability has been taken into account from the
previous voyage(s) see answer to question 4.6
- YES
Response
- If there is no stability book use the Load line
 30
relating to MARPOL)
- 1.2 “Provisional approval” is there a limit to the duration
of this provisional approval?
- 1.3 Is an electronic version of the SIB acceptable?
- 1.4 It is still unclear for us if the stability program should
be approved by class? If not, should the PSCO check this
on board with standard approved condition out of the
damage stability booklet?
- 1.5 What if an oil tanker does use a PC to calculate
alternative loading conditions and on that way master
checks compliance with damage stability
And I received following answer
Answer 1: That’s OK, at least the master has attempted to
verify damage stability, but could ask the question does
he/she verify that the computer is giving correct results on
a regular basis
But in instructions received on 12 August you said
Qu.2: 4.11 Oil tankers have no options for alternate
loading conditions, if qu.4. answered “NO”, all other
questions are N/A? should the vessel be detained directly?
Answer 2: True, MARPOL Reg 28 does not give the option
for alternate loading, it makes ref to oil tankers complying
with damage stability for any operating draught reflecting
actual partial or full load conditions. In the case that the
master cannot show that the ship is loaded in accordance
with the SIB (which would include damage for each
condition) then Qu 4 should be answered “NO” and all
other questions “N/A”. Detention should be considered if
the vessel is loading and intends to depart without loading
to a known condition.
• 1.6 I would like to know if an oil tanker vessel, with a
deadweight over 100,000 tons and has been built 2005
where the damage stability plans were not mandatory,
does the vessel have to have such plans and a stability
computer program that includes damage stability?
(Question from company)
Question 2 Is the SIB written in a language understood by
the master?
- 2.1 Deficiency reference in case of detention (specifically
relating to MARPOL)
Regulations Annex I RegII/10.3 (if it doesn’t cover
damage use MARPOL, see Qu 3)
- No
- Yes, provided it is approved by the flag/RO
- If the ship was contracted for construction on/after
01/07/05 then approval is required under IACS UR L5 for
IACs members. Prior to this no approval was required
unless specifically requested by the owner. The whole
area of stability program approval is not clear and was
removed from the Questionnaire. Thus for the purposes
of the CIC the main concern is that the master has taken
account of damage stability. If using a program for this
we will accept it, we could ask the question of the master
“How is the program verified?” but it is not part of the
CIC. We are not expecting PSCOs to go as far as
checking stability calculations.
- You are right, generally oil tankers are not permitted to
use an alternate loading condition. Apologies for the
confusion, on reflection I would suggest that detention is
too harsh. If an oil tanker is loaded to an alternate
condition BUT the master has shown that this condition
does meet damage stability requirements for example
the results of a computer program then answer YES to
Qu 4. If however the master cannot show that this
alternate condition meets DS requirements and the ship
is loaded for departure then detention should be
considered until such times DS has been confirmed
- No, we are not looking at damage control plans.
Generally oil tankers should be loaded to a known
condition in the SIB (which has been approved for
MARPOL damage conditions). If however the ship is
loaded to an alternate condition the master needs to
show how damage has been taken into account, this
could be in the form of an output from a computer
program that covers damage.
Reponse
- No MARPOL ref, taken from Intact Stability code
 31
Question 3 Does the approved stability information cover
damage conditions?
- 3.1 Deficiency reference in case of detention (specifically
relating to MARPOL)
- 3.2 Tankers built in the period from late 1990's upto
2002, do not have damage stability documentation. How
will PSC Inspectors view this requirement during the up
coming CIC
Question 4 Can the master demonstrate that the ship is
normally loaded in accordance with the SIB?
- 4.1 the number of 2 cm GMf refers to intact or damage
stability or both
- 4.2 is there a convention reference for this number?
- 4.3 Is it appropriate to that that here also N/A should be
blacked out?
- 4.4 Is there a legal base for the 1% to which a PSCO can
refer? (URL states 5%) (in the training many deem this not
practical to enforce)
- 4.5 A distinction between oil tankers and gas / chemical
tanker may be needed in the guidance (“acceptable
deviation is considered to be….”)
