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Ukraine has acceded to the 1988 Protocol relating to the International Convention on Load Lines. On Wednesday, December 5, the State Secretary of the Ministry of Infrastructure of Ukraine, agreed with IMO to deposit the instruments of accession.

The 1988 Protocol relating to the International Convention on Load Lines defines the limitations on the draught to which a ship may be loaded. It makes a significant contribution to the ship’s safety. These limits are given in the form of free boards, which constitute, besides external weather tight and watertight integrity, the main objective of the Convention. Measures under that treaty consider the potential hazards present in different zones and different seasons.

The first International Convention on Load Lines, adopted in 1930, was based on the principle of reserve buoyancy, although it was recognized then that the freeboard should also ensure adequate stability and avoid excessive stress on the ship’s hull as a result of overloading.

In the 1966 Load Lines convention, adopted by IMO, provisions are made for determining the freeboard of ships by subdivision and damage stability calculations. The Convention, which entered into force in July 1968, focuses on freeboards which constitute, besides external weathertight and watertight integrity, its main objective.

The 1988 Protocol updates and revises the earlier treaty. The technical annex contains several additional safety measures concerning doors, freeing ports, hatchways and other items. These measures help to ensure the watertight integrity of ships’ hulls below the free board deck. All assigned load lines must be marked amidships on each side of the ship, together with the deck line.

On December 5, Mr. Andriy Galushchak, State Secretary of the Ministry of Infrastructure of Ukraine, met IMO Secretary-General Kitack Lim at IMO Headquarters in London to deposit the instruments of accession. The 1988 Load lines Protocol now has 110 Contracting States, representing more than 97% of world merchant shipping tonnage.



On December 4, 2018, US President Trump signed the USCG Authorization Act, S. 140, a new bill which includes measures for USCG operations while incorporates the Vessel Incidental Discharge Act (VIDA). Namely, with this act, USCG is required to draft a policy letter for testing BWMS within 180 days, followed by a 90 day comment period. Totally, the USCG has 360 days after the date of enactment of the Act to come up with a final policy. What is more, this bill has wide implications on US EPA VGP, due in March 2019.


Ballast Water Regulations


Until now, two US federal agencies, the US Coast Guard and the Environmental Protection Agency (EPA), have been regulating ballast water and other vessel discharges under differing statutory authorities.

VIDA now delegates the lead role in establishing standards for US ballast water regulations to the EPA and assigns to the US Coast Guard the lead role in monitoring and enforcing those standards. Now, the EPA and the USCG will cooperate under the Clean Water Act to jointly set and implement standards for ballast water and incidental discharges.

Additionally, the VIDA Bill includes legislative language that amends the USCG regulations. Specifically, it will allow the use of reproductive methods by explicitly expanding the definition of ‘living’ to ensure that organisms that cannot reproduce (non-viable) are not considered to be living. This means that organisms which cannot reproduce are as good as dead for the purposes of the regulation.


In this matter, the Act requires the USCG to create a draft policy letter for testing BWMS within 180 days, which will be followed by a 90-day comment period. When the bill will become a law, the USCG has 360 days to come up with a final policy. The policy will be detailing reproductive methods based on best available science. Moreover, the USCG must consider Type Approval testing methodologies that utilize organism grow-out and Most Probable Number (MPN) analysis to determine the number of viable organisms in ballast water that can reproduce.


This is considered as good news for UV-based BWMS, as in the past, they had to increase dose delivered to organisms to meet the USCG Ballast Water Discharge Standard. The Act is also expected to harmonize the USCG’s policy approach on reproductive methods in determining BWT system efficacy with that of the IMO. In 2017, the IMO officially approved the MPN method to determine viability/reproductive capability (IMO Document BWM.2-Circ.61).


Furthermore, VIDA addresses unique regional situations. Namely, Pacific Coast ballast water exchanges will continue, while the Great Lakes may set their own basin-wide standards. Additionally, States will be allowed to establish no-discharge zones for areas that require additional protection.


VIDA implications on US EPA VGP


Beyond BWM, the new Act also affects the Vessel General Permit (VGP), which is expected to disappear in 4 years. The bill eliminates the Small Vessel General Permit program for all vessels below 79 feet. In addition, it permanently exempts all fishing vessels from the EPA discharge requirements. Small vessels had a temporary VGP exemption, which ended this year. As a result, vessel owners were worried because without a solution, activities such as washing a deck after gutting fish could lead to fines.


