Health, Environment and Safety Management for LNG Transport

Moving hydrocarbons around the world by ship inherently carries risk, which is typically managed by following a brood range of regulatory requirements, Company-specific additional controls and industry best practices.

The principles behind the carriage of liquefied gases have changed little over the post few decades, but the complexity of operational systems used has increased. Safety management is a proactive and preventive approach to safe operations.

This chapter considers some of the operational hazards that may occur during operations, either on board a liquefied gas carrier or in the terminal, and provides on overview of certain methods of hazard identification and mitigation.

The three key components of safety management: personal health & safety, process safety, and environmental safety (or stewardship), are interrelated. Process safety focuses on incidents, resulting from a loss of containment.

Personal health & safety, also known as occupational safety, covers slips, trips, falls and equipment safety in on effort to minimise exposure to dangerous products. Environmental safety addresses impacts on the environment through normal operations, vapour releases or spills.

Many of the tools and controls used to manage hazards are shored between the three components, primarily because the hazards are often common and a small incident can escalate into a process safety incident.

A detailed discussion of the three components, especially process safety, is beyond the scope of this publication, and, in any case, many are not specific to liquefied gas carriers. However, the basic concepts will be introduced, with on emphasis on how they may be applied to gas carriers.

Within this publication and for operations, either on board or in the terminal, you need to understand the following terms:

• Hazard – is a condition or situation with a potential for creating harm to human health and/or the environment.
• Risk – is the chance of harm (ie the product of consequence times frequency).
• Risk assessment – is a systematic analysis of potential risks.
• Risk mitigation – are the measures taken to reduce risk.

The overall approach to the avoidance of hazards by personnel will usually be, in order of preference:

1. Hazard removal.
2. Hazard control.
3. Reliance on personal protection.

Reliance on personal protection will generally only be used where hazard removal or hazard control is unachievable, where no other means of dealing with the task are possible and only in cases where that’ specific item or task is essential.

Safety Management Systems (SMS)

Safety management systems bring together all of the facets of safety, including:

• engineering design;
• risk management;
• training;
• operation maintenance;
• recycling (disposal).

All ships have an SMS to comply with the legal requirements of the International Safety Management (ISM) Code. The SMS will include all procedures, policies and standards that relate to operational safety onboard ship.

ISM Code

Historically, a number of serious accidents were caused by human error, with management fault also identified as a contributing factor. While it is widely accepted that 80 to 90 % of accidents are attributable to human error, the task for operators is to minimise the scope for poor decisions or actions that may directly or indirectly contribute to a casualty or pollution incident.

At its 18th Assembly in November 1993, the IMO adopted Resolution A.741(18), “International Management Code for the Safe Operation of Ships and for Pollution Prevention“, known simply as the ISM Code (Reference 1.13). The ISM Code is implemented through SOLAS Chapter IX.

The ISM Code requires a Company (within the meaning given in the ISM Code) to establish safety objectives that ensure safety at sea, prevention of human injury or loss of life and avoidance of damage to the environment.

Functional requirements for an SMS

Under the ISM Code, every Company should develop, implement and maintain an SMS that includes:

1. establishment of a safety and environmental-protection policy;
2. development of instructions and procedures to ensure safe operation/proper maintenance of ships and protection of the environment in compliance with relevant international and flag State legislation;
3. defined levels of authority and lines of communication between, and amongst, shore and shipboard personnel;
4. procedures for reporting accidents and non-conformities with the provisions of this Code;
5. procedures to prepare for and respond to emergency situations;
6. and procedures for internal audits and management reviews:
   • Provide for safe practices in ship operation and a safe working environment.
   • Establish safeguards against all identified risks.
   • Continuously improve safety management skills of personnel ashore and aboard ships, including preparing for emergencies related both to safety and environmental protection.
   • Comply with mandatory rules and regulations.
   • Consider applicable codes, guidelines, and standards recommended by marine safety organizations, the government of the state under which the ship is flagged (or an authorized organization acting on their behalf), the Classification Societies, and the maritime industry organizations.
   • Provide adequate resources and shore-based support to enable the designated person or persons to carry out their functions.

An SMS provides the detail on how a vessel should operate on a day to day basis, including the procedures to be followed in case of an emergency, how drills and training are to be conducted and the measures that must be taken for safe operations.

Central to the development of a safety culture is the need For senior management to take responsibility for safe operational management within the Company. The ISM Code requires the Company to link the Master and crew of the ship to the Company through a named contact ashore, who is known as the designated person (sometimes known as the designated person ashore (DPA)) (see point “Shipboard safety organisation” below).

The arrangement does not detract from the Master’s responsibility for operations on board, which are clearly set out in the ISM Code and in the laws and regulations of the jurisdictions where the vessel trades or passes through, but it does allow managers and owners to be held to account for their actions or omissions in relation to safety management.