- 4.6 Where does the requirement to maintain records of
stability calculations for previous loaded conditions come
from
Response
- Oil Tanker MARPOL AI Reg 28
- Gas Tanker IGC code Ch 2
- Chem Tanker IBC Code Ch 2
- Documentation on board comprises Intact loading
conditions plus damage calculations. In some cases the
SIB will include approved damage calculations for each
condition of loading, however there may be cases where
there is no separate set of damage calculations, the only
indication that damage has been assessed is that the SIB
will be stamped as complying with MARPOL. A separate
approved set of damage calculations is NOT a mandatory
requirement. During the CIC the PSCO will be looking for
evidence that the stability has been assessed for damage
and that the ship is loaded in accordance with approved
loading conditions or if alternate loading conditions are
used they have been verified.
Response
- Intact GM according to SLF-51-13-1 para1.4, but
f
should be stated in guidance
- No, not sure where this “acceptable” deviation came
from. If a master can show that he is within these limits I
would suggest we accept it.
- No, the whole point of the CIC is to see whether
tankers are complying with damage stability the answer
to Qu 4 “ Can the master confirm that the ship is
normally loaded in accordance with the SIB (which
includes damage in the case of tankers)?” is either YES
or NO
- No
- See Qu 5.4. Not sure we should make a distinction
between types
- There is no specific reference, however, the vessel is
provided with approved stability information for the
guidance of the master. The stability information contains
approved loading conditions which should have been
verified for damage. To load the vessel in accordance
with the Regulations, the vessel must either be loaded in
accordance with one of these conditions or to some other
condition for which a verification is possible, either by
assessing using critical KG/GM or by using a stability
 32
- 4.7 In question 4 "the master should be able to
demonstrate that the loaded condition of the ship ALWAYS
complies with an approved condition of loading", is
indicating that all voyages should be taken in
to account
- 4.8 What should be the action taken by the PSCO when
for the previous voyage no sufficient data or damage
stability calculations are available on board ?
- 4.9 What will be the action taken when for the previous
voyage damage stability calculations were carried out, but
the vessel was not complying ? ground for detention?
- 4.10 At what time the required damage stability should
be available on board? If we carry out the CIC on the
intended voyage, the vessel will for example be
discharging? [does the questioner mean loading?] during
our PSC inspection ETD 2 days later and no data available
yet? should in this case qu.4 be answered NO?
- 4.11 Oil tankers have no options for alternate loading
conditions, if qu.4. answered “NO”, all other questions are
N/A? should the vessel be detained directly?
program.
The master must assure himself by endorsing the
stability condition made by the officer in charge of
loading the vessel, that the vessel meets minimum
requirements. This should be included in SMS procedures
as it is a mandatory requirement to meet stability and
someone (usually the master) must indicate that this is
done prior to sailing.
To fulfil this requirement there must be a record and this
record is that which may also be requested by PSCO if
there is a desire to check that the vessel is properly
loaded.
There should be a requirement to hold records in the
SMS otherwise an audit cannot be facilitated. If there are
no records then ISM cannot be met as there is no means
to determine whether the Regulations relating to stability
are being complied with in service.
- To comply with the regulations the master should
ensure the ship complies with damage stability for every
loaded voyage. The PSCO should be satisfied that master
does take damage stability into account for
at least the previous voyage. See also answer to Qu 4.6
above. Note the wording of the questionnaire was
changed from “always” to “normally”
- Answer Qu 4 as “NO” and record as deficiency 1799
Marpol other for oil tanker and 1899 other for Gas and
chemical tankers - “Damage stability not being complied
with” AT code 55 flag state consulted
- In this case the master would be aware that the ship
was not complying, it would be difficult to detain as the
situation is now over. Would suggest recording as an ISM
deficiency 2535 – Development of plans for shipboard
operation - AT 18 rectify within 3 months
- In the case of a tanker that is loading the CIC is aimed
at the intended loaded voyage. If the calculations are not
available during the inspection the PSCO could ask the
master to simulate how the damage stability will be
calculated to ensure compliance prior to departure and
maybe ask for records from a previous voyage. If the
PSCO is satisfied that master is taking damage stability
into account then Qu 4 can be answered “YES”
- True, MARPOL Reg 28 does not give the option for
alternate loading, it makes ref to oil tankers complying
with damage stability for any operating draught reflecting
actual partial or full load conditions. In the case that the
master cannot show that the ship is loaded in accordance
with the SIB (which would include damage for each
condition) then Qu 4 should be answered “NO” and all
other questions “N/A”. Detention should be considered if
the vessel is loading and intends to depart without
loading to a known condition.