In early 2018, the Lake Carriers’ Association had emphasized on the importance of VIDA for the Great Lakes noting that ‘’ VIDA will align operations now regulated inconsistently by seven of the eight Great Lakes states and the U.S. EPA under the banner of the USCG and engage U.S. EPA and the states to drive the science and implementation that protect our waters. ’As explained, VIDA is inclusive of all regulatory parties, assisting in multi-jurisdictional issues.


In other words, with the enactment of VIDA, a discharge of ballast water into navigable waters of the United States is no longer subject to the Clean Water Act and the EPA general permit.


Black Rome had explained that VIDA attempts to establish a single national best management practice for ballast water discharges, while allowing states to petition the secretary of homeland security home of the Coast Guard to establish stricter standards if the state can establish that 1. the revised best management practice would reduce adverse effects of discharges, and 2. the revised practice would be economically achievable and operationally practicable.


Other provisions

The bill includes several other reforms, some of which are highlighted below:

– Maritime drug and border enforcement

The bill provides for new authorities to tackle illicit trafficking and smuggling, as well as transnational criminal organizations. This will be achieved by broadening interagency cooperation, combating concealment of bulk cash, and increasing the budget for investigations and ability to use informants.

– Multiyear contracting

The bill allows the US Coast Guard Commandant to use a number of new acquisition tools, such as multiyear funding for providing future National Security Cutters.  These changes will enable USCG to limit the price of follow-on vessels and give shipyards greater predictability.

– Arctic operations

The bill directs the US Coast Guard to carry out a review of assets and personnel needed to protect the safety and security of the Arctic.

– Recreational boating

The bill enhances safety and clarifies requirements for recreational boating safety. Specifically, it implements the installation of engine cut-off switches and alternate signaling devices.

The changes that this law will bring will be developed in phases over 2 years. During this period, the current EPA (VGP) requirements will still be in effect until new regulations are established.



On its monthly safety scenario for December, the Swedish Club presents a case where serious damage was caused to a ship’s main engine. Namely, due to lack of communication water contaminated the lubrication oil damaging severely the engine.


The incident


Engineers on a bulk carrier were conducting scheduled maintenance on one of the ballast pumps. They had closed all the isolating valves to the ballast pump and put up notices about the job in the engine room and engine control room, but not on the bridge. They didn’t finish the job on the first day, so continued the next day.


The next day the Master asked an officer to print out the alarm list for the ballast water management system, prior to arriving at the next port as a port state inspection would take place. To get the list the officer had to start the ballast water management system, which he did.


The bilge high level alarm was activated in the engine room. An oiler checked the bilges and could see water pouring in, covering the tank top. An engineer turned off the power to the ballast water management system.


He found that two ballast system valves were open from the main seawater crossover suction line. He closed these valves to stop the ingress of the water. These valves had been opened automatically when the ballast water management system started. The engineers pumped the water from the tank top into the bilge holding tank.



An hour later the M/E bearing wear alarm – Water Level 50%, went off. The lube oil for the crank case had 0.09% of water in it. The second lubricating oil purifier was started. A little later the M/E bearing wear alarm went off again. A second sample of the lube oil was taken, and it was found that the oil had 0.08% of water in it.


The chief engineer decided to partially change 3,000 litres of lubrication oil for the crank case. A third sample was taken and the water content was 0.019%.


Subsequently, the engine stopped and a full change of the lube oil was performed. A crosshead bearing was opened for inspection. No damage was found. Nevertheless, one of the rubber diaphragm seals for draining the crankcase to the system lubricating oil tank was found to be defective. This caused the water flooding into the engine room to contaminate the lube oil.


The main engine restarted and the voyage continued. The main engine was an electronic controlled model i.e. the exhaust valves and fuel injection system were powered by hydraulics. The system lubrication oil was also used as a hydraulic medium.


The next day there were problems with some hydraulic components and the main engine had to be stopped. A couple of cylinder units and pumps had to be dismantled, cleaned and reassembled. The main engine could not be restarted because of low hydraulic pressure. It was decided that one of the cylinders had to be blanked off.


