Ship to Shore Access Guidelines for Gas Terminal and Vessel Operators

Explore detailed LNG terminal management guidelines, including best practices for ship to shore access, specialized terminal equipment, and the crucial role of senior management.

Learn how gas terminal and vessel operators can ensure safe and efficient operations through mutual support and comprehensive management information.

Guidelines for ship to shore access for gas terminal and vessel operators

This section covers safety protocols, best practices for using gangways and accommodation ladders and terminal equipment, ensuring safe and efficient LNG transfer operations.

Guidelines for ships – with particular reference to ships gangways and accommodation ladders

Regulatory

1. Shipowners/operators whose flag state has ratified the identified international conventions covering ship/shore access requirements, must comply with regulations resulting from that ratification. International Labour Organisation Conventions 147 and 152“ILO Conventions 147 and 152 – Ship and Dock Safety Standards” give examples of conventions and regulations.
2. Shipowners/operators whose flag state has not ratified identified international conventions should work to regulations set out in UK Statutory Instrument 1988 No. 1637. See Merchant Shipping Safety – Access Regulations, Liability Act, and ILO Convention Ratifications“Merchant Shipping Safety – Regulations and ILO Conventions”.
3. Shipowners/operators accept the principle of the “general duty of care” and “take such care as in all the circumstances of the case is reasonable to see that the visitor will be reasonably safe in using the premises for the purposes for which he is invited or permitted by the occupier to be there”. (For some this will be a legal obligation).
4. Shipowners/operators, or their representative (the Master), shall undertake to ensure all those involved with providing access are aware of the identified regulations or equivalent standards.
5. Shipowners/operators, or their representative (the Master), properly acquaint themselves with local Bye-Laws and jetty regulations. They should resist time constraints being placed upon this activity until they properly understand their rights and obligations.

Operational

Because gangway and accommodation ladders encounter a vast range of situations the identified regulations have, to an extent, relied upon general directives. They also allow that safe access shall be provided “so far as is reasonably practicable”. These guidelines have identified user groups for whom access must be safe at all berths. The shipowner/operators or their representative (the Master), must ensure all those providing ship/shore access are made aware of the composition of that user group and interpret the identified regulations accordingly.

Those providing access must also be made aware of their obligations under the principle of a “general duty of care”. This process of education shall, inter alia, include the following interpretation of UK SI 1988 No. 1637 or similar interpretation of regulations inspired by the ILO 134 and 147 conventions.

1 Safety nets shall be deployed whenever a gangway or accommodation ladder is in place. The only exception being when the quay landing area and the ship deck position allow the gangway to rest horizontally with no significant gap between ship and quay.

2 In the case of a ship’s gangway, areas adjacent to the head of the gangway must be free of obstructions and accessed by a safe route. This is of particular importance if gangways are re-positioned to landing areas away from the main deck in order to cope with tidal movements.

3 A gangway watch must be kept at all times. Those keeping watch must understand how the gangway or accommodation ladder has been safely rigged and be able to make adjustments, or call for assistance to make adjustments, so that at all times the safety standards to which access was initially rigged remain consistent. The watchkeeper shall also be available to deal with, or call for assistance to deal with, inebriates and unauthorised persons attempting to board the vessel.

4 On occasion, due to conditions peculiar to a specific berth, ships gangways and accommodation ladders will be impossible to rig with the required degree of safety. Under these circumstances, portable aluminium ladders are accepted under the code.

Although these ladders are usually provided by a shore establishment, the shipowner/operator remains responsible to ensure safe access as defined in these guidelines.

The ladders shall be of a design which incorporate handrails at each side and shall be rigged on the principles that persons using the ladder are at no greater risk than would be the case with properly installed gangways or accommodation ladders.

It may be that, in the judgement and experience of the Master, ladders can never be made safe for certain categories of the user group. In which case those categories shall be prevented from using the portable ladder. Watchkeepers shall have clear and precise instructions as to who shall be excluded.

Visits to the vessel shall either then be regulated to times when conventional equipment can be deployed under the conditions indicated by these guidelines or alternatives, such as a boat service, should be provided.

The elements of SI 1988 No. 1637 which are unaffected by the concept of a portable ladder shall be applied. Adequate lighting, lifebelt positions, constant supervision and so on, all must be provided.

5 When positioning access between ship and shore cognisance shall be taken of the OCIMF publications:

• “Safety Guide for Terminals Handling Ships Carrying Liquefied Gases in Bulk”.
• “Recommendations for Manifolds of Refrigerated Liquefied Gas Carriers for Cargoes from 0 °C to minus 104 °C”.

