Handling of H2S Oils - Recommended Procedures
There are several actions which may be recommended to the master as below:
The first step is to request, better in writing and well in advance of loading operation, Material Safety Data Sheet for the cargo to be loaded. IMO Res. 150(77) requires from the supplier to provide vessel, before commencement of cargo or bunker operation, with Material Safety Data Sheet (MSDS) for the product which is going to be loaded.
The second step is to examine MSDS, which shall be submitted to the ship’s staff as a part of exchange of information during pre-loading safety conference. Master must insist on H2S content to be specifically mentioned and reflected in Ship/Shore Safety Checklist in the course of compulsory safety routine. Unfortunately MSDS not always available before the loading starts, and when available, it seldom, for the reasons mentioned above, states correct data about H2S content in cargo. In such cases, without knowledge and forward notice as to dangerous nature of cargo, ship’s crew may potentially be exposed to serious risk of poisoning.
The third step is to take independent measurements of H2S content in tanks as soon possible and carry out risk assessment. If or when presence of H2S in cargo vapours has been established then it is necessary to ensure crew safety during loading.
The next step is to advise all parties concerned, terminal including, about H2S content as measured by crew. It will put ship’s side in an advantageous position in case of any further dispute.
Finally, a letter of protest shall be lodged stating observed readings of H2S in tanks, shifting responsibility to the shippers for failure to provide the vessel with MSDS accurately reflecting H2S content. It is also advisable to mention that ship’s side does not assume any responsibility as to any claims for consequences which may arise due to high H2S content in the cargo and that ship has no means to reduce it.
Examples of the Letter of Request For H2S Readings in Liquid/Vapour and the Letter of Protest – MSDS/H2S.Letter of Request For H2S Readings in Liquid/Vapour
In compliance with section 220.127.116.11 of International Safety Guide for Oil Tankers and Terminals (ISGOTT) which requires that H2S content in cargoes and bunkers shall be specifically advised before loading or bunkering operation, I herewith request that H2S readings of cargo to be loaded in liquid/vapour to be submitted to the ship’s staff at the time of ship/shore pre-loading safety conference.
Letter of Protest - H2S Content
On behalf of my Owners and Principals I hereby protest against the following:
In violation of IMO Res. 150(77) and section 18.104.22.168 of International Safety Guide for Oil Tankers and Terminals (ISGOTT) which requires that H2S content in cargoes and bunkers shall be specifically advised before loading or bunkering operation, required data as per my Letter of Request For H2S Readings in Liquid/Vapour dated (date) were not provided by (shippers or terminal name) before loading and were not reflected in MSDS presented, see attachment.
In port of (port name) vessel loaded cargo of (cargo name) in tanks (tanks’ numbers).
Measurements of H2S content done by crew upon completion of loading, (date), show H2S content in excess of (H2S reading)ppm in all tanks, see report attached.
Because vessel has no means of control or reduction of H2S vapours and in order to protect the vessel, her owners and/or any other party who may be directly or indirectly concerned, I lodge this formal letter of protest and hold the consignor, the shippers and the terminal jointly responsible for any delays, loss, damage or claims which may arise due to the high H2S content in cargo loaded. This protest is made without prejudice to the terms, conditions and exceptions of the relevant Charter Party.
Needless to say that master shall notify earliest possible all the parties concerned about the H2S content in cargo tanks and all measures undertaken including but not limited to those mentioned above.
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