 33
- 4.12 "the master should be able to demonstrate that the
loaded condition of the ship ALWAYS complies with an
approved condition of loading", is indicating that all
voyages should be taken in to account?
- 4.13 What should be the action taken by the PSCO when
for the previous voyage no sufficient data or damage
stability calculations are available on board?
- 4.14 What will be the action taken when for the previous
voyage damage stability calculations were carried out, but
the vessel was not complying? Is this a ground for
detention?
- 4.15 At what time the required damage stability should
be available on board? If we carry out the CIC on the
intended voyage, the vessel will for example be
discharging during our PSC inspection ETD 2 days later and
no data available yet? Should in this case qu.4 be
answered NO?
See also Qu 4.10 above
- 4.16 Oil tankers have no options for alternate loading
conditions, if qu.4. answered No, all other questions are
N/A? Should the vessel be detained directly?
- 4.17 This might not be possible as the proposed loading
can be quite different from the loading conditions
mentioned in the SIB, however loading strictly in
compliance with the Load line Criteria’s. (Question from
company)
- 4.18 This need not necessarily mean that the current
situation is exactly as per the “examples” given in SIB but
the stability parameters must not be outside the approved
SIB. (Question from company)
4.19 There are 63 damage stability condition approved by
the class. When u take your final load/dich condition prior
departure. You have to check with each of the damage
condition.
You don't have the privilege to choose which one of the
cases will "occur". Each condition is with different Tanks
been impact.
Lets assume that ship touched coral or rock in her
starboard forward then after checking find WBT1 N 2STB
water start to penetrate, and I can check and assess
accordingly with the damage stability condition from the
book or from the loadcomputer. But the a/m is only when
it has occurred.
Prior departure I must take in account all the 63
possibilities and verify that all of them are "GOOD" should i
have 1 condition "NOT GOOD" then I will need instruction
- The questionnaire has been changed from ALWAYS to
NORMALLY. To comply with the regulations the master
should ensure the ship complies with damage stability for
every loaded voyage. The PSCO should be satisfied that
master does take damage stability into account for at
least the previous voyage
- Record Qu 4 as “NO” and record as a deficiency.
- No, as this happened previously. Record as a deficiency
and include flag State consulted as an Action Taken. Also
this is a failure of the SMS.
- In the case of a tanker that is loading the CIC is aimed
at the intended loaded voyage. If the calculations are not
available during the inspection the PSCO could ask the
master to simulate how the damage stability will be
calculated to ensure compliance prior to departure and
maybe ask for records from a previous voyage. If the
PSCO is satisfied that master is taking damage stability
into account then Qu 4 can be answered “YES”
- No see 1.2 above
- Yes, but in this different or alternate condition the
master must demonstrate compliance with damage
stability requirements
- Yes but we would accept a deviation of within 1% of
weight in individual cargo/ballast tanks and 2cm of the
approved condition GMf
- The damage stability calculations that have been copied
to the ship will have been used by the certifying
administration (usually the classification society) to
ensure that the 'standard' loading conditions, in the
approved Stability Booklet/Loading Manual, comply with
the relevant requirements. The information is
supplied to the ship, firstly as evidence of compliance
with the relevant requirements, but also to illustrate the
effect of damage, e.g. angle of heel, depending on its
location and for the various 'standard' conditions of
loading. It is not intended, nor can it be used without
extensive knowledge of naval architecture principles, to
calculate the effects of damage for alternate loading
conditions.
 34
from head office.
Each condition is minimum 2 pages and this should be
retained o/b for PSC evidence.
Sofar self checked visually only from the loadcomputer.
