Serving you at

over 500
locations in 100
countries
worldwide, with
a focus on Asia-
Africa and
Middle East
INTRODUCTION TO BULK
CARRIERS
What is a bulk carrier ? 

"A ship which is intended primarily to carry dry cargo in bulk, including such types as ore carriers
and combination carriers" 

Bulk carriers are single-deck vessels, designed with top-side tanks and hopper side tanks in
cargo spaces and are intended primarily to carry single-commodity solid bulk cargo. 
Solid bulk cargo means any material, other than liquid or gas , consisting of a combination of
particles, granules or any larger piece of material, generally uniform in composition, which is
loaded directly into the cargo spaces of a ship without any immediate form of containment.
Example of such dry cargo are grain, sugar and ores in bulk.
FEATURES OF A BULK CARRIER
 • Carrying capacity varying from 3,000 tonnes to 300,000 tonnes
1

• Average speed of 12 ~ 15 knots

2

• Single deck ships, ie no tweendecks

3

• Small to medium sized bulk carriers (carrying capacity up to 40,000 tonnes) generally have cargo handling
4 gear fitted, while larger vessels use shore based facilities for loading and unloading

• The cargo holds are usually large, without any obstructions, with larger hatch sizes to allow easy
5 loading/unloading of cargoes

• Most bulk carriers have one cargo hold dedicated as a ballast hold. This can be used on ballast voyages for
6 improved stability. One or two further holds may be permitted for partially ballasting but only in port

• They have hydraulic, single pull or stacking (piggy- back) type steel hatch covers
7

• these ships usually have four types of ballast tanks :

(1) sloping topside wing tanks (2) sloping bottom side wing tanks
8 (3) double bottom tanks (4) fore peak and after peak ballast water tank.
TYPES OF BULK CARRIERS
 Less than 10,000MT DWT

Small vessels of less than 10,000 DWT, This category

includes Mini-bulkers, which can carry from 500 to 2,500
tons in a single hold and are designed mainly for river
transport and to pass under bridges. They have small
crews of three to eight people. The photo shows the mini-
bulker Aladin, designed to pass under low bridges.
 Handymax Bulk Carriers

Handysize, range from 10,000 to 35,000 DWT, These smaller

Handysize and Handymax vessels are the workhorses of the dry bulk
market, and they have the highest rate of growth. This is because of
the new regulations coming into effect which add greater constraints
on the building of larger vessels.
 SUPRAMAX BULK CARRIERS

Supramax, range from 45,000 to 59,000 DWT, A

Supramax vessel is typically 150 – 200 meters in length
and they have five cargo holds and four cranes.
 PANAMAX BULK CARRIERS

Panamax, range from 60,000 to 80,000 DWT, this size is

restricted by the Panama canal's lock chambers, 32.26
metres in width, 320.0 metres long, and 25.9 metres deep.
They mostly carry coal, grain and minor bulks. The photo
shows the Sea Phoenix, a 40,000 ton Handymax traversing
the Panama Canal.
 CAPE SIZED BULK CARRIERS

Capesize, from 100,000 to 200,000 DWT, these ships are

too large to traverse the Suez or Panama Canals and must
go around the Cape of Good Hope or Cape Horn to travel
between oceans. Because of their size they can only dock
at small number of ports.
 VERY LARGE BULK CARRIERS

Very Large Bulk Carriers, for ships over 200,000 DWT.

The Berge Stahl, shown on the left, is 364,768 DWT and is
the world's largest bulker. Bulk carriers of this size almost
always carry iron ore.
BULK CARGO OPERATIONS
 • Bulk carriers are designed to load a maximum deadweight of any type of bulk cargo from heavy ore to light grain .

• The loading, carriage and finally the discharge of dry bulk cargo is not as simple or straight forward as most people would
imagine.
2

• Many bulk cargoes have hazardous properties, or can change their properties on passage. The ship can be easily
damaged by incorrect loading e.g. loading a forward hold to maximum can cause the ship to bend. This ‘stress’ can have
3 life threatening results at sea in rough weather. 

• Residues from previous cargoes can also seriously effect latter cargoes. Water damage can also have devastating effect
on some bulk cargoes e.g. cement. It is not easy to verify true weights or quantities of cargoes loaded or discharged. All
4 these factors have a serious consequence on the methods of operation for the safe carriage of bulk cargoes.