The main engine was started and stopped numerous times the next days as the hydraulic system was leaking. Because the engine was running on low rpms, the scavenge trunking became fouled with oil deposits, so the engine had to be stopped several times and the trunking had to be cleaned.


Probable cause

A defective rubber diaphragm caused the water to flood into the engine room and contaminate the lube oil. Because of this, there was serious damage to crosshead bearings, crosshead pins, main engine cylinders, hydraulic pumps and main engine turbo charger bearings.



Port of Vancouver in order to ensure safety informs that thick fog and fog patches are common at this time of year and there is a high chance of restricted visibility. Therefore, the port reminds the regulations that require anchored ships to sound every minute and moving ships to sound every two minutes as it is written on Rule 35 of Collision Regulations of Canada Shipping Act of 2001.

The Rule 35 includes common international safety requirements but also contains a Canadian modification.

The Rule 35 of Collision Regulations of Canada Shipping Act of 2001:


Sound Signals in Restricted Visibility — International


In or near an area of restricted visibility, whether by day or night, the signals prescribed in this Rule shall be used as follows:


  • A power-driven vessel making way through the water shall sound at intervals of not more than two minutes one prolonged blast.


  • A power-driven vessel underway but stopped and making no way through the water shall sound at intervals of not more than two minutes two prolonged blasts in succession with an interval of about two seconds between them.


  • A vessel not under command, a vessel restricted in her ability to manoeuvre, a vessel constrained by her draught, a sailing vessel, a vessel engaged in fishing and a vessel engaged in towing or pushing another vessel shall, instead of the signals prescribed in paragraph (a) or (b) of this Rule, sound at intervals of not more than two minutes three blasts in succession, namely one prolonged followed by two short blasts.


  • A vessel engaged in fishing, when at anchor, and a vessel restricted in her ability to manoeuvre when carrying out her work at anchor, shall instead of the signals prescribed in paragraph (g) of this Rule sound the signal prescribed in paragraph (c) of this Rule.


  • A vessel towed or if more than one vessel is towed the last vessel of the tow, if manned, shall at intervals of not


  • more than two minutes sound four blasts in succession, namely one prolonged followed by three short blasts. When practicable, this signal shall be made immediately after the signal made by the towing vessel.


  • When a pushing vessel and a vessel being pushed ahead are rigidly connected in a composite unit they shall be regarded as a power-driven vessel and shall give the signals prescribed in paragraph (a) or (b) of this Rule.


  • A vessel at anchor shall at intervals of not more than one minute ring the bell rapidly for about five seconds. In a vessel of 100 metres or more in length the bell shall be sounded in the forepart of the vessel and immediately after the ringing of the bell the gong shall be sounded rapidly for about five seconds in the after part of the vessel. A vessel at anchor may in addition sound three blasts in succession, namely one short, one prolonged and one short blast, to give warning of her position and of the possibility of collision to an approaching vessel.


  • A vessel aground shall give the bell signal and if required the gong signal prescribed in paragraph (g) of this Rule and shall, in addition, give three separate and distinct strokes on the bell immediately before and after the rapid ringing of the bell. A vessel aground may in addition sound an appropriate whistle signal.


  • A vessel of 12 metres or more but less than 20 metres in length shall not be obliged to give the bell signals prescribed in paragraphs (g) and (h) of this Rule. However, if she does not, she shall make some other efficient sound signal at intervals of not more than 2 minutes.


  • A vessel of less than 12 metres in length shall not be obliged to give the above mentioned signals but, if she does not, shall make some other efficient sound signal at intervals of not more than 2 minutes.


  • A pilot vessel when engaged on pilotage duty may in addition to the signals prescribed in paragraphs (a), (b) or (g) of this Rule sound an identity signal consisting of four short blasts.


Sound Signals in Restricted Visibility — Canadian Modification


Notwithstanding paragraph (j), in the Canadian waters of a road stead, harbour, river, lake or inland waterway, a vessel shall sound the signals prescribed for a vessel of 12 meters or more in length if it is.

  • Less than 12 meters in length,
  • Ordinarily used for the purpose of pushing or pulling any floating object, and
  • Not located within a recognized mooring, storage or booming area.


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