Risk Watch Vol 15 No 3

7/29/2019 Risk Watch Vol 15 No 3

1/8

Regulatory update8 Brazilian coastal trade foreign crews beware

Navigationand Seamanship

1 Ballastblacklist dismissed byinvestigators as a cause for bulkergrounding

3 Apparent misuse of inshoretraffic zones

3 X-Band, S-Band

Containers and Cargoes6 Problems loading hot cement clinker

in bulk

7 More cement cargo problems

7 Beware bankrupt cargo interest

Miscellaneous8 Publications

Volume 15: Number 3

August 2008

The Britannia Steam Ship

Insurance Association LimitedRISK WATCH

Safety5 Fire onboard poor ship board practices

result in uncertainty and delay in dealingwith a fire in the cargo hold

5 Rescuers continue to die in significantnumbers

The May 2008 edition of Risk Watch dealt

with the grounding of the PASHA BULKER

in detail as recounted by the State

investigation into the incident.The Federal

Department responsible for investigations

(The Australian Transport Safety Bureau

ATSB) has now published its report, which

largely reflects the findings of the State

report on the actions of the Master of thePASHA BULKER.The report goes into a little

more detail on the part played by the coal

terminals ballasting requirements in the

grounding,and, at the same time, has some

interesting criticism of the Port Authority

albeit not in regard to any possible

ballasting blacklist.

Ballastblacklist

Dismissed by investigators as a causefor bulker grounding.

Whereas the summary of the report

states that initiatives by the coal terminal

operators, relating to improving the

performance of ships with regard to their

de-ballasting time, may have influenced the

decisions of some Masters not to ballast

their ships for heavy weather, the report

did not find that these measures were a

contributing factor to the casualties.

Whilst the report is critical of those vessels

which did not take heavy weather ballast, it

also points to the results of a questionnaire

of all vessels at the anchorage, in which only

three of the Masters who responded cited

concerns about ballast within the terminals


2/8

Ballast blacklist continued

2 Britannia RISK WATCH Volume 15: Number 3: August 2008

vessel suitability list (the so called blacklist).The

report notes that; The vessel suitability

initiative may have heightened concerns of

some Masters at the time of the incident

because their ships being assessed as

unsuitable for loading would effectively

penalise their ships. Nevertheless,the report

agreed with the berth operators that they do

not penalise the vessels but rather operate an

approval process based on ship performance.

Although the ATSB acknowledge that the

existence of the vessel suitability list would

result in pressure on the Master and the crew

to provide explanations about an unsuitable

assessment of their ship, the report however

states that this was a problem of perception.

The evidence does not confirm that, at the

time of the incident, there were any compelling

reasons why the terminals ballasting

requirements would prevent Masters from

taking heavy weather ballast.

In support they refer to the example of those

3 ships whose berthing schedule on the 7/8

June coincided with the deteriorating weather.

None of the Masters of these three ships

indicated concerns about ballasting and all put

out to sea in good time. Further, the evidence

does not confirm with certainty that ships whichgot into difficulty on the 8 June, including

PASHA BULKER, were not appropriately ballasted

for heavy weather because of concerns about

the berth operators ballasting requirements.

The ATSB was clear in stating that; In any

case,the responsibility for ensuring a ship is

appropriately and safely ballasted at all times

rests with its Master.

Although the ATSB declined to criticise the coal

terminal operators, it did recommend that the

port authority and the Vessel Traffic Information

Centre (VTIC) take measures to address ten

safety issues.

The issues identified included:

the advisory role of the VTIC was not properly

understood by the Masters of a number of ships,

the port authoritys incident control system

was not activated early enough,

offers of help to the PASHA BULKER by the

VTIC were made at a late stage in extreme

weather conditions,

VTIC advice was limited to Masters of only those

ships that were dragging their anchors, and

VTIC did not cancel the scheduled berthing of

any ship even after the weather conditions hadbecome severe.

For its part the port authority has undertaken

to provide Masters of ships at Newcastle

anchorage with regular weather broadcasts

when a Bureau of Meteorology weather

warning is in place.

Unless the local port authority/VTIC clearly

indicates that they will give prompt and

comprehensive advice as to when the

anchorage becomes unsafe, it would seem

sensible for Masters to assume that no such

advise will be provided, and to act on their

own initiative.

The full article is available on the ATSB website

http://www.atsb.gov.au/publications/investiga

tion_reports/2007/MAIR/pdf/mair243_001.pdf

Navigation and Seamanship


3/8

Apparent misuse of inshore traffic zones the UK Maritime & CoastguardAgency recently published a Mariners Guidance Note (MGN 364) on therouteing of vessels through the English Channel with special attention onthe use, or rather misuse, of inshore traffic zones, (ITZs).