• Bulk cargoes have an inherent tendency to form a cone when they are loaded if conveyor belts or similar systems are not
supervised and controlled. The angle formed by this cone is known as the `angle of repose' and varies with each cargo.
Cargoes such as iron ore will form a steep angled cone, whereas cargoes that flow freely form a shallow angled cone. A
5 cargo with a low angle of repose has the potential to shift during passage

• For some cargoes, bulldozers may be required to spread the load into the sides of the holds as cargo is nearing
completion.
6
COMMON BULK COMMODITIES
 • Coal 
Coal is transported on all types of bulk carriers from handy size to VLCBs. However, it is not an easy or
straight forward cargo to handle. It can emit methane gas and it is self-heating. In addition coal contains
sulphur which causes severe corrosion when in contact with the ship's steelwork.
In most ports the cargo is loaded wet to reduce dust. Much of this moisture settles on passage and is
1 pumped out through the ship's hold bilges which means that less weight is discharged than is loaded.

• Iron Ore 
This cargo is loaded very fast, 10,000 tonnes an hour is not unusual. The loading and de-ballasting of the
ship must be meticulously planned to ensure that the vessel is not overstressed. There is very little chance
of damaging the cargo but the ship can receive extensive damage during the discharge operation from the

2 equipment used.

• Mineral Concentrates 
Many different types of concentrates are handled in various parts of the world and in varying quantities.
Most of these cargoes are extremely heavy and have a low transportable moisture limit (TML). 
This means that if the moisture content of the cargo become greater than the TML the cargo can liquefy and
turn into a slurry. When this happens on board, the cargo moves from side to side as the ship rolls which
reduces the ship's righting lever. It does not require much cargo weight to capsize the vessel when this
3 happens, it a loss of stability due to free surface effect. Some of the most dangerous cargoes where this can
happen are copper, lead or zinc concentrates, magnetite, limonite and most pyrites.
 • Grain 
One of the most difficult and dangerous cargoes to carry in bulk are grain cargoes. Most grains have an angle
of repose (slip angle) of about 20° from the horizontal, which means that if the ship rolls more than 20° the
cargo will shift. Then this happens the ship will develop a large list, lying on her side and still rolling will
obviously cause a greater shift of cargo which in turn will capsize the vessel. 
Most authorities therefore request that the master proves that his ship is capable of remaining stable even if the
grain cargo shifts. This is done by the compiling of the Grain Loading Form which fully outlines the ships
stability at the worse condition on passage.

4 Naturally grain cargoes, like any foodstuff, are susceptible to claims with contamination from a previous cargo
and in addition can easily be damaged by water.
Vermin can also be a problem. Cargo holds must be clean and dry prior to the loading of any grain cargo and
most grain charters demand a survey of the ship's hold prior to loading for this reason.

• Cement 
Obviously any moisture is going to ruin a cargo of cement but probably a greater danger to the vessel is the
dust that can be produced during the loading and discharge of the cargo. If it is not removed promptly or gets
into the ship's air intakes it can cause some long term problems to the vessel.

5 Salt- Salt, strangely enough, is not damaged from water, in fact the cargo can be loaded slightly moist. However,
it can get rust stained from the ship's steelwork, therefore the ship must cover all the steel within the cargo hold
with a lime wash solution thereby keeping the salt off the steelwork.

• Woodchips 
A supposedly harmless cargo that does have some hidden dangers. Some shipments many be subject to
oxidation leading to depletion of oxygen and an increase of carbon dioxide in the cargo hold and adjacent
spaces. In addition, woodchips can be easily ignited by external sources, it is readily combustible and can also
ignite by friction.
6
LOADING/DISCHARGING
OPERATIONS
i) Prior to loading bulk cargo , the shipper should declare characteristics & density of the
cargo, stowage factor, angle of repose, amounts and special properties.

ii) Cargo availability and any special requirements for the sequencing of cargo operations.

iii) Characteristics of the loading or unloading equipment including number of loaders and
unloaders to be used, their ranges of movement, and the terminal's nominal and maximum
loading and unloading rates, where applicable.
iv) Minimum depth of water alongside the berth and in the fairway channels.

v) Water density at the berth.

vi) Air draught restrictions at the berth.

vii) Maximum sailing draught and minimum draught for safe maneuvering permitted by the
port authority.

viii) The amount of cargo remaining on the conveyor belt which will be loaded onboard the
ship after a cargo stoppage signal has been given by the ship.

ix) Terminal requirements/procedures for shifting ship.

x) Local port restrictions, for example, bunkering and deballasting requirements etc.
 Devising a Cargo Stowage Plan and
Loading/Unloading Plan

Exceeding the permissible limits specified in the ship's approved

loading manual will lead to over-stressing of the ship's structure and
may result in catastrophic failure of the hull structure.

