WILL the lessons learned from the sinking of the very large ore carrier Stellar Daisy simply be too late to make a difference?

It has already been two years since the 266,141 dwt vessel, which had been converted from a very large crude carrier, sank in high seas in the South Atlantic on its way to China from Brazil. Two crew members were rescued out of 24 on board.

The Marshall Islands, which flagged the 23-year-old vessel and which was the lead investigator, published its accident report in recent days, noting “catastrophic structural failure”.

A spokesperson for the flag state administration told Lloyd’s List that it has submitted its findings to the International Maritime Organization for review during a working group on casualty analysis in the Implementation of IMO Instruments sub-committee which next meets in July.

“We are in the process of submitting the recommendations in the report to IMO for consideration at [the Maritime Safety Committee which will meet in May next year]”, the spokseperson said.

The IMO confirmed that any specific proposal to amend a code, including the Safety of Life at Sea Convention, needs to be put forward for consideration by the relevant body. A two-thirds majority is also needed for any amendments to be approved.

The time it therefore takes from proposal to adoption, and entry into force would be a minimum of 24 months, according to the IMO, which added that if an issue is deemed urgent, member states can call for an extraordinary meeting.

Too late?

“By the time any changes to the regulations are made, converted VLOCs will be retired or scrapped due to age or end of charters,” the Dry Bulk Terminals Group executive director Nicholas Ingle said.

The process could be simpler and therefore quicker, he said, adding that the biggest issue would be getting input and agreement from all member states. 

"Our regulator has no teeth and as a result relies on member states to bite," he said.

The IMO told Lloyd’s List that “the process is the process” and was set up by member states in 1974. “The system is set.”

But if a member state wants to change the process, it needs to raise the issue at the relevant committee or sub-committee. 

There are 45 converted vessels still trading in the fleet, posing risks to seafarers. Most were built as single-hull tankers in and around 1993, meaning they are more than 25 years old as of today. By 2021, that number will have dwindled as the natural end-of-life cycle occurs.

But as the Stellar Daisy report shows, there are safety risks associated with these types of conversions.

Recommendations

The Marshall Islands has identified some areas for improvement to avoid similar tragedies, including aligning bulk carrier inspection regimes with those of tankers.

The IMO's 2011 ESP code states that water ballast tanks on bulk carriers be inspected annually if the condition of the coatings is "poor", while for tankers, annual checks are required if the condition is "less than good", meaning it is more stringent.

“While acknowledging the environmental consequences of a major oil spill are significantly different than the environmental consequences associated with the loss of a bulk cargo, the potential loss of life associated with the loss of a tanker or a bulk carrier is the same,” according to the report. 

A revision to the International Maritime Solid Bulk Cargoes Code has also been recommended to make it mandatory for independent third-party laboratories to test cargo moisture as per the Transportable Moisture Limit rules which are in force to avoid liquefaction.

It also recommended an amendment to Solas Chapter XII that requires bulk carriers of more than 150 m carrying Grade A cargoes to have sufficient stability and strength to withstand liquefaction in one or more holds. 

Although the Solas Chapter XII regulation does require water level detectors, it does not currently have a reference to “liquefaction” or to Grade A cargoes. These are however noted in the mandatory IMSBC code.

Intercargo this week identified liquefaction as the major cause for loss of life on bulkers.

Conversion safety

The International Association of Classification Societies, which found no safety issues with converted VLOCs, said it is initiating a review of the Stellar Daisy investigation report “imminently”.

It could not say how long it would take to conduct its review.

The group said in its 2017 annual report that “no safety-related critical structural damages have been identified and there is no clear justification for any IACS work on these vessels”.

It said in an email that IACS does not have rules for VLOCs, although individual members will have their own rules. 

The Korean Register, which was responsible for classing 30 converted VLOCs, 18 of which were in the Polaris Shipping fleet, said that it complied with all relevant rules and regulations concerning the conversions, and has, in large part, agreed with the Marshall Islands' recommendations.

It noted that “any proposal of a new work programme suggesting the development of new requirements or amendments to existing requirements of IMO mandatory instruments must be made through IMO member states; they are not for individual class societies or NGOs to initiate”.

Since the design of Stellar Daisy was similar to that of the other converted VLOCs in terms of structural configuration, compartment arrangement, reinforcement, hull materials, longitudinal strength, transverse strength and local strength, KR carried out emergency inspections on 29 vessels following the Stellar Daisy incident.

Based on the surveys, “proper repairs” were carried out, while a dozen other vessels were inspected by the South Korean government, the Marshall Islands and a different classification society, it said. 

Flooding risk

A number of bulk carriers were lost due to flooding in the 1990s, according to KR, which led to revisions in the Solas regulations.

The worry for converted VLOCs is that they have large water ballast tanks, which “increases the potential for a major structural failure and loss of buoyancy in the event that a WBT floods when the ship is in a laden condition”, KR noted in a response to questions from Lloyd's List.

The current Solas regulations, however, only consider flooding of cargo holds, but not WBTs, it said, adding that this is the gap in the additional safety measures that is mentioned in the Marshall Islands report.

KR said that “with any action taken by IMO, IACS and its member societies will need to revisit the IACS requirements already in place to ensure that they are adequate to effectively prevent tragic accidents. KR, as an involved society, will also carry out a thorough review of its own rules and procedures to see whether there any areas to improve the safety of converted VLOCs.”

“The results of our findings will be fed back to IACS so that potential changes to global practices can be assessed and strengthened.”