CLIPPER BULK − CLEANING MANUAL June 2006

008 - Surveyors and Standards of Cleaning Version 1.0

The concept of hold cleaning is simple enough: Remove previous cargo residue, rust,
and paint scale so that the holds will be ready for the next cargo. Independent
surveyors are used to determine if the holds are ready. Surveyors and inspectors are
frequently responsible for the most difficult, uncontrollable, and frustrating aspects of
hold cleaning.

The standards of cleanliness inspectors are looking for will generally fall into one of the
following categories:

1. Sweep clean - the least stringent standard. In this instance, the next cargo to load
is typically a dirty cargo that is not easily susceptible to contamination from the
previous cargo or small amounts of rust or paint scale. This standard must be
agreed to by Charterers and cargo interests and is usually only done so to save
time (and money) and is to the mutual benefit of all parties. It is always advisable,
however, to wash and dry holds after each cargo to prevent accumulation of
residues that may harden or promote corrosion and in accordance with normal
practices of good hold maintenance.

2. Grain clean - the most common standard for all types of bulk cargoes, as
stipulated in charter parties. This standard obviously implies that the holds are
clean enough for grains (including wheat, corn, seeds, beans, etc.) many of which
will be for eventual human consumption. This standard requires that:

a) Holds be clean (washed then rinsed with freshwater)

b) Dry
c) Free of previous cargo residue
d) Free of loose rust scale and flaking paint
e) Free of pests (insects)
f) Free of odor or fumes (from previous cargoes or recently applied paint)

Not stated, but implicit, in the grain clean standard is that most grains or bulk
cargoes will be processed or refined after discharge and are tolerant of small
amounts of contamination.

3. Hospital clean - a stricter standard than grain clean. This standard applies to
cargoes that are easily damaged by any contamination. Processing that will remove
contaminates after discharge is minimal. Examples are soda ash (a white powder
used in making glass, paper, and detergents that is easily discolored by rust),
titanium slag, rutile sand, or white rice which may be directly bagged for human
consumption.

Hospital clean standards are basically the same as for grain clean but there is no
tolerance for even very small amounts of previous residue or loose rust and paint
scale. In addition, it may require that intact blistering paint, or hard, intact corrosion
be removed and areas of bare steel recoated.

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 CLIPPER BULK − CLEANING MANUAL June 2006

008 - Surveyors and Standards of Cleaning Version 1.0

4. AQIS clean - this standard is established by the Australian Quarantine and

Inspection Service (AQIS) for some cargoes, particularly fertilizers, imported to
Australia. Originally, this standard focused on ensuring the vessel was free of
previous grain residue. This was done to prevent contamination of fertilizer by a
grain fungus called Karnal Bundt which was feared could spread to Australian
crops. The standard then came to include any organic material, not just grain,
including log bark. Inspection standards now include ANY cargo residue.

There have been a number of instances whereby AQIS inspectors at Australian

disports have found residues and refused to allow the ship to discharge in Australia.
This has required that the cargo be resold and discharged in another country at
tremendous expense.

The AQIS Surveyor’s Guidelines states, “The inclusion of a single grain of foreign seed
in a cargo of fertilizer could be sufficient cause for AQIS to condemn the entire
shipment and require it to be re-exported. In terms of quarantine contamination, items
of quarantine concern include, but are not limited to:

Grains and cereal crops (wheat, barley, oats, maize, sorghum)

Leguminous crops (beans, peas, soybeans, lucerne)

Meals and stock feed

Oilseeds

Rice

Sugar

Sand and soil

Plant material (leaves, weeds, seeds, twigs, wood chips, bark)

Animal material (feathers, bird excreta, etc.)

Other quarantineable items identified in the Quarantine Act of 1908 and other
applicable regulations.”

Bird excreta!

To mitigate the possibility of a vessel failing inspection in Australia prior to discharge of

cargo, the Fertilizer Industry Federation of Australia (FIFA) has trained surveyors in
AQIS standards to inspect vessels prior to loading fertilizer cargoes bound for
Australia. These inspections are carried out in daylight with hatches open. Cherry-
pickers are used and surveyors are extremely thorough and meticulous; handheld
lights and mirrors are used.

FIFA inspection protocols for holds and hatch covers stipulate that:

Holds free of ANY previous cargo residue

Holds and hatches are free from loose rust, scale, or paint

Holds are dry, clean, and odor-free

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Confidentiality Notice
This document is strictly confidential and is solely for the use of the intended recipient. No part of this document may be photocopied or faxed or
reproduced in any way or distributed to any other party, without the express written consent of Clipper Bulk A/S.
 CLIPPER BULK − CLEANING MANUAL June 2006

008 - Surveyors and Standards of Cleaning Version 1.0

Particular emphasis on previous cargo on overhead beams, hatch-end beams,

hatch cover joints and hinges, frame brackets, pipe brackets, ladder-ways,
manhole covers, etc.

Hatch covers should be opened and closed at least three times each prior to
cleaning to shake down any remnants of past cargoes.

Bilge covers, access covers, tank top manholes, should be inspected and properly
secured.

Bilge wells clean and dry with pumps in good working order

Request may be made to seal ventilator shafts if their condition is suspect

Hatch covers must be demonstrated to be watertight

AQIS elaborates: Hatch cover wheels, hinges, joints, channels, cleats, dogs
(including washers), drains, and gaskets to be inspected. Greased areas to be
checked carefully. Hatch cover tops and undersides to be carefully inspected in
both the open and closed positions.