The amount and type of cargo to be transported and the intended

voyage will dictate the proposed departure cargo and/or ballast
stowage plan.

The officer in charge should always refer to the loading manual to

ascertain an appropriate cargo load distribution, satisfying the imposed
limits on structural loading.
There are two stages in the development of a safe plan for cargo loading or unloading:-

Step 1: Given the intended voyage, the amount of cargo and/or water ballast to be
carried and imposed structural and operational limits, devise a safe departure
condition, known as the stowage plan.

Step 2: Given the arrival condition of the ship and knowing the departure condition
(stowage plan) to be attained, devise a safe loading or unloading plan that satisfies the
imposed structural and operational limits.
In the event that the cargo needs to be distributed differently from that described in the ship's loading
manual, stress and displacement calculations are always to be carried out to ascertain, for any part of
the intended voyage, that:

The still water shear forces and bending moments along the ship's length are within the permissible
Seagoing limits.

If applicable, the weight of cargo in each hold, and, when block loading is adopted, the weights of cargo
in two successive holds are within the allowable Seagoing limits for the draught of the ship. These
weights include the amount of water ballast carried in the hopper and double bottom tanks in way of
the hold(s).

The load limit on the tanktop and other relevant limits, if applicable, on local loading are not exceeded.
The consumption of ship's bunkers during the voyage should be taken into account when carrying out
these stress and displacement calculations.
Whilst deriving a plan for cargo operations, the officer in charge must consider the
ballasting operation to ensure:-

Correct synchronisation with the cargo operation.

That the deballasting/ballasting rate is specially considered against the loading rate and the
imposed structural and operational limits.

That ballasting and deballasting of each pair of symmetrical port and starboard tanks is
carried out simultaneously
During the planning stage of cargo operations, stress and displacement calculations should be carried
out at incremental steps commensurate with the number of pours and loading sequence of the
proposed operation to ensure that:

The SWSF and SWBM along the ship's length are within the permissible Harbour limits.

If applicable, the weight of cargo in each hold, and, when block loading is adopted, the weights of
cargo in two adjacent holds are within the allowable Harbour limits for the draught of the ship. These
weights include the amount of water ballast carried in the hopper and double bottom tanks in way of
the hold(s).

The load limit on the tanktop and other relevant limits, if applicable, on local loading are not exceeded.

At the final departure condition, the SWSF and SWBM along the ship's length are within the
permissible Seagoing stress limits
During the derivation of the cargo stowage, and the loading or unloading plan, it is
recommended that the hull stress levels be kept below the permissible limits by the
greatest possible margin. A cargo loading/unloading plan should be laid out in such a way
that for each step of the cargo operation there is a clear indication of:-

The quantity of cargo and the corresponding hold number(s) to be loaded/unloaded.

The amount of water ballast and the corresponding tank/hold number(s) to be

discharged/loaded.

The ship's draughts and trim at the completion of each step in the cargo operation.

The calculated value of the still water shear forces and bending moments at the completion
of each step in the cargo operation.

Estimated time for completion of each step in the cargo operation.

Assumed rate(s) of loading and unloading equipment.

Assumed ballasting rate(s)

 • The loading/unloading plan should indicate any allowances for cargo
stoppage (which may be necessary to allow the ship to deballast when the
loading rate is high), shifting ship, bunkering, draught checks and cargo
trimming.
1

• The loading or unloading plan should only be changed when a revised plan
has been prepared, accepted and signed by both parties. Loading plans
should be kept by the ship and terminal for a period of six months.
2

• A copy of the agreed loading or unloading plan and any subsequent

amendments to it should be lodged with the appropriate authority of the
port State.
3
OPERATIONAL GUIDANCE
 Operational guidance

All bulk carrier officers should have clear guidance

and instructions available onboard their ship.