These respectively state:

3.3 Access and Security. The access from the terminal to the ship should be positioned as far away from the manifolds as practicable.

3.20 Emergency Escape. In addition to the means of access referred to in section 3.3 a safe and quick emergency escape should be available both on board and ashore. Fire protection should be provided for these emergency escapes. On board the ship it may consist of a lifeboat ready for immediate use, preferably at the after end of the ship.

8.6 Emergency exits from manifold area. There should be two independent means of exit from the manifold area so that in the event of a cargo spillage or other incident, evacuation of the area is possible at all times.

Equipment

Gangways and accommodation ladders must all comply with UK SI 1988 No. 1637 which also states the relevant British Standard to which the equipment must be made.

1 Frequently, criticism of the length of gangways‘has been made. These guidelines make the following proposals.

Every ship of 30 metres or more registered length shall ensure that a gangway appropriate to the deck layout, size, shape and maximum freeboard of the ship is carried of not less than the following length:

1. in the case of a ship of 30 metres or more, but of less than 80 metres, in registered length, 4,5 metres;
2. in the case of a ship of 80 metres or more in registered length, 9 metres.

2 For ease of handling, gangways and parts of the accommodation ladder will almost certainly be constructed from aluminium or an aluminium with alloy. In this connection, the SIGTTO textbook “Liquefied Gas Handling Principles on Ships and in Terminals” states:

2.9 Aluminium. Aluminium equipment should not be dragged or rubbed across steel since it may leave a smear which, if it is on rusty steel and is subsequently struck, can cause an incendive spark. It is therefore recommended that the undersides of aluminium gangways and other heavy portable aluminium structures be protected with a hard plastic or wooden strip.

Read also: Terminal Operations for LNG or LPG Carrier after Arriving in Port

These requirements shall be incorporated into the design of all access equipment. Shipowners, when seeking new builds, should clearly specify where landing areas should be arranged and should instruct their Building Supervisors to ensure the clear areas so provided are not violated by piping, mooring arrangements or other space competing installations.

Guidelines for terminals – with particular reference to ladders and custom built equipment

Regulatory

1 Terminal owners/operators, working in countries who have ratified the identified international conventions, must comply with regulations resulting from that ratification.

2 Terminal owners/operators working in countries who have not ratified the identified international conventions should work to the UK dock regulations 1988.

3 Terminal owners/operators should accept the principle of the “general duty of care” and “take such care as in all circumstances of the case is reasonable to see that the visitor will be reasonably safe in using the premises for the purpose for which he is invited or permitted by the occupier to be there”. (As with shipowner/operators for some this will be a legal obligation).

4 Terminal owners/operators working in countries who have adopted the IMO “Recommendations on the Safe Transport, Handling and Storage of Dangerous Substances in Port Areas” adopted by the Maritime Safety Committee at its forty-third session (December 1980) and including amendments adopted at its forty-eighth session (June 1983) must comply with these requirements which inter alia recommends:

3.3.2 Berthing. 3.3.2.1 The Berth Operator should ensure that:

1. adequate and safe mooring facilities are provided;
2. safe access is provided between the Ship or Berth and the shore.

To some extent this is contrary to custom and practise. However, these guidelines will require the terminal owner/operators to fulfil this obligation in the event that the ship owner/operators are unable to provide safe access for the complete identified user group.

5 Terminal owners/operators working in countries who have not accepted IMO recommendations shall accept.

6 Terminal owners/operators shall undertake to ensure those involved with providing access are aware and understand the shipowners/operators statutory (or equivalent under these guidelines) obligations.

7 Terminal owners/operators shall have a duty to acquaint the shipowner with local Bye-Laws and jetty regulations and their interpretation. This shall include access arrangements with particular reference to drink and drug related problems.

Operational

Notwithstanding IMO requirements the ship will undertake to deploy its own equipment to provide access between ship and shore when such access is needed. Terminal staff will cooperate with the ship’s crew in rigging and maintaining access for the identified user group, in a fashion laid down by these guidelines.

Should this prove impossible after actual attempts at rigging or identified as such by intervention from terminal staff with experience of similar vessels using similar equipment, then the terminal owner operators will provide access. This access should involve no more risk to user than would ship rigged equipment under these guidelines.

