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Key considerations for mitigating accidents during fumigation

[caption id="attachment_57152" align="alignright" width="365"] Photo credit: Gard P&I Club[/caption]

Gard P&I Club has provided key recommendations to mitigating accidents during fumigation operations, especially while in transit. Fumigation of cargo holds using aluminium phosphide tablets, which release phosphine gas, is essential to protect products from infestation and ensure they arrive in good condition. The heavier-than-air phosphine gas penetrates the cargo to eliminate insects and pests.

However, according to Gard, despite the existence of industry best practice recommendations, fumigation-related incidents continue to occur. While it remains uncertain how many fatalities could have been prevented through stricter adherence to the current IMO guidance, many incidents have been linked to the absence of vessel-specific procedures, underestimation or lack of awareness of the risks involved, or decisions influenced by commercial pressures.

The IMO best practice recommendations clearly assign primary responsibility for the fumigation process to the designated fumigator-in charge. However, the vessel operator and master remain responsible for ensuring safe working conditions onboard. Therefore, when fumigation is planned – especially if treatment will continue during the voyage – the precautions outlined in MSC.1/Circ.1264 should be reviewed and used as a basis for establishing appropriate vessel-specific safety protocols within the Safety Management System (SMS).

A checklist can be prepared using Appendix 3 of the IMO circular, Model Checklist for In-Transit Fumigation, or by referring to the Fumigation Checklist found in the Fumigation Handbook published by the United States Department of Agriculture (USDA).

In addition, the following measures should be considered, Gard Club highlights:

- Conduct or reaffirm risk assessments, ensuring that all hazards associated with fumigated cargoes, including toxic exposure, oxygen depletion, fire, and explosion risks, are identified, addressed, and managed throughout the voyage.
- Ensure vessel-specific enclosed space registers and entry procedures clearly recognise the presence of dangerous fumigant gases as an added risk – both for cargo holds and for spaces connected to or adjacent to fumigated holds.
- Provide comprehensive general-level training to all crew members. In addition, when in-transit fumigation is planned, the fumigator-in-charge should brief all crew members directly on fumigation hazards, symptoms of exposure, and emergency actions – rather than delegating this responsibility solely to the designated vessel representatives. Ensure full attendance and understanding during safety briefings.
- Verify that emergency procedures are in place to deal with crew exposure to fumigant gases. The US CDC’s emergency response card on phosphine provides useful information. Medical officers could also consult the emergency section of the Mariners Medico Guide for up-to-date guidance on treating patients exposed to poisonous gases.
- Require thorough pre-loading gas-tightness inspections by the fumigator-in-charge, with documented results. Where gas-tightness cannot be determined with certainty, implement additional risk control measures, such as supplementary gas monitoring. After fumigant application and before disembarkation, require the fumigator-in-charge to inspect and confirm that no gas leaks are present and to formally attest that conditions onboard are safe.
- Emphasise the designated vessel representatives’ responsibility to participate in both pre-loading and post-fumigation inspections. This promotes crew awareness and familiarity with vessel conditions and potential risk areas. However, avoid placing responsibility on the master or their representatives to sign-off for gas-tightness and safe conditions, as this may create a conflict of interest.
- Implement procedures to minimise crew time spent on deck and near hatch covers during the first 24 to 36 hours after fumigation has been set – when the risk of fumigant gas explosions is highest.
- Equip vessels with reliable portable atmosphere testing instruments, fitted with sensors capable of detecting fumigant gases such as phosphine, and increase the frequency of gas checks.
- Arrange for continuous atmosphere monitoring in high-risk areas, such as spaces connected to or adjacent to fumigated cargo holds, especially if those spaces are designed for continuous occupation or are frequently accessed.
- Assess the impact of modifying or interrupting ventilation system airflow during the voyage, as such changes may increase the risk of hazardous conditions.
- Reinforce that crew should never handle fumigants. If top-up fumigation is required during the voyage (e.g. for log cargoes), request the fumigator-in-charge to sail with the vessel.
- Establish a clear company policy on the use of adequate respiratory protection for personnel that enter holds where fumigants have been present – acknowledging that hazards may persist even after a hold is certified gas free and spent fumigants have been removed, and warning crew and port workers to remain vigilant and use appropriate protective equipment until all risks are eliminated.
- Finally, company procedures should clearly state that the master has the right to refuse in-transit fumigation if it is deemed unsafe. Safety should always take precedence over commercial considerations.

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TSB Canada: Overloaded barge led to crewmember and cargo overboard

[caption id="attachment_57161" align="alignright" width="365"] Starboard side view of the cargo vessel Sivumut. Credit: TSB Canada[/caption]

The Transportation Safety Board of Canada (TSB) has published its investigation report into a overloaded barge which led to a crewmember and cargo overboard in Frobisher Bay, Nunavut in 2023 due to and overloaded barge.

What happened

On 27 October 2023, the cargo vessel Sivumut was anchored in Frobisher Bay, Nunavut, while transshipping cargo to Iqaluit, Nunavut, using barges and tugs.

During transshipment operations, the tug Qimmiq departed the Sivumut while towing the Tasijuaq barge in an alongside tow.