It seems that the coastguard may be taking a

much closer look at vessels misusing the ITZs

in the Dover Strait.

At the same time, the UK Hydrographic Office

has republished BA Chart 5500, Mariners

Routing Guide English Channel and

Southern North Sea.

Navigators will be aware that under Rule 10 of

the International Regulations for Preventing

Collisions at Sea, 1972, the vessel, unless it is

shorter than 20 metres in length, is required

to use the appropriate traffic lane and, by Rule

10(d)(ii), can only use the inshore traffic zone

(ITZ) when en route to or from a port or any

other place situated within the ITZ or to avoid

immediate danger.MGN 364 usefully expands

upon Rule 10(d) by stating that the high traffic

density within a traffic lane is not sufficient

reason to justify the use of an inshore traffic

zone irrespective of the apparent absence of

traffic within that ITZ. Nor is restricted visibility,

with or without high traffic density, sufficient

reason to justify the use of an inshore traffic

zone. However, the guidance note goes on to

say that vessels may use an ITZ where

necessary to seek shelter from weather, but

reminds navigators that in so doing they may

encounter vessels heading in any direction.

Navigators should note that neither the

Channel Navigation Information Service

(CNIS) nor HM Coastguard (Dover) can grant

permission for vessels to use the English ITZ

in contravention of Rule 10(d). If Masters do

decide to use the English ITZ they must report

this fact to CNIS/Dover Coastguard.

MGN 364 reminds navigators that vessels are

tracked and recorded by radar and AIS

through the Dover Strait, and that any vessel

found contravening the Collision Regulations

(impliedly emphasising contravention of Rule

10(d)) will be reported to their Flag State or, if

arriving at a UK port, may be liable to

prosecution. Navigators regularly utilising the

traffic separation schemes in the Dover Strait

and Southern North Sea would find Section 4

of MGN 364 especially useful as it highlights

and clarifies how vessels should navigate in

some of the worlds busiest crossing points and

high traffic concentration areas.

http://www.mcga.gov.uk/c4mca/mcga-

mnotice.htm?textobjid=59809BACB29DBED8

3


4/8


X-Band, S-Band very early in their careers, navigators are instructed onthe difference between X-Band and S-Band radars.The difference is easilyunderstood and fundamental to efficient radar watch-keeping.

The detailed circumstances surrounding a

collision recently suffered by a Britannia Member

illustrates the consequences of navigators failing

to keep the fundamentals of radar watch-

keeping in the forefront of their mind.

The Members fully loaded bulk carrier was

proceeding north-easterly in open water.

An experienced Second-Officer was in charge

of the morning 8-12 watch and reported

variable visibility throughout the watch, being

poor at times with showers and drizzle.

Noticing that the forward mast-head light

appeared scattered and diffused,he estimated

visibility in the region of 1 nautical mile (nm);

this was confirmed by the 12-4 watch.The deck

log book had recorded rough to moderate sea

and swell with overcast sky and, inaccurately,

moderate to good visibility.

Throughout the morning 8-12 watch no vessels

were sighted either visually or by radar. However,

within 5 minutes of the afternoon (12-4) watch-

keeper taking over the watch, the look-out

visually sighted a light on the port side.The light

was diffused and indistinct but it did appear to

be close.The 12-4 watch-keeper immediately

put the vessel on hand steering and started

taking bearings of what now appeared as 2-

mast head lights and a green light, thought to

be side lights, along with deck lights astern.

The 12-4 watch-keeper assessed that there was

no time to take a series of bearings and

ordered starboard helm followed shortly by

hard to starboard the duty officer was then

disturbed by a call from the duty engineer

asking why an increased load had come on to

the main engine.The watch-keeper ended that

call abruptly and attempted to call the Master

but mistakenly called the Chief Officer and

reported the close quarters situation.

The watch-keeper then went to the port side of

the bridge and flashed the approaching vessel

with an Aldis signal lamp and then tried to raise

the vessel on channel 16 VHF. There was no

response.As his own vessel began to swing tostarboard, both vessels approached very close

and subsequently were parallel.The watch-

keeper assessed that it was necessary to go

hard to port in order to swing the stern away

from the other vessel.Unfortunately, this order

was given too late and contact was made

midships. A second contact was made further

aft.The contacts were thought to be slight.

Soon after,VHF contact was made with the

other vessel and details were exchanged.