AQIS states, “Every inch of the cargo holds must be closely examined. If there are
any areas that cannot be properly inspected due to ship’s fittings, the fittings must
be removed to permit the required inspection.”

FIFA inspection protocols for deck areas stipulate that:

Deck areas to be free of ANY previous cargo residue.

AQIS guidelines for deck areas further state, “Sheets of loose scale may also conceal
residues and for these reasons, all loose material should be removed. The application
of fresh paint on deck can be a good idea but mariners should be instructed not to
paint over any loose material - grains/organic material are no less of an issue to AQIS
if they are painted over,” and, in addition require:

Areas under and around pipelines, walkways, deck fittings, grabs, mooring
machinery, storerooms, and the tops of mast houses be inspected.

Both accommodation ladders, winches, and falls are to be thoroughly inspected.

Cranes (inside and out), wires, blocks and associated hardware to be inspected.

Note: These are considered to be minimum standards.

Coaming brackets, piping, bulwarks, stanchions, etc., are all thoroughly examined. Log
lashing gear will be checked to ensure there are no bits of bark embedded in wires,
chains, and hardware. Particles of bark are frequently found embedded on timber
stanchions. Any wood, plywood, and corn type brooms are not acceptable.

Summary
The problem with the hold inspection process is that, particularly for grain clean
standards, there is required of the surveyor a certain degree of judgment as to what is
a satisfactory standard of cleanliness for the intended cargo to load.

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Confidentiality Notice
This document is strictly confidential and is solely for the use of the intended recipient. No part of this document may be photocopied or faxed or
reproduced in any way or distributed to any other party, without the express written consent of Clipper Bulk A/S.
 CLIPPER BULK − CLEANING MANUAL June 2006

008 - Surveyors and Standards of Cleaning Version 1.0

Surveyors always pay very close attention to hatch covers, hatch coamings, and
overheads. The most obvious sign of cargo contamination is residue that can be seen
on top of the cargo after opening hatches at the disport; this residue typically falls from
unclean hatch covers or overheads. This is a sign that the surveyor didn’t do a good
job and he may be called into question if there is a cargo claim.

For grain clean or lower standards, surveyors frequently inspect the interior of the hold
from the tank top only. If residue is noted in the upper reaches they may request
ladders or other means of access for closer inspection.

Even though hospital clean and AQIS standards are explicit in their requirements,
there is still room for judgment. For example, a vessel that had previously carried a
cement cargo was found to be clean of all organic material and loose rust and paint on
deck and in holds. There still remained, however, patches of very thin, hardened
cement residue even after thorough cleaning by pressure washers and mechanical
tools. The surveyor was able to dislodge very small amounts of cement dust by
aggressively using his sharpened scraper on a small area.

Common sense would seem to indicate that none of this residue could possibly
contaminate the fertilizer. But, the surveyor, citing the ANY previous residue provision
of his inspection protocols, insisted all this residue be removed. With the crew using
man-lifts and working with scrapers, around the clock for four days, the holds passed
inspection. After passing, it was still possible to find small patches of thin hard residue
whereby dust could be raised by forceful scraping.

In other words, under almost any circumstance, even with vessels on their maiden
voyage, surveyors can find something to fail holds. Often, their judgments may appear
to be completely unreasonable but argument is almost always futile and may anger the
surveyor and result in a more stringent inspection.

There is a common perception that surveyors will fail obviously clean holds because
they are working in collusion with the terminal or Charterer. This might be because the
cargo is not ready to load or is unavailable. Failure of the holds in such situations puts
the vessel off-hire and saves the Charterer or terminal money at the expense of the
shipowner. This should never be assumed much less mentioned to the surveyor. In
reality, most surveyors are honorable individuals with their own interpretations of
cleanliness standards.

It is important to establish a friendly, cooperative relationship with the surveyor. Be

ready for his arrival with at least one hatch open and ready for inspection and the next
hatch open when he is ready. At a minimum, the Chief Officer (and the Master if
available) and three crewmen should accompany the surveyor during inspection.
Ladders, tools, buckets, etc., should be available so that the crew can clean any
problems areas noted by the surveyor immediately.

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Confidentiality Notice
This document is strictly confidential and is solely for the use of the intended recipient. No part of this document may be photocopied or faxed or
reproduced in any way or distributed to any other party, without the express written consent of Clipper Bulk A/S.
 CLIPPER BULK − CLEANING MANUAL June 2006

008 - Surveyors and Standards of Cleaning Version 1.0

If it does not appear that the holds will pass, insist that the surveyor note precisely the
areas to be cleaned in each hold and what method he would prefer to see them
cleaned (many surveyors will not give advice on how to clean - that is up to the crew).
Have the surveyor or crew mark areas to be cleaned with chalk. Make precise notes.
On re-inspection, you can show the surveyor that work has been completed as per his
recommendations.

If the holds do not pass on the initial inspection, quickly organize the crew into
remedying the situation and get them to work. This will make a good impression on the
surveyor.

Again, surveyors do not want to argue with you, they must be taken seriously and the
crew must respond quickly to their concerns. There is simply no other way to approach
this.

Cleaning Manual / 008 - Surveyors and Standards of Cleaning Page 5

Confidentiality Notice
This document is strictly confidential and is solely for the use of the intended recipient. No part of this document may be photocopied or faxed or
reproduced in any way or distributed to any other party, without the express written consent of Clipper Bulk A/S.