The cargo handling spaces of specialised self-unloading bulk carriers continue to present a very high fire risk due to the inadequacy of standards or regulations for self-unloading systems, including for conveyor belts, and dedicated fire detection/fixed fire-extinguishing systems. This has been a factor in at least three major fires over a 25-year period, including Iron Chieftain’s constructive total loss.
On 18 February 2021, the Australian Maritime Safety Authority (AMSA), advised that it would work with the ATSB to raise the deficiencies highlighted by the investigation report with the International Maritime Organization (IMO).
On 8 April 2021, in response to ATSB’s request for relevant detail on AMSA’s proposed course of action, AMSA advised that as the IMO’s Maritime Safety Committee (MSC) must approve new work items based on papers submitted by Member States (countries) and IMO sub-committees, Australia (AMSA and ATSB) would use the Sub-Committee on Implementation of IMO Instruments (III) and the Casualty Analysis Working Group (CAWG) that reports to III to initially highlight the issue and to seek like-minded support.
The ATSB welcomes the intent of the safety action proposed by AMSA and undertakes to assist AMSA as required by highlighting this safety issue at IMO forums to seek improved regulations and standards. However, given the importance of this safety issue, the ATSB is concerned by the absence of a detailed proposal and/or timeframe to raise this issue with IMO through the appropriate process and best ensure the MSC approves work items aimed at addressing this issue.
Any such work items assigned to the CAWG will be actively promoted by the ATSB as a member of that group. In addition, the ATSB will use its membership in the IMO’s Casualty Analysis Correspondence Group (CACG) and the Marine Accident Investigators’ International Forum (MAIIF) to highlight the safety issue and seek like-minded support. In the interim, the ATSB issues the following safety recommendation.
The Australian Transport Safety Bureau recommends that the Australian Maritime Safety Authority takes steps to formally raise this safety issue with the International Maritime Organization to seek safety action aimed at addressing the risk of fire in the cargo handling spaces of self-unloading bulk carriers due to the inadequacy of the current associated standards/regulations.
The Australian Maritime Safety Authority (AMSA) has accepted the recommendation in full and agreed that the safety issue should be taken to the International Maritime Organization (IMO) for consideration. AMSA has suggested that an information paper highlighting the findings of the report be submitted by Australia to the next meeting of the IMO Sub-Committee on Implementation of IMO Instruments (III) in 2022 with a request that the Working Group on Analysis of Marine Safety Investigation Reports considers the report and information provided. AMSA proposed that ATSB and AMSA liaise to further discuss this approach in the lead up to the next III Sub-Committee meeting.
The ATSB notes AMSA’s response and undertakes to assist AMSA in the submission of an information paper to highlight this safety issue at the next meeting of the IMO SubCommittee on Implementation of IMO Instruments (III) in 2022. In addition, the ATSB will also use its membership of the IMO’s Casualty Analysis Correspondence Group (CACG) and the Marine Accident Investigators’ International Forum (MAIIF) to highlight the safety issue and seek support for its resolution.
Noting that consideration of the paper at the meeting will determine the next steps, the ATSB encourages AMSA to take the necessary action to best ensure the proposal’s progress to a work item aimed at addressing this issue at the IMO’s Maritime Safety Committee (MSC).
On 7 March 2022, AMSA advised the ATSB that a draft information paper on inadequate standards and regulations for cargo handling spaces of specialised self-unloading bulk carriers had been prepared for circulation to the ATSB and other interested member states.
On 16 March 2022, AMSA circulated the draft information paper, seeking input from the ATSB and interested member states including Canada, the Bahamas, the United Kingdom and New Zealand. The ATSB reviewed the paper and provided input for AMSA’s consideration, following which AMSA reviewed all feedback received and amended the paper as appropriate.
On 18 May 2022, AMSA submitted Australia’s information paper on inadequate standards and regulations for cargo handling spaces of specialised self-unloading bulk carriers to the International Maritime Organization (IMO) for consideration at the eighth session of the Sub-Committee on Implementation of IMO Instruments (III) in July 2022.
The ATSB acknowledges AMSA’s efforts in the preparation and submission of an information paper on inadequate standards and regulations for cargo handling spaces of specialised self-unloading bulk carriers to the IMO SubCommittee on Implementation of IMO Instruments (III).
Submission of this paper to the III Sub-Committee addresses the ATSB safety recommendation that AMSA take steps to formally raise this safety issue with the IMO to seek safety action.
The ATSB will continue to use its membership of the IMO’s Casualty Analysis Correspondence Group (CACG) and the Marine Accident Investigators’ International Forum (MAIIF) to promote the paper highlighting the safety issue and seek support for its resolution.
The ATSB will monitor the progress and effectiveness of any resulting safety action and re-assess the residual risk accordingly.
On 19 February 2021, in response to a draft of this investigation report, Lloyd’s Register noted the investigation’s conclusions and agreed that the arrangements of conveying machinery spaces of self-unloading bulk carriers merited improvement to address the risk.
Lloyd's Register proposed to support an approach to the International Association of Classification Societies (IACS) to seek a Unified Interpretation for the requirements for conveying spaces, to mitigate the fire risk in these spaces.
On 8 April 2021, Lloyd’s Register advised that a submission had been made to the General Policy Group of the International Association of Classification Societies (IACS) and was awaiting a decision as to when this would be assigned to the IACS Safety Panel.