(Query from Company)
Question 5 Has the master verified an alternate loading
condition by written authority from flag/class?
- 5.1 can a PSCO, based on the IBC and IGC code legally
require this? (to use KG/GM data to calculate alternative
loading conditions, i.e. legal reference to clarify)
- 5.2 Is this in accordance with the certificate of the IBC
and IGC?
- 5.3 With respect to Question 5 of the CIC questionnaire
what constitutes an alternate loading condition
- 5.4 All Trim and Stability booklets have various loaded
conditions, how much of a deviation from an approved
loading condition is considered an alternate load condition
- 5.5 What is meant by alternate loading condition, are you
referring to a condition which is NOT mentioned in SIB
(Stability Information Booklet), if so, this would be the
case with almost all the ships, in that case, do we have to
go back to the class / flag each time for an approval, if so,
this would be impractical, if not, close to impossible.
(Question from company)
- 5.6 If answer to Q. No.4 is a “NO” i.e. the stability
parameters are indeed outside SIB parameters, written
approval (confirmation) from class or flag would be
required. (Question from company)
- 5.7 "Has the master verified an alternate loading
condition by written authority from flag/class?", it is most
commonly noticed that oil tankers do not load always
exactly 100% as per the conditions included within the
SIB, but are very similar conditions, for example
"homogeneous" condition but with less displacement with
the ones mentioned in the SIB. Does such conditions need
to be verified from the flag/class or
Response
- Gas tankers and Chemical tankers are very clear on this
issue and on the Certificate of Fitness it states:
“Where it is required to load the ship other than in
accordance with the above instruction, then the
necessary calculations to justify the proposed loading
conditions should be communicated to the certifying
Administration who may authorise in writing the adoption
of the proposed loading conditions.”
- See 5.1 above
- Any condition not in the SIB
- The "rule of thumb" for deviation is 1% of the weight in
the approved condition for each cargo and ballast tank
and within 2cm of the approved condition GMf. (This is
explained on page 15 of the guidance in annex I under
the heading "Variation of Loading"). Nobody seems to
know where this allowance came from and not all
Administrations accept it. I would suggest that if the
PSCO was confronted with this situation he/she would
accept it, the main thrust of the CiC is to ensure that
masters/shipowners are actually taking damage stability
into account
- We have defined an alternate condition as one that is
not defined in the SIB, if the ship has been loaded to a
known condition but is slightly out by the above
allowance of 1%/2cm then this would be considered
acceptable and not be treated as an alternate condition.
The master has to demonstrate that whatever the
loading condition it MUST comply with damage stability
requirements. This can be achieved by either obtaining
approval from flag/class or using critical KG/GM limit
curves or more commonly using a computer program
- No, see 5.5 above.
- No. The generally accepted allowance in this situation
would be up to 1% of weight in individual cargo and
ballast tanks and up to 2cm of the approved GMf
 35
can they be considered as the conditions mentioned within the SIB? (Question from company)
• 5. 8 Will port state inspectors’ detain oil tankers loaded
with an alternate loading condition (not included in SIB,
and out side your limits of 1% and 2cm GM), even though
a formal acceptance for the specific loading condition has
been granted by the flag/RO? (Question from RO)
• 5.9 How can the vessel 'simply' verify that he is in
compliance with the Damage Stability requirements, when
it has had to load a multiple grade cargo that does not
meet any example condition given in the SIB? (keep in
mind that the vessel does not have a Damage Stability
function on its Load Computer)
Question 6 Has the master verified an alternate loading
condition by assessing loaded condition against critical
damage KG data, included in the approved stability
information?
- 6.1 (including sheet 15.3) the reference to “ the
company….” How should this be interpreted?
- 6.2 “sufficient guidance” “correctly applied” how are
these terms to be interpreted? How can a PSCO check this,
assure him/herself of this?
- 6.3 Again not very clear (question from company)
ACTUAL loaded condition is within the limiting curves.
- 6.2 If answer to No.5 above is still a “NO”, Master is
permitted to demonstrate current stability condition by
comparing KG or GM data with approved damage loading
condition. (question from company)
Question 7 Is there an on-board stability computer
program that includes damage stability?