There should be guidance on:-

safety aspects of bulk cargo carriage etc
(liquefaction, heating, hazardous gases,
preparation of holds carriage requirements of bulk cargo
oxygen depletion, entry into enclosed
spaces)
CASE STUDY-1
M.V Trans Summer
VESSEL PARTICULARS:-

Year Of Bulit:2012

Flag: Hong Kong

Summer DWT:56824

LOA:190 M

Max Breadth:31 M

Summer Draft:13 M

No of Cargo Holds: 5

No of Cranes: 4
 SUMMARY OF INCIDENT:-

Port of Loading: Subamin-Indonesia

Cargo:Nikel Ore in Bulk

Date NOR Tendered: 15th July 2013

Commenced Loading Operations:17th July 2013 at 1230hrs

 Facts leading upto the Incident:-
On 10th July 2013 the Charterer sent a Notice to the Master reminding him to pay particular attention to the possible high
moisture content in the cargo and recommended that a “Can Test” should be conducted on each barge prior loading

Loading commenced on 17 July at 1230 after the Chief Officer and Chief Engineer inspected the nickel ore mine

Although the Master had already received a cargo declaration together with a moisture certificate issued by shipper, the
Chief Officer and Chief Engineer did not verify the conditions of cargo stockpiles nor were they aware whether the cargo
stockpiles would be covered by tarpaulins to prevent wetting.

The cargo declaration showed that the moisture content at time of sampling was 33.87% and had a flow moisture point of
38.66% with a resulting transportable moisture limit of 34.79%

It was noted that it rained frequently during the loading of cargo. To avoid rainwater wetting the cargo, the loading
operation was suspended during these times. The crew on board the vessel closed the cargo hold hatches while the
stevedores on the barges covered the cargo using tarpaulins

A “Can Test” was performed on each barge prior to transfer to the Trans Summer. The “Can Test” samples were taken from
approximately 1 m below the cargo surface. If the “Can Test” failed, the moisture content was determined and if the
moisture content was found to exceed the transportable moisture limit then the cargo was rejected. The results of all the
cargo moisture content tests were recorded and sent to the vessels owner

Subsequently, all documents on the vessel including the above records were lost in the accident. The information
regarding the cargo loading sequences was retrieved from emails exchanged between the Trans Summer and the vessels
owner,
on 23 July a moisture content certificate was received; however, nobody on board the vessel checked the cargo
declaration and certificate. As a consequence, they did not know the moisture content of cargo loaded into the cargo holds
from 24 to 30 July

On 30 July, the moisture content certificate was checked by the crew and it was sent to the company. It showed that the
moisture content at time of sampling was 33.88% and had a flow moisture point of 38.69% and a resulting transportable
moisture limit of 34.80%. The vessel accepted cargo on two occasions with a moisture content exceeding the transportable
moisture limit

The loading was completed on 6 August.On 7 August at approximately 1342hrs, the vessel departed Subaim, Indonesia,
bound for her discharge port in Yangjiang, China. Everything was found normal upon departure with the stability of the
vessel intact.

During the voyage, on 9 August, the cargo in hold number 4 was inspected and found to be normal. No further inspections
were performed. On the same day, the Master was informed to monitor a tropical depression developing in the Philippines.

On 10 August, the tropical depression developed into typhoon “Utor,” which was predicted to make landfall close to Trans
Summer’s discharge port in Yangjiang, China. Typhoon precautionary measures were then executed by the crew.

On 12 August at 1540, the Master altered course towards Wanshan QuanDao, China (about 100 miles from Yangjiang), to
shelter from the typhoon. On 13 August at 2000, after anchoring 2 nautical miles off the coast, easterly winds increased to
force of 8 to 9 and wave height increased to approximately 5 to 6 meters. The rolling and yawing of the vessel at this time
were 10 degrees with increasing periods

Early morning on 14 August, the wind was continuing at force 9 blowing in an easterly direction and the vessel was yawing
about 10 degrees and rolling about 7 to 8 degrees. At 0757, the wind was now blowing from the southeast at force 9 with
wave heights about 4 to 6 meters.

The distance to typhoon centre was about 120 nautical miles. At 1000, the wind force intensified to force 10 with wave
heights up to 7 meters. At 1010, a high wave rushed from the starboard side causing the vessel to heel port side more than
20 degrees immersing the deck edge in water. The vessel then rolled back and stayed listing about 10 degrees to port. The
listing to port then increased to 15 degrees soon afterwards and persisted
Ballast was then used to try to correct the list but it was mistakenly pumped into the starboard top tanks instead of the
double bottom tanks causing the vessels centre of gravity to increase.

