As a result of several incidents where containers have been lost overboard, the Australian Maritime Safety Authority (AMSA) has decided to carry out a focused inspection campaign on cargo securing arrangements that will run from 1 August to 31 October 2020. This campaign is not included in the PSC inspection and its results will not be transmitted to regional PSC regime databases. However, in cases of non-compliance, the attending AMSA surveyor may proceed to a full PSC inspection.
Relevant for ship owners, operators and managers of ships carrying cargo in containers.
According to AMSA, the aim of the focused inspection campaign (FIC) is to draw the attention of ship owners and operators to their obligations under Regulations 2 and 5 of Chapter VI of SOLAS.
The campaign focuses on the use of cargo information, as well as the stowage and securing of unitised cargo. AMSA will focus on non-Australian flagged vessels entering Australian waters, that must comply with cargo securing arrangements approved under Regulation 5 of Chapter VI of SOLAS. It is not a concentrated inspection campaign (CIC) by a PSC regime.
The FIC inspection is not part of a PSC inspection and data about the FIC inspection will not be transferred to the regional PSC regime database. However, if during a FIC inspection the AMSA surveyor discovers clear grounds for non-compliance, the AMSA surveyor may proceed to a full PSC inspection. The results of that PSC inspection will be forwarded to the regional PSC database.
Details on the release are available in the AMSA marine notice 05/2020.
We would like to share some possible areas that could be covered in the FIC:
- Approval of cargo securing manual according to latest regulation
Latest regulation is MSC.1/Circ.1353 Rev.1. This circular superseded previous MSC/Circ.745 requiring no new content for existing vessels except for a maintenance record for lashing equipment, which is however not subject to approval. Operators should make sure they have this maintenance record available on board.
- Sufficient amount of lashing equipment on board
The Cargo Securing Manuals (CSM) usually contain a list of lashing devices for the described lashing pattern as well as the estimated number of devices that should be on board the vessel. These figures refer to an agreement between the supplier of the lashing system and the owner of the vessel and are based on an estimated cargo mix of different container types.
The cargo mix may change during service, sometimes even before delivery of the vessel, and may lead to a change in the number of lashing fittings estimated to be necessary on board. In DNV GL’s opinion only the actual number of lashing devices necessary to secure the actually intended stow of containers, in accordance with the lashing pattern given in approved CSM, are required.
- Lashing computer
To prove that the actual loading condition would be compliant with relevant regulations, the crew must be trained and confident in using the approved loading and lashing computer. Any condition exceeding max. permissible stackweights or permissible lashing forces may lead to a full PSC inspection by AMSA and result in a detention.
- Lashing pattern
For actual loading conditions the lashing patterns must be in line with the schemes shown in the cargo securing manual. There have been claims recently that twistlocks for use between containers have been used as bottom layer twistlocks.
Bottom layer twistlocks usually have a larger flange size to transfer high compression loads. It is possible to use intermediate semi-automatic twistlocks in the bottom layer as well, however the max. compression will be reduced which is not accounted for in lashing computers. Therefore, it is highly recommended to make sure that only bottom layer twistlocks are used on the hatch cover/deck level.
- Lashing equipment type and condition
It has been observed that the worn condition of fixed lashing equipment, in particular, may have contributed to loss of containers. Heavily corroded raised sockets and broken lashing eyes should be replaced. The new equipment shall be delivered with a product (batch) certificate issued by DNV GL. The new lashing equipment shall be of same type.
If the maker or type are changed, then it must be ensured that new equipment is certified for the same loads, has the same function principle and the same geometric properties. The replacement shall be documented in the alteration page of the cargo securing manual and confirmed by a surveyor stamp. Furthermore, the product certificates, handling and maintenance instructions, and prospect drawings of the new equipment shall be appended to the cargo securing manual. Alternatively, an addendum to the cargo securing manual for the replacement of lashing equipment can be submitted for approval.
- Heavy over light stowage
This means a heavier container is stowed in a higher layer than a container with significantly less weight in the same stack. There is a rule of thumb to avoid heavy weight cargo in top tiers, if possible, in order to reduce dynamic forces. However, this rule dates back from times where the cargo securing manual was the only instrument to evaluate forces in container stacks.
Nowadays, most vessels have an approved lashing computer on board, that calculates lashing forces in accordance with the relevant container lashing rules of class societies for the actual loading condition. Lashing force calculations according to rules of DNV GL cover dynamic loads that occur in the stack in roll motion and heave and pitch motions. Therefore, it is possible to evaluate each individual container stack even for heavy over light stowage. Nevertheless, we suggest that, if possible, heavy containers should be placed as low as possible in the stack to minimize the resulting dynamic forces
- Familiarize with the content and instruct master and crew accordingly
- Use DNV GL’s DATE service for any technical questions
- AMSA Marine Notice 05/2020
- AMSA checklist for FIC on cargo securing arrangements
- AMSA marine notice 03/2018
- AMSA marine order 42
- AMSA home page