- 7.1 which are the legal references for this this? (it may
be the case that the master cannot confirm he complies,
whereas he factually does)
- No, if an oil tanker has formal acceptance from
flag/class for a specific loading condition this would be
accepted by the PSCO. (See also answer to Qu 1.2)
- It would be difficult to "simply" verify compliance with
damage stability requirements in an alternative loading
condition. In essence the ship would need a loading
computer covering damage stability. It may be possible
to request flag/class to verify this alternate condition
prior to sailing. Note that failure to comply with damage
stability requirements prior to departure is in
contravention of the IBC Code. This is exactly the
purpose of the CIC to ensure damage stability is being
complied with in situations like this.
Response
- This was a typing error. The company agreement
should be deleted. But this is in relation to the ‘standard’
loading condition, not the use of allowable KG/GM data.
- I agree the wording is subjective, however the main
concern is that the master understands the information
supplied and is able to be satisfied that the ship complies
with the damage stability criteria
- This is simply another method for calculating damage
stability if the ship is loaded to an alternate loading
condition outwith the SIB. This may be done if critical
damage KG/GM data is available, ie Max KG or min GM
limit curves, the master needs to demonstrate that the
- See 6.3 above
Response
- There are no legal references for stability computers.
 36
- 7.2 If answer to No.6 above is still a “NO”, Master is
given an opportunity to demonstrate compliance using
loading instrument. (question from company)
- 7.3 What if the type approval for the software is made by
a non IACS Class, will that be accepted?
- 7.4 What if the type approval for the software is made by
IACS Class but before 2005, will that be accepted?
Questions 8 Has the master verified an alternate loading
condition by using the on-board stability computer
program for carrying out damage stability checks?
- 8.1 is it allowable that the calculations are produced on
shore and emailed back to the ship?
- 8.2 If the vessel does not have a Damage Stability
Program installed in its Loadicator and does not have a
Damage Stability Booklet, then what are the consequences
and what should we as a prudent manager do? (Question
from company)
master must demonstrate that the ship complies with damage. The most common way to assess this is using a damage
stability computer program.
Questions 9 Was the ship detained as a result of this CIC?
- 9.1 In case of detention: what Sirenac code should be
used?
Annex 1
- A1.1 (including sheet 15.3) what is meant by “limits”?
- A1.2 our standards are 1 %, how to act if an
administration allows 5%?
- A1.3 Page 6 IBC code: what is the reference for ships
built after 1-1-2007?
- A1.4 Page 7 the indented par. seems to be incorrect (as
rd
they seem to refer to the .1 statement. And the 3 par.
rd th
(intended) refers to MARPOL Which make the 3 and 5
- Yes the master may use a computer program to verify
that the alternate loaded condition complies with damage
stability requirements.
- Yes
- Yes
Response
- Yes
- The master MUST be able to demonstrate that the ship
is loaded in compliance with damage stability
requirements.
- If the ship is loaded to a KNOWN condition in the SIB
and has been approved for damage, approval may be in
the form of a stamp on the SIB “Approved for Damage”
or possibly a Damage Stability Declaration or a letter
confirming approval for damage from flag/class. If
however the ship is loaded to a condition outwith the SIB
ie an ALTERNATE condition then the
Response
- 1799 Marpol - other for oil tanker and 1899 - other for
Gas and chemical tankers - “Damage stability not being
complied with” AT code 17/30/55 rectify before
departure/ship detained/flag State consulted
Response
- The limits refer to 1% of the weight in the approved
condition for each cargo and ballast tank and within 2cm
of the approved condition GMf.
- No more favourable treatment could be applied, but as
stated earlier the 1% is only guidance, thus that may be
difficult, maybe could add as an “observation” on the
report of inspection
- IBC 04 Amend / II / 2.1
- This is poor drafting on my part, the indented
paragraph onwards is not specifically referring to Gas
Tankers, but to tankers in general (Oil, Gas, Chemical)
maybe there should be a sub-heading “General” at the
 37

paragraph contradictory. start of the indented paragraph to show this.