The barge carried 24 shipping containers with one crew member stationed atop the containers.

Shortly after the tug’s departure, the barge listed to port and began to capsize, causing the crewmember and 23 containers to fall overboard. Eight minutes later, the crewmember was retrieved from the water by the Sivumut crew and then transported to Iqaluit for medical attention. Sixteen containers were later retrieved.

The investigation

As part of its investigation, the TSB performed a stability assessment of the Tasijuaq and found that it was operating beyond its stability limits, compromising its ability to right itself. While the barge had not undergone a stability assessment, and was not required to by regulation, the company did have a structural arrangement plan indicating the maximum allowable deck load. However, this plan was kept onshore, and the limits were not communicated to the crew. Without this information, the crew relied solely on previous experience to determine safe operating limits.

The investigation also determined that procedures for transshipment operations within the company’s safety management system (SMS) were limited and dispersed across multiple documents, and that informal operational practices had developed over time, reducing safety margins.

Following the occurrence, the company took several safety actions including developing third‑party loading guides for its barges, adding a transshipment procedures manual to its SMS, and installing recovery devices on the tugs.

Read the full report: TSB Canada report M23C0305

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Ship to Ship Transfer Guide for Petroleum, Chemicals and Liquefied Gases update published

[caption id="attachment_57480" align="alignright" width="385"] Ship to Ship Transfer Guide for Petroleum, Chemicals and Liquefied Gases update published[/caption]

The Chemical Distribution Institute (CDI), International Chamber of Shipping (ICS), Oil Companies International Marine Forum (OCIMF) and the Society of International Gas Tanker and Terminal Operators (SIGTTO) have released the second edition of ‘Ship to Ship Transfer Guide for Petroleum, Chemicals and Liquefied Gases’.

Originally published by OCIMF in 1975, the STS Transfer Guide was consolidated in 2013 through the combined expertise of CDI, ICS, OCIMF and SIGTTO. Recognised globally by the tanker industry and IMO Member States as the definitive reference for safe and effective STS operations, this new second joint edition, released in the 50th anniversary, reflects current best practices, regulatory developments and technical innovations.

The guide provides comprehensive guidance on planning and executing STS transfers of petroleum, chemical and liquefied gas cargoes. Applicable to all vessels and referenced within Annex 1 of the MARPOL Convention, it serves as a key resource for vessel Masters, Marine Superintendents, STS service providers and regulatory authorities.

This edition features a foreword by Arsenio Domínguez, Secretary-General of the International Maritime Organization (IMO), recognising the guide’s vital role in supporting the implementation of MARPOL and reinforcing the shared responsibility for safety through consideration of human factors. The importance of continued industry collaboration to maintain and improve safety standards, reduce environmental impact, and achieve incident-free STS operations is emphasised.

Capt. Howard Snaith General Manager of CDI said, “The depth of knowledge and expertise brought by the members of the Working Groups involved in the development of this revised edition is truly exceptional. Every aspect of ship-to-ship transfers was rigorously examined, with each chapter undergoing detailed analysis and discussion. This publication stands as a testament to the outstanding work and seamless collaboration of a dedicated team of international professionals—delivering guidance that will significantly enhance safety across the industry.”

You can find the guide here: Ship to Ship Transfer Guide for Petroleum, Chemicals and Liquefied Gases – Second Edition

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MIT Maritime Consortium releases “first-of-its kind” guide for design safety of nuclear ships

[caption id="attachment_57484" align="alignright" width="300"] Left to right: Co-authors Anthony Valiaveedu, Nat Edmonds, and Jose Izurieta. Credit: Tony Pulsone/MIT MechE[/caption]

A guide for design safety of nuclear ships has been released by the MIT Maritime Consortium, aims to set the standard for safe maritime nuclear propulsion.

The “first-of-its-kind” handbook serves as a guide for design safety for civilian nuclear ships.

Using research data and standards, combined with operational experiences during civilian maritime nuclear operations, the handbook provides unique insights into potential issues and resolutions in the design efficacy of maritime nuclear operations, a topic of growing importance on the national and international stage.

The handbook, which is divided into chapters in areas involving the overlapping nuclear and maritime safety design decisions that will be encountered by engineers, is careful to balance technical and practical guidance with policy considerations.

Commander Christopher MacLean, MIT associate professor of the practice in mechanical engineering, naval construction, and engineering, says the handbook will significantly benefit the entire maritime community, specifically naval architects and marine engineers, by providing standardized guidelines for design and operation specific to nuclear powered commercial vessels.

“This will assist in enhancing safety protocols, improve risk assessments, and ensure consistent compliance with international regulations,” MacLean says. “This will also help foster collaboration amongst engineers and regulators. Overall, this will further strengthen the reliability, sustainability, and public trust in nuclear-powered maritime systems.”

Anthony Valiaveedu, the handbook’s lead author, and co-author Nat Edmonds, are both students in the MIT Master’s Program in Technology and Policy (TPP) within the IDSS. The pair are also co-authors of a paper published in Science Policy Review earlier this year that offered structured advice on the development of nuclear regulatory policies.

Download the guide: The Nuclear Ship Safety Handbook

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