CHEMICAL & PRODUCT

TANKER CONFERENCE
London, 14th March 2017
1. MISC at a Glance
2. A Chemical Tanker Incident
3. Questions for Introspection
4. Background
5. The Incident
6. Actions taken by MISC
7. The State of the Industry - Operation of Chemical / Product Tankers Today
8. MISC’s view on Required Industry Changes Resulting from our Experience
a. Cargo Tank Inerting
b. Electrical Storm Warning System
c. Wall Wash Test Requirements
d. Pressure Vacuum Valves
e. Review and Revision of IBC Code – Chapter 17
f. Fire Fighting Training
9. Reflection & Contemplation
MISC AT A GLANCE
 MISC
Logo

Energy & Maritime

Energy Shipping
Solutions

LNG Shipping Offshore Business

Petroleum & Product Shipping Marine & Heavy Engineering

Maritime Education & Training

Maritime Services & Port and

Terminal Management PMSSB

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KEY FINANCIAL HIGHLIGHTS

Revenue Profit Before Tax

$ 2.29b $ 0.69b
Total Assets Shareholders’ Equity

$ 12.52b $ 8.49b
Financial Year Ended 31 December 2016

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MISC GROUP AT A GLANCE

9,000

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BUNGA ALPINIA – LESSONS LEARNED
Recommendations for the Industry to Achieve Safer Chemical Tanker
Operations
A CHEMICAL TANKER INCIDENT

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Questions for Introspection
• Do we consider ourselves to be a responsible industry?
• Should we not self-regulate rather than wait for onerous regulations to be
imposed?
• Are we prepared to learn from past incidents?
• Shouldn’t industry shift from historically reactive to one that is proactive?
• Shouldn’t we consider replacing “customary” practices with safer and more
credible options presented through latest technology? This specifically in reference
to assessing quality of tank cleaning?

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Background
At 0237hrs on 26th July 2012, an MISC owned, 38,000 dwt IMO type II Chemical Tanker
suffered a major explosion, whilst loading methanol, resulting in the tragic loss of five of its
crew.

Following the incident, the vessel was a constructive total loss and also resulted in loss of
cargo and damage to neighboring facilities.

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The Incident
• The vessel arrived at Labuan to load methanol, having also part loaded methanol at a port in the
Middle East. At Labuan, in line with industry practice, the tanks were subjected to a wall-wash test to
prove their cleanliness, prior loading methanol.
• With a flashpoint of 120 Celsius, methanol is considered to be “low flash cargo” but regulations
(applicable to the vessel) do not require cargo tanks to be inerted (with IG* or Nitrogen) prior to
loading. Accordingly on satisfactory completion of the wall-wash test, loading commenced and first-
foot sampling was carried out.
• Tanks 1P, 2 P&S and 6 P&S were loaded on receipt of satisfactory first-foot sampling analysis, to be
followed by 5 P&S and 9 P&S in accordance to the loading plan.
• When loading the first set of tanks, a sudden lightening squall struck the vessel and flammable vapour
released from the P/V valves at tanks 1P and 2 P&S was ignited. The P/V fire flashed back into the
cargo tanks, which subsequently exploded, this caused the fire to escalate leading to further
explosions.
* Shippers do not allow vessels to inert their tanks with IG, for methanol loading, citing cargo contamination.
They do not object to NITROGEN purged tanks.

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Actions taken by MISC
• PV valves of the same make and model were tested at an independent, approved facility. IACS
members and makers were invited to witness the tests - latter did not attend.
• The PV valves failed the tests, particularly the flashback tests. Following the failure of PV valves to
conform with required standards, all PV Valves of similar make and design were replaced in the entire
fleet.
• Portable units of Lightning Warning & Detection System were supplied to entire fleet.
• Procedures related to loading low flash point MARPOL Annex II cargoes were raised to standards
over and above the industry guidelines. These included a 3 tier system of cargo plan and RA
approval, restriction on number of cargo tanks within flammable range and imposing the use of IG for
cargo operations involving low flashpoint grades, subject to agreement by shipper(s) and receiver(s).
• Development of an in house FF training standards for tackling PV valve fires.
• Extensive engagement on lessons learned with large number of stakeholders, including but not limited
to IACS members, ICS, IPTA, Flag State, Oil/Chemical Majors, CDI, INTERTANKO, OCIMF and
others interested parties.
• Presentation of industry level changes and proposals tabled through the flag state at IMO, during the
July 2015 MSC and Casualty Working Group of the III Sub-Committee.