Lloyd’s Register advised that the support received from other IACS members would dictate proceedings and that an interim approach via an IACS Unified Requirement (UR) may be desirable as it was a quicker route to action given the long gestation time for a Regulation change at the International Maritime Organization (IMO). This approach would at least get IACS members to a position of implementing a preventative requirement for new ships, although retrospective application may be problematic.
Lloyd’s Register provided the following estimated timeline to develop a UR should the approach to the IACS safety panel progress:
Lloyd’s Register advised that, while an IACS-based action would provide a more expedient interim solution, in the longer term, changes to the International Convention for the Safety of Life at Sea (SOLAS) 1974, as amended, and associated IMO instruments would also be required to ensure safety across the board.
The ATSB welcomes the course of safety action proposed by Lloyd’s Register with regard to addressing this safety issue and seeking improved standards and regulations, and the action it has taken to initiate that process. It is also acknowledged that safety action may take some time. Consequently, the ATSB will continue to monitor the safety issue.
On 10 June 2021, Lloyd’s Register advised the ATSB that a proposal for a Unified Requirement (UR) to address fire detection and extinction for self-unloading bulk carriers had been raised with the General Policy Group of the International Association of Classification Societies (IACS). Following review, the proposal was expected to go to the IACS Safety panel for further work.
On 29 July 2021, Lloyd’s Register advised that a majority of IACS members preferred to await any new regulations or guidelines from the International Maritime Organization (IMO) rather than pursue the development of a UR.
Recognising that safety action by IACS was being requested primarily due to the relatively long time frame for safety action at the IMO and that safety action by IACS could have a positive safety impact, Lloyd’s Register have escalated the issue within IACS to the General Policy Group with an objective of issuing an instruction to Safety Panel to develop the required UR.
The ATSB welcomes the action taken by Lloyd’s Register (LR) in proposing and pursuing the development of a Unified Requirement (UR) to address the inadequacy of fire standards or regulations for cargo handling spaces of self-unloading bulk carriers. The ATSB encourages LR and the International Association of Classification Societies (IACS) to continue to work towards addressing this safety issue and ATSB will continue to monitor progress towards its resolution.
On 23 June 2023, Lloyd’s Register advised the ATSB that a proposal to develop a Unified Requirement (UR) to address fire detection and extinction for self-unloading bulk carriers was submitted to the responsible working group (the Safety Panel) of the International Association of Classification Societies (IACS). However, the proposal was rejected by the Safety Panel with most of its members electing to wait for any new regulation or guidelines that may be introduced by the International Maritime Organization (IMO).
The ATSB acknowledges the efforts made by Lloyd’s Register in seeking to address this safety issue through the introduction of a UR. Notwithstanding this unsuccessful attempt, the ATSB will continue to promote and highlight the safety issue and seek support to have it addressed through the IMO.
On 18 January 2021, the International Association of Classification Societies (IACS) advised the ATSB that, in accordance with its guidelines, draft marine accident investigation reports containing matters relevant to class were to be directed to the classification society that classed the involved ship, in this case, Lloyd’s Register.
On 8 April 2021, consistent with those IACS guidelines, Lloyd’s Register confirmed it had initiated the process for an IACS Unified Requirement (UR) aimed at providing an expedient interim solution to addressing the safety issue through class rules pending changes to International Maritime Organization (IMO) regulations. Lloyd’s Register also indicated that the process, if successful, should result in the UR entering force on 1 July 2023.
The ATSB welcomes the proposed course of safety action being progressed through the International Association of Classification Societies (IACS) by Lloyd’s Register to address this safety issue and will continue to monitor the issue.
On 10 June 2021, Lloyd’s Register advised the ATSB that a proposal for a Unified Requirement (UR) to address fire detection and extinction for self-unloading bulk carriers had been raised with the General Policy Group of the International Association of Classification Societies (IACS). Following review, the proposal was expected to go to the IACS Safety panel for further work.
On 29 July 2021, Lloyd’s Register advised that a majority of IACS members preferred to await any new regulations or guidelines from the International Maritime Organization (IMO) rather than pursue the development of a UR.
Recognising that safety action by IACS was being requested primarily due to the relatively long time frame for safety action at the IMO and that safety action by IACS could have a positive safety impact, Lloyd’s Register have escalated the issue within IACS to the General Policy Group with an objective of issuing an instruction to Safety Panel to develop the required UR.
The ATSB welcomes the action taken by Lloyd’s Register (LR) in proposing and pursuing the development of a Unified Requirement (UR) to address the inadequacy of fire standards or regulations for cargo handling spaces of self-unloading bulk carriers. The ATSB encourages LR and the International Association of Classification Societies (IACS) to continue to work towards addressing this safety issue and ATSB will continue to monitor progress towards its resolution.
A proposal to develop a Unified Requirement (UR) to address fire detection and extinction for self-unloading bulk carriers was submitted to the responsible working group (the Safety Panel) of the International Association of Classification Societies (IACS). However, the proposal was rejected by the Safety Panel with most of its members electing to wait for any new regulation or guidelines that may be introduced by the International Maritime Organization (IMO).
The ATSB acknowledges the efforts made, particularly by Lloyd’s Register, in seeking to address this safety issue through the introduction of a UR. Notwithstanding this unsuccessful attempt, the ATSB will continue to promote and highlight the safety issue and seek support to have it addressed through the IMO.