Security

ISPS Code

The “International Ship and Port Facility Security Code (ISPS Code)” (Reference 1.14) is a comprehensive set of measures that enhances the security of ships and port facilities. It was developed in response to the perceived terrorism, piracy and smuggling threats to ships and port facilities. The ISPS Code is implemented through SOLAS Chapter XI-2, “Special Measures to Enhance Maritime Security“. The ISPS Code has two parts, one mandatory and one recommendatory.

The ISPS Code takes the approach that ensuring the security of ships and port facilities is a risk management activity and that, to determine what security measures are appropriate, an assessment of the risks must be made in each particular case. The purpose of the ISPS Code is to provide a standardised, consistent framework for evaluating risk, enabling Governments to offset changes in threat with changes in vulnerability for ships and port facilities through determination of appropriate security levels and corresponding security measures.

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The ISPS Code establishes relevant roles and responsibilities at a national and international level. ISPS Code provisions relating to port facilities, which include both onshore and offshore facilities, relate solely to the ship/port interface. ISPS Code provisions do not extend to the actual response to attacks or to any necessary clear-up activities after an attack.

For each ship and port authority affected, the ISPS Code requires:

• the implementation of a ship security plan (SSP);
• the implementation of a port facility security plan (PFSP);
• the appointment of a Ship Security Officer (SSO);
• the appointment of a Company Security Officer (CSO);
• the appointment of a Port Facility Security Officer (PFSO);
• the installation of ship alarms;
• the installation of shipboard automatic identification systems (AIS).

Gas carriers that act as both trading vessels and temporary offshore facilities (ie floating storage and regasification units (FSRUs)), may need to have both an SSP and a PFSP, as appropriate.

Safety Organisation

Terminal organisational structure

Terminal emergency organisational structure and incident planning at terminals is generally less standardised than on ships, primarily due to the fact that terminals are regulated by local regulation and industry guidelines rather than by international standards such as the IMO conventions. Terminal plans depend upon the size and nature of the terminal, how it is located in relation to other harbour facilities and neighbouring industry and any relevant local and national legislation.

Whatever the nature and location of a terminal, it will require a fast acting emergency structure under the command of a site incident controller. The incident controller should operate from a designated emergency control room. The organisation will need to be fully responsive at any time of day or night and under shift working conditions. While always responsible for initiation and direction of immediate action in case of a major incident, the emergency organisation at a marine terminal may come under the direction of the port authority. If this is the case, the port authority should have a fast acting structure within its own emergency control centre available at all times, with the means of coordinating assistance from other public services. They should also have procedures for issuing warnings to, and evacuation of, surrounding industry and population. The terminal’s emergency planning, and similar port planning, should be developed together and should be exercised jointly at suitable intervals.

When developing procedures it is important to provide guidance to the site incident controller on the scale of incident severity. This will help to provide a check on when to call on port authority emergency response personnel and services.

Incident plans

The following incident types will usually be included when developing a terminal’s incident plan:

• loss of containment and/or fire on board a ship alongside the jetty;
• loss of containment and/or fire while loading or receiving cargo;
• loss of containment and/or fire not associated with loading or receiving cargo.

Shipboard safety organisation

As with all ships, personnel from different departments will have responsibilities in respect of health and safety. These responsibilities are briefly discussed below.

Master’s responsibility

The Master is responsible for his ship under the relevant regulations of the applicable Flag State Administration in addition to relevant local and notional (ie Port State) regulations for the port that the ship is visiting or the territorial waters through which the ship is transiting, as well as relevant international obligations when outside territorial waters. He is responsible for emergency response and fire-fighting on board, including the direction of fire-fighting capabilities of tugs until fire and rescue service are on board.

There are no additional safety responsibilities for the Master of a gas carrier compared to other ships. Under the ISM Code, the Master is the shipowner’s representative responsible for overall implementation of the Company’s safety and environmental protection policy on board ship.

The Safety Officer

The Safety Officer is the primary contact on board for all occupational health and safety issues, and anyone with concerns about potential hazards or unsafe practices should raise them with him.

The Company will delegate the responsibility for health and safety to the Safety Officer, whose role will usually be to implement the Company’s health and safety programme under the instruction of the ship’s Master.

The Safety Officer will usually have service experience onboard gas carriers and will usually receive specific training before being appointed to the role by the Company. The need for further training, either “on the job” or otherwise, will normally be discussed with the Master.

While the ultimate responsibility and authority remain with the Master, the Safety Officer is usually expected to have an understanding of many areas of the ship’s operation, with sufficient experience to be able to recognise good and bad practice and the professionalism to want to see the health and safety message embedded into daily working practice.

Safety Representative

Safety representatives may occasionally be appointed by and from the ship’s crew to represent the crew on matters affecting their health and safety. The safety representative(s) may also be called upon to assist the Safety Officer with safety inspections, risk assessments or accident/incident investigations.