Above measures were initiated and implemented by MISC without waiting for the industry to react. In principle, whilst majority of
stakeholders supported our proposals on lessons learned, regrettably that support did not translate into actions which would prevent
recurrence of similar incident.

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The State of Industry : Operation of Chemical / Product
Tankers Today

• Inert Gas – Installation of a fixed IG system is required for tankers of 8,000Ts dwt and
over, constructed on or after 1 January 2016 ONLY. SOLAS regulations;
o II-2/16.3.3 allows chemical tankers the option to begin inerting their cargo tanks after the cargo tank
has been loaded, but before commencing unloading, but only if nitrogen is used as the inerting
medium.

• Nitrogen Blanket – A requirement under IBC/BCH Code, new SOLAS regulations or

imposed by the requirements of cargo quality. Is this the solution? NOT IN OUR VIEW!
• Wall wash testing / first foot practices – customary method used by industry to test for
cargo tank readiness; issues with it? Restricts the operator to inert cargo tanks prior loading,
not to mention increased number of enclosed space entries required for the task. First foot
sampling for non-inerted tanks increases risk exposure significantly.

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The State of Industry : Operation of Chemical / Product
Tankers Today

• Batch approval of equipment – the “stamp the stamp” practice by IACS members.
Following MISC’s PV Valve testing, it became evident that this practice does not provide
assurance on equipment conformance with standards set.
• Non uniform application of standards by authorities – The Danish Maritime Authorities
banned makers two of similar type of valves in 1996. While initially the EU appeared to
embrace the ban, this was reversed after an IACS member’s intervention – Disunity in the
industry costs lives!

IHS Chemical Tanker Casualty database contains 45 cases of FIRE &

EXPLOSION between 2009 and 2015! Total number of victims? 28!

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MISC’s view on Required Industry Changes
1. Cargo Tank Inerting.
2. Electrical Storm Warning System.
3. Wall Wash Requirements.
4. PV Valves and other Safety Equipment and Performance Standards.
Uniform application. Class Approval.
5. Review and Revision of the IBC Code, Chapter 17.
6. Fire Fighting Training For Shipboard Specific Area and Equipment such as
PV Valves.

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Cargo Tank Inerting
• Previous legislative requirement – Tankers > 20k DWT or COT capacity > 3k CBM.
• New legislative requirement (1st Jan 2016) – IGS on tankers > 8k DWT. To facilitate tank
inspection prior loading, allowance for cargo tanks to be inerted after completion of loading.
Tanks to remain so until the compartment is purged of all flammable vapours prior
commencement of gas freeing.
• What needs to change – Tanks to be inerted prior commencement of loading and remain so
until completion of tank cleaning.
• How / where to change –To deliberate in IMO’s Sub-Committee on Ship Systems and
Equipment (SSE) and absorb changes in revised inerting requirements under SOLAS II-2/4.

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Cargo Tank Inerting

Alpinia STOR
VALOR
(MTBE)

Completed
Commenced Completed Commenced Completed
Tank
Loading Loading Discharging Discharging /
Cleaning
Commenced TC

COT Non-inerted Undefined atmosphere in tanks

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Cargo Tank Inerting
The Requirements Today
Pre-loading
Inerting
Risk of
Vessel Type Requirements
Explosion
s

CRUDE/ PRODUCT TANKERS YES YES

EXPLOSIVE LNG / LPG TANKERS YES YES

TANK MIXTURES
CHEMICAL YES NO

Have we as an industry failed to address this risk?