If restricted access is to be imposed, as described in International Labour Organisation Conventions 147 and 152“ILO Conventions 147 and 152 – Ship and Dock Safety Standards”, the Master undertakes to inform terminal owner/operators of his precise instructions and request cooperation, if necessary, to provide alternatives.

1. Access users must be permitted to land in or embark from a clear and unobstructed area from which safe access can be obtained to other permitted areas of the terminal.
2. Where appropriate the terminal owner/operators shall provide suitable anchoring points for safety nets.
3. If jetties employ vertical ladders then the Master and Terminal Staff must agree upon the user groups for whom such access does not violate the spirit of these guidelines.
4. Vertical jetty supported ladders shall be maintained in good repair and kept free of mud and silt by regular sluicing down by Terminal Staff. They shall be subject to the position requirements.
5. Vertical ladders of this type must not be used if the set of any stream passing the jetty holds the ship off the jetty or where the vessel, when permitted to touch bottom, lists away from the jetty. Additionally, should the fender line render these ladders more than 0,5 metres away from the ship’s side, they must not be used.

Equipment

Terminal owners/operators will be aware if visiting vessels are continually unable to use their own equipment to provide ship/shore access. If this be the case, the terminal owner/operator shall provide custom built equipment to provide access for the complete identified user group.

Tower bridge arrangements may be inappropriate for small tidal berths.

1 When terminals are at the planning stage, terminal owners/operators will seek the widest possible consultation. Input shall be sought from:

• Shipowners operating other vessels likely to visit the proposed terminal.
• Local fire authority.
• Department of Transport (or equivalent).
• HSE (or equivalent).
• Local experts on weatherand tidal movements.

Mutual support

The legislation which has been used to form the basis of these guidelines has been drafted with a specific objective in mind – namely cooperation between ship and shore.

The scope of the Merchant Shipping (Means of Access) Regulations and the Docks Regulations overlap but both sets of regulations have been deliberately drafted to be complementary. The Docks Regulations place no duties on the master or crew of a vessel or their employers in connection with plant that remains on board a ship and any dock operation carried out in the ship solely by the master or crew. However, where a suitable gangway or accommodation ladder is provided and has been safely deployed by a ship, the access will also satisfy the requirements of the Docks Regulations. Where it is not practicable or safe to use a ship’s access equipment, shore side operators and employers still have a duty to ensure that safe means of access are provided for those necessarily visiting the ship.

No amount of legislation and regulation can create cooperation and mutual respect but it does serve as a framework in which such conditions might flourish.

Management information on ship to shore access for gas terminal and vessel operators

The guidelines emphasise a need for cooperation between ship and shore at the intermediate management levels – the Ship’s Master and Terminal superintendents.

Senior management role

In order to preserve safe conditions, for which these officers are directly responsible, all errors must be controlled or corrected. However, should fundamental faults occur they can only resort to denying access between ship and shore, an act which will disrupt smooth operations, involve increased operational costs and probably involve the ire of their employers.

Correcting fundamental faults requires an expenditure of funds which cannot be sanctioned by ships masters and, to a degree, terminal superintendents. The true level of responsibility and accountability in such cases, resides with those able to expend the necessary monies – namely the executive officers who are or who represent the owners of ship or terminal.

Regardless of the type of activity undertaken methods to involve Senior Management with safety issues have followed similar patterns. These methods should be adopted to augment the guidelines.

It is suggested that executive officers of shipowning/operating and terminal owning/operating companies institute a “need to know” policy. Ships masters and terminal superintendents will be required to report on any incident where access, on an unrestricted basis under these guidelines, was denied. Senior managements will apply modem techniques (see SIGTTO’s Guidelines for Hazard Analysis as an Aid to Management of Safe Operations) to solving problems and implementing solutions.

Should death or serious injury occur as a result of access incidents, senior management should interview the Master and Terminal Superintendent as quickly as possible to ascertain the reasons for the accident.

Once in full possession of the facts, senior management should take measures to prevent further problems. Solutions should not be confined to improvements of equipment but would, if necessary, involve elements such as:

• education;
• methods to combat alcohol and drug abuse;
• maintenance programmes and;
• disciplinary measures for neglect.

At all times during this corrective process there should be close liaison between ship and shore interests.

Summary

The Guidelines demonstrate the existence of much legislation and regulation aimed at making safe access between ship and shore. This approach has met with only limited success. The principle of influence from the top down must now be applied by senior management. If it is not, little will change and seamen will continue to have more chance of dying in port than at sea.

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.