Safety Committee

It may be prudent to put a safety committee in place on ships that have more than five crew, whether there is a safety representative or not. This committee will normally include the following:

• master – chairperson of the committee;
• safety Officer;
• safety Representative(s);
• others as invited to attend.

Where there is a larger number of crew, such as on floating offshore facilities, departments such as production, marine and catering may establish small safety subcommittees dealing with individual departments. These subcommittees will normally be represented on the main safety committee.

The safety committee is usually responsible for the following general duties:

• involvement and commitment of management;
• worker participation and contribution;
• hazard identification, risk assessment and control;
• health and safety planning and training;
• accident/incident investigations.

Designated Person

The ISM Code requires that someone based ashore and having direct access to senior levels of Company management be designated to provide a direct link between the Company and those on board. This responsibility and authority of this “designated person“, also sometimes called designated person ashore (DPA), will normally include:

• monitoring the safety and environmental protection aspects of the ship’s operations;
• ensuring that adequate resources and shore based support are available for the safe operation of the Company’s fleet of ships.

Training, competency and experience

Seafarer training – the STCW Convention

The IMO has prescribed minimum training standards, over and above normal seafarer certification, for crews serving on liquefied gas carriers. Once completed, the training is documented either on the seafarer’s Certificate of Competency or issued as a separate document. The training requirements for these endorsements are detailed in the Standards of Training, Certification and Watchkeeping (STCW) Convention, and are divided into basic and advanced training courses. STCW does not stipulate separate training requirements between liquefied natural gas (LNG) and liquefied petroleum gas (LPG) carriers.

The “Basic Training for liquefied Gas Tanker Cargo Operations Course” (STCW A-V/1-2-2) is for ratings and officers assigned with specific duties and responsibilities related to cargo and cargo equipment on liquefied gas carriers. Seafarers may also meet the basic requirements by completing 3 months‘ approved seagoing service on liquefied gas carriers.

The “Advanced Training for liquefied Gas Tankers” (STCW A-V/1-2-4) is for Masters, Chief Engineers, Chief Motes, Second Engineers and any person with immediate responsibility for loading, discharging, core in transit, handling of cargo, tank cleaning or other cargo related operations on liquefied gas carriers.

Seafarer and terminal operator competencies

Industry practice is for all personnel to receive proper training that goes beyond a familiarisation induction and the basic use of equipment or procedures. This training is best managed using the latest edition of the relevant competency guidance. The following publications contain certain guidelines that may be useful to refer to in managing any such training:

• SIGTTO “LPG Shipping Suggested Competency Standards” (Reference 2.2);
• SIGTTO “LNG Shipping Suggested Competency Standards” (Reference 2.1 );
• SIGTTO “LNG Steamship Suggested Competency Standards for Engineers” (Reference 2.3);
• OCIMF “Marine Terminal Operator Competence and Training Guide (MTOCT)” (Reference 2.53).

Such training will commonly cover the nature of the hazards, including those which are sometimes not immediately obvious, as well as many other pertinent points.

Senior officer experience matrix for LNG and LPG carriers

Risk management is usually considered on essential port of maintaining the safety record of LNG/LPG shipping and protecting the environment. The “LNG and LPG Experience Matrix” (Reference 2.77), available from SIGTTO, offers guidance on the assessment of the risk profile in relation to the officer complement by balancing thresholds of experience in ranks. The experience matrix considers a number of elements, including length of sea service, experience in rank, experience in LNG/LPG operations and training assessment.

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It is important to appreciate that the experience matrix is offered as a tool to help with evaluating and managing risk. When evaluating risk in the event of non-compliance with a particular element of the experience matrix, consideration may be given to other mitigating factors, including bespoke training, the manning scale in place, time with the LNG/LPG shipowner/operator and the wider competence management systems employed by the ship operator in officer recruitment and development.

Author

Olga Nesvetailova

Freelancer

Literature

1. The international group of liquefied natural gas importers (GIIGNL). LNG custody transfer handbook / 6^th Edition: 2020-2021.
2. ©Witherby Publishing Group Ltd. LNG Shipping Knowledge / 3^rd Edition: 2008-2020.
3. CBS Publishers & Distributors Pvt Ltd. Design of LPG and LNG Jetties with Navigation and Risk Analysis / 4^th Edition.
4. NATURAL GAS PROCESSING & ITS ENERGY TRANSITION ROLE: LNG, CNG, LPG & NGL Paperback – Large Print, November 14, 2023.
5. OCIMF, ICS, SIGTTO & CDI. Ship to Ship Transfer Guide for Petroleum, Chemicals and Liquefied Gases / 1^st Edition, 2013.
6. The Society of International Gas Tanker and Terminal Operators (SIGTTO). Ship/Shore Interface / 1^st Edition, 2018.