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Electrical Storm Warning System
• Current legislative requirement – None. However industry guidelines refer to suspending all
operations that may evolve flammable vapours during electrical storms in the vicinity of the ship.
Current industry guidelines are vague and changes are not foreseen but equipment would solve this
issue.
• Future legislative requirement – None.
• What needs to change – Decision to suspend cargo operation is left to human factor. Periods of
darkness and visibility conditions could impair judgment. carriage and use of lightning detectors during
all cargo operations on board tankers carrying volatile cargoes (FP < 600C) should be made
mandatory for early detection and suspension of cargo operation. We envisage the equipment to be
similar to COT level alarm (audio-visual) providing warning in CCR and on deck. Ideally, this
equipment should be made mandatory at the terminals.
• How / where to change – IMO – To be discussed during Sub-Committee on Ship Systems and
Equipment (SSE) meeting and carriage requirements to be included in SOLAS II-2/4

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Wall Wash Test Requirements
• Current legislative requirement – None. However, charterers require WW standard for most chemical
cargoes as proof of cleanliness and acceptability.
• Future legislative requirement – NA
• What needs to change – For purpose of WW test, loading of low flash cargoes should not be permitted
in non-inerted tanks.
• How / where to change – If charterers insist on WW requirements, test to be conducted at anchorage
and tanks to be inerted on successful outcome. Alternatively, the industry should consider accepting
WW tests conducted by vessel. Better still, we need to move forward and adopt new technology which
is not only safer but also more for effective for testing tank cleanliness.

Exemption clauses on tank inerting requirements on chemical tankers > 8k DWT should be
reviewed. Review based on EXPLOSIVITY of the environment and not vessel size.

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Pressure Vacuum Valves
• Current legislative requirement – current requirements on performance standards for PV valve as per
MSC 677+1009 adopt the ISO 15364:2000 requirements of Flashback, Endurance burning and
Detonation tests.
• Future legislative requirement – None.
• What needs to change – Testing criteria against lightning strike to be established. To include, ISO
requirements (ISO 16852:2008) specifying the requirements for flame arrestors preventing flame
transmission. Flash back test (5 yearly) confirming integrity and reliability of the valve to be made
mandatory.
• How / where to change – IMO – To deliberate in Sub-Committee on Ship Systems and Equipment
(SSE) and revisions made to performance standards.

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Review and Revision of IBC Code – Chapter 17
• Current legislative requirement – NA
• Future legislative requirement –ongoing
• What needs to change – Incongruent information on hazard identification and absence of information
on sampling requirements. For instance, in case of cargoes like MEOH, MTBE hazard identified
(under column ‘d’) as ‘Pollution’ against ‘Safety’. For cargo like Coconut oil, it is Safety/Pollution.
Toxicity associated with MEOH is not identified and vapour detection arrangements have been
excluded. Though requirements are in place for gauging (under column ‘j’), as sampling also presents
hazards this should be included with gauging criteria.
• How / where to change – To be discussed by IMO Working Group on the Evaluation of Safety and
Pollution Hazards (ESPH) and changes made to minimum requirements.

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Fire Fighting Training
• Current legislative requirement – None.

• Future legislative requirement – None.

• What needs to change – Training requirements for fire fighting course listed under STCW code Part A
Section VI/1,VI/3 and or STCW Part B Section V-1,V-1-1,V1-2 tanker safety training should incorporate
techniques required to fight fires on ship type specific equipment’s / compartments like on PV valve,
Gas freeing vent (Purge pipe) Compressor room, cargo tank vent riser.

• How / where to change – IMO – To address in Sub-Committee on Human Element, Training and
Watch-keeping (HTW) and appropriate changes brought in training requirements as per STCW code.

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Reflection & Contemplation
• Challenger Space shuttle disaster – 7 killed.
o Worldwide attention and sweeping reforms.
• Airline disasters – multiple deaths
o Changes and improvements after each incident adopted quickly.
• Chemical Tankers
o 45 cases of FIRE/EXPLOSION between 2009 and 2015! Number of
victims? 28 killed!
o MISC’s own disaster, 5 killed – if similar (or worse) recurs, would
respectable industry stakeholders not be held accountable given past
incidents?

The jury is out, self-interest and apathy still prevail.

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Those that fail to learn
from history are doomed
to repeat it

- Winston Churchill -
Q&A
Thank You