USCG Shares Advice On Risk Analysis For Simultaneous Operations During LNG Bunkering - IBIA

10/24/21, 6:00 PM USCG shares advice on risk analysis for simultaneous operations during LNG bunkering - IBIA
Home / News / USCG shares advice on risk analysis for simultaneous

operations during LNG bunkering
24
AUG News & Commentary
2017
USCG shares advice on risk analysis for

simultaneous operations during LNG bunkering
LNG bunkering concurrent with other operations is allowed in the US,

but the US Coast Guard says safety assessments should be
conducted for each and every operation where LNG bunkering is
planned to take place simultaneously with other operations.
The Office of Operations & Environmental Standards of the US Coast

Guard (CG-OES) has recently issued a policy letter providing advice to
USCG Captains of the Port (COTPs) on how to evaluate simultaneous
operations (SIMOPS) during LNG fuel transfer operations.
The USCG has also pointed to further recommendation for risk analysis
of SIMOPS involving LNG bunkering provided by the Liquefied Gas
Carrier National Center of Expertise (LGC NCOE).
SIMOPS is a term used to describe multiple operations occurring

onboard vessels and in and around the marine transfer loading area
of facilities. SIMOPS while bunkering LNG may include loading or
discharging cargo; passenger and crew embarkation/debarkation;
ship maintenance and repairs, and various other operations. These
https://ibia.net/2017/08/24/uscg-shares-advice-on-risk-analysis-for-simultaneous-operations-during-lng-bunkering/ 1/6
ship maintenance and repairs, and various other operations. These
may entail some increased risk and complexity to the process of
transferring LNG as fuel.
According to the CG-OES policy letter, if SIMOPS involving LNG

bunkering are planned, the COPT should conduct an evaluation of the
safety aspects of each planned operation on a case-by-case basis. It
says COTPs may engage, where applicable, a range of stakeholders.
These may include the vessel owner/operator, the persons in charge

of the supply facilities, the Port Authority and stevedores, as well as
other port users operating in and adjacent to the bunkering area who
may be affected by the LNG bunkering operation. Factors which the
COTP may consider include overall risk and consequences regarding
the safety of persons and vessels in the vicinity of where SIMOPS will
take place, operational issues, the geographic area, port needs,
contingency plans, and mitigation measures.
The CG-OES policy letter suggests that the processes and procedures
outlined by the LGC NCOE, or LNG bunkering industry standards
developed by classification societies DNV GL or ABS, “may be used by
the maritime industry as a means for demonstrating that SIMOPS can
be conducted safely and securely”.
COPTs are also encouraged to contact LGC NCOE for technical

assistance as personnel there have gained experience while attending
and monitoring several LNG bunkering operations in US ports.
The LGC NCOE Field Notice is not a legal requirement or regulation, but
provides recommendations to the marine industry and COPTs to help
reduce risks associated with LNG bunkering SIMOPS. It encourages
vessel operators to conduct an optional, formal operational risk
assessment of their SIMOPS, but the onus in the recommendation is on
LNG suppliers.
“Usually, these risk assessments are conducted by the supplier from

which the LNG will be bunkered. However, it is important to recognize
that this process should be conducted in close coordination with the
receiving vessel particularly on initial operations and may also
receiving vessel, particularly on initial operations, and may also
include other service providers (e.g., port terminal, bunker/stores
barges, stevedore employers, emergency response organizations,
etc.) depending on the size and complexity of the operation,” the LGC
NCOE field notice says.
As part of assessing the risk of LNG SIMOPS, the LNG supplier is

encouraged to first establish the level of risk (high, medium or low)
around the bunkering operation, and on the basis of that conduct the
relevant type of risk assessment.
SIMOPS in a high risk area, where ignitable concentrations of

flammable gases and vapours could be significant, are not
recommended without a quantitative risk assessment that would
demonstrate that the risk is As Low as Reasonably Practical (ALARP) or
that mitigation measures would be put in place to reduce these risks
to ALARP.
Within an area identified as medium risk, steps should be taken to

minimise ignition sources and ensure that only essential personnel
and activities are allowed. SIMOPS in medium risk areas in conjunction
with bunkering LNG are not recommended without a qualitative risk
assessment which would demonstrate that the risk is minimised and
that sufficient mitigation measures would be put in place to reduce
any remaining risks, the LGC NCOE recommendation says.
“SIMOPS in low risk areas may be appropriate without a risk

assessment,” the Field Notice says.
The LNG supplier is encouraged to conduct relevant risk assessments

for each operation, and to produce a SIMOPS report summarising the
intended operation, how risks were assessed and mitigated and how
these mitigation measures would be implemented.
The CG-OES Policy letter issued in June 2017 is available here:

https://www.uscg.mil/hq/cg5/lgcncoe/docs/BunkerDoc-SIMOPS-OES-
PolicyLtr_01-17.pdf
The LGC NCOE Field Notice issued in August 2017 is available here:
https://www.uscg.mil/hq/cg5/lgcncoe/docs/BunkerDoc-SIMOPS-
LGCNCOE-FieldNotice_01-2017.pdf
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10/24/21, 6:00 PM USCG shares advice on risk analysis for simultaneous operations during LNG bunkering - IBIA

Home / News / USCG shares advice on risk analysis for simultaneous

USCG shares advice on risk analysis for

LNG bunkering concurrent with other operations is allowed in the US,

The Office of Operations & Environmental Standards of the US Coast

SIMOPS is a term used to describe multiple operations occurring

According to the CG-OES policy letter, if SIMOPS involving LNG

These may include the vessel owner/operator, the persons in charge

COPTs are also encouraged to contact LGC NCOE for technical

“Usually, these risk assessments are conducted by the supplier from

As part of assessing the risk of LNG SIMOPS, the LNG supplier is

SIMOPS in a high risk area, where ignitable concentrations of

Within an area identified as medium risk, steps should be taken to

“SIMOPS in low risk areas may be appropriate without a risk

The LNG supplier is encouraged to conduct relevant risk assessments

The CG-OES Policy letter issued in June 2017 is available here:

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