At 1030, when the vessel listed to port about 17 degrees, the second officer transmitted a distress signal under Master’s
order and life rafts and the lifeboat were prepared for launching. The Master announced abandon ship at 1105 the same day

The following are the main conclusions from the investigation into the sinking of the Trans Summer:-
(1)The requirements of IMSBC Code for the cargo of nickel ore, under groups A and B, were not strictly followed.

(2)The safety shipboard procedures for loading and carriage of nickel ore were not followed.

(3)Liquefaction of cargo inside cargo holds while the anchored vessel experienced rolling at the anchorage, compounded
by worsening weather and sea condition due to approaching of typhoon and mistakenly pumping water into ballast tank

(4)Master’s assessment to select the shelter for the vessel to anchor was not appropriate

(5)The moisture content certificate was issued by the shipper instead of local administration or independent organization
(or authorized organization)

(6)The crew was not trained and therefore not competent to carry out Testing on board to verify the moisture content of the
cargo before loading.
CASE STUDY-2
M.V Bulk Jupiter
VESSEL PARTICULARS:-

Year Of Bulit:2006

Flag: Bahamas

Summer DWT:56,009

LOA:190 M

Max Breadth:32 M

Summer Draft:13 M

No of Cargo Holds: 5

No of Cranes: 4
 SUMMARY OF INCIDENT:-

Port of Loading: Kuantan-Malaysia

Cargo:Bauxite in Bulk

Date NOR Tendered: 12th December 2014

Commenced Loading Operations:17th December 2014 at 2100hrs

 Facts leading upto the Incident:-
The east coast of Malaysia had endured record-breaking rainfall over the month of December 2014.
The loading operations continued for an extended period of time due to heavy rain and technical delays.

During periods of rain, vessels generally close their hatch covers to prevent any moisture from entering cargo holds and
maintain the cargo in a dry condition. However, any cargo left on the quayside was left uncovered and therefore exposed
to the elements.

It was observed that during the transportation of Bauxite on load trucks from the mines to the port and subsequently to the
vessel it was not protected from exposure to rain.

At the time of loading there was no transportable moisture limit test performed on the bauxite as in the IMSBC Code, under
the individual schedule for bauxite, it did not state the cargo was potentially liquefiable

On 30 December at 2124, the Bulk Jupiter left Kuantan, Malaysia, bound for Qingdao, China, with 46,400 tonnes of bauxite
on board and stability intact.

After clearing the breakwater, the vessel was observed to be rolling about 2 to 3 degrees in low swell.

On 31 December, part way into the voyage, the weather deteriorated. Wind was forecast north-east at a force of 6 to 7, wind
speed 24 to 34 knots, and sea state from 4 to 6 and with an average wave height of 2.2 m.
 Facts leading upto the Incident:-
The east coast of Malaysia had endured record-breaking rainfall over the month of December 2014.
The loading operations continued for an extended period of time due to heavy rain and technical delays.

During periods of rain, vessels generally close their hatch covers to prevent any moisture from entering cargo holds and
maintain the cargo in a dry condition. However, any cargo left on the quayside was left uncovered and therefore exposed
to the elements.

It was observed that during the transportation of Bauxite on load trucks from the mines to the port and subsequently to the
vessel it was not protected from exposure to rain.

At the time of loading there was no transportable moisture limit test performed on the bauxite as in the IMSBC Code, under
the individual schedule for bauxite, it did not state the cargo was potentially liquefiable

On 30 December at 2124, the Bulk Jupiter left Kuantan, Malaysia, bound for Qingdao, China, with 46,400 tonnes of bauxite
on board and stability intact.

After clearing the breakwater, the vessel was observed to be rolling about 2 to 3 degrees in low swell.

On 31 December, part way into the voyage, the weather deteriorated. Wind was forecast north-east at a force of 6 to 7, wind
speed 24 to 34 knots, and sea state from 4 to 6 and with an average wave height of 2.2 m.
The following are the main conclusions from the investigation into the sinking of the Bulk Jupiter:-

(1)There is significant documentary evidence to identify that the 46,400 t of bauxite loaded over the course of the 13-day
period had an average moisture content of 21.3%. Despite this, there is no physical evidence to confirm what caused the
vessel to adopt an unrecoverable list to starboard and subsequent capsize.

(2)It was found that the cargo declarations were considered generic, including the declared 10% moisture content of the
cargo. This was found when comparisons were made between the Bulk Jupiter’s cargo declaration and declarations of the
bulk carriers Orchid Island and Medi Okinawa which alsoi loaded from the same port

(3)Communications between the Master and the company ship manager indicated the Master had a lack of understanding
of the practical method for determining excessive moisture content of a bulk cargo, specifically the “Can Test.”

(4) In total 186.55 hours of loading was lost due to rainfall, the equivalent of 7 days of loading over the period. The
infrastructure available to adequately store and transport bauxite in Kuantan increased the exposure of the bauxite to the
elements. Despite the crew’s diligent response to the rain by continually opening and closing the hatch covers to reduce
the ingress of water, the cargo remained exposed while on the quayside, in stockpiles, and in the trucks.

(5)An independent inspection was not requested by the Master to verify the properties of the cargo prior to loading on
board. Considering the extreme weather conditions and storage facilities available it was acknowledged that the cargo was
very wet and that measures to protect the cargo on shore from further rain were not effective in preventing further wetting.
The absence of an independent inspection resulted in the cargo being loaded without its physical properties and moisture
content being verified against the parameters of the IMSBC Code schedule or the cargo declaration form
The following are the main conclusions from the investigation into the sinking of the Bulk Jupiter:-

(7)The previous class and special survey inspections indicate no structural integrity failures; the vessel had fulfilled
diligently all prior certification conformity requirements and as such the likelihood of a catastrophic structural failure is
considered low.

(8)Having presumed that the probability of structural failure is low, as a singular causal event, it can be concluded that
either liquefaction or a free surface effect induced an unrecoverable list. When considering the conditions in the order that
they occurred, there can only be very few circumstances that cause a vessel to capsize so quickly with minimal warning.
Due to the reliability of the information provided on the cargo declaration, in particular the composition of cargo, it has
been determined that the probability of liquefaction occurring is considered high. A further causal event, for which it would
only occur if the cargo is sufficiently compacted, is a free surface effect generated on top of the cargo. Notwithstanding
this, if the cargo had liquefied, a free surface effect will also occur, with similar catastrophic effect. Another related
phenomenon associated with both liquefaction and free surface effect occurs when the cargo slides to one side of the
vessel and fails to return to where it came from. This particular effect would be inevitable once the angle of heel is greater
than the angle of repose of the cargo, if untrimmed or if the cohesion between the particles of the cargo is insufficient
when an angle of heel is induced.
HEAVY WEATHER DAMAGE
 Heavy Weather Damage Case Study:-
All Cargo Hatch Covers battened down and sealed with hatch sealing tape.
(RAMNEK TAPE)

Successfully underwent Hose Test and Cleanliness Inspection in the presence of

Surveyor.

During the course of the voyage following encountered:-

Heavy Weather with winds of up to Force 10 on the Beaufort Scale.

Excessive Rolling and Pitching with Heavy Seas shipping all over exposed decks
and spray all over.

Upon Arrival at the Discharge Port following was observed:-

Top Surface of the Cargo was wet,caked and mouldy.

 Heavy Weather Damage Case Study:-
Findings:-

An external surveyor at the discharge port inspected the cargo hatch covers,
paying particular attention to:-

Rubber Gaskets

Closing Devices

Non–Return valves

Ventilators

Hatch Access

Double Drainage Channels etc.

All were visually found to be in good working order

 Heavy Weather Damage Case Study:-

Conclusions:-

Traces of Sea Water were found on the Inner Hatch Coaming.

An ultrasonic test was conducted on the affected hold and it was found that the
cross joints between forward and aft hatch panels, had leaked.

It was also found that there was no contact between compression bars and
rubber gaskets on the cargo hatches cross joint panel
SINKING OF “DERBYSHIRE”
 SINKING OF “DERBYSHIRE”
• Causes:-
1

• Catastrophic Structural Failure due mountainous seas

2 and swells

• Over Reliance on Shore Based Routing Service

3

• Lack of Command and Control as no attempt

4 observed to initiate Abandon Ship Procedures
“We see things from our customer’s point of view – they
want their delivery to be timely and hassle-free.”