Significant fault could be attached to the other

vessel, especially as it appeared that the other

vessels total lack of action to avoid the collision

resulted from the watch-keeper being asleep,

(a fact admitted by the radio officer in

exchanges with our Members vessel.) It is

however useful to address the faults of the 8-12

watch-keeper on board the Members vessel.

The 8-12 watch-keeper, when questioned, was

clearly aware of the advantages of S-Band radar

during conditions of rain and similarly was

familiar with the proper use of rain clutter and

sea clutter adjustments. However,only the

X-Band radar was turned on throughout thewatch and there is evidence that the rain and

sea clutter were not adjusted appropriately for

the prevailing conditions.The other vessel was

relatively large at 449 grt and 43m in length.The

steel construction of the other vessel should

have made an easily distinguishable target on

the S-Band radar if the rain and sea clutter were

adjusted appropriately. It is perhaps worth

noting that the X-Band radar was fitted with

ARPA and therefore was perhaps favoured

during ocean passage, when only one radar was

usually utilised.The usefulness of the ARPA

function perhaps led to the advantages of the

S-Band radar being overshadowed by the

convenience of the X-Band radar.There was no

explanation for the watch-keepers failure to

adjust the clutter appropriately and simple

oversight is presumed.

It should be noted that the 12-4 watch-keeper

did adjust the X-Band radar for sea and rain

clutter immediately upon taking over the

watch, but still did not observe the fishing

vessel.He did not utilise the S-Band radar but

in any event had no time to do so. It appears

that the S-Band radar was the only means by

which the vessel could have been located by

radar. It was not switched on however.

Navigators are reminded of Rule 5 of the

Collision Regulations (COLREGs);proper look-

outby all available means

During periods of rain and drizzle the 12-4

watch-keeper had correctly assessed the

visibility to be in the region of 1 nm.The

Masters standing orders clearly stated that he

should be called in the event of visibility falling

to 3 nm. This was not done.If it had been then

the possibility exists that the Master would havecome to the bridge and checked that the

correct radar were being utilised and that

clutter adjustments had been made. Masters

should be aware of a possible reluctance in

junior officers to call the Master irrespective of

standing orders.Masters should encourage

junior officers to call them even if this,

ultimately, proves to be unnecessary.

One further point. None of the watch-keepers

seemed to have considered the need for

sound signals, in accordance with COLREGs

Rules 34-36.

Navigation and Seamanship


5/8

5

Fire on board poor ship board practices resultin uncertainty and delay in dealing with a fire inthe cargo hold.

The Australian Transport Safety Bureau (ASTB)

has recently issued a report into the fire on

board the BBC ISLANDER whilst off Dampier in

August 2007.The report highlighted that

failures in onboard safety management and

training can result particularly in the event ofan emergency in potentially dire

consequences.

The BBC ISLANDER is a general cargo ship that

had previously loaded deck cargo requiring

brackets to be welded on to the hatch covers.

Subsequently those brackets required removal

and a fitter was assigned to remove them with

oxyacetylene cutting equipment.The fitter

accidently cut a hole in the hatch cover and

sparks fell into the cargo hold causing

palletised cargo to catch fire.

The Master quickly decided to fill the hold with

CO, however his entire supply of CO was soon

exhausted with little apparent effect. He then

decided to notify the Harbour Master and

requested more CO and that the ship be

allowed alongside.

Two days later the vessel berthed and the local

fire and emergency services utilised more CO,

but still the fire remained alight.Thereafter, cargo

was removed to reach the seat of the fire so that

fire hoses could be utilised,but the fire persisted.

Expansion foam was utilised to flood the hull.

Still the fire persisted.Eventually, four days after

the fire began, it was extinguished by utilising an

off-shore supply vessels fire monitor to flood the

cargo hold with 700 tonnes of sea water.

It appears that:

The ships officers had not compiled accurate

or complete cargo stowage plans. Apart from

being in breach of SOLAS requirements, this

also meant that the Master and crew did not

have the proper information concerning thelocation and type of the different dangerous

goods on board to allow them to deal with the

emergency efficiently.

Although there was a safety management

system requiring a hot workpermit, the crew

had not been trained or supervised in the

implementation of that procedure. Additionally,

the fitter could not read English and hence

could not understand its requirements in any

event.Accordingly, no continuous fire watch

was maintained inside the cargo hold.

The incident illustrates what all good officers

know; without training and supervision it is

unlikely that safety management systems will be

implemented properly.

The report also highlighted that the shore

firefighters had little experience in responding

to, or fighting, shipboard fires.

http://www.atsb.gov.au/publications/investiga

tion_reports/2007/MAIR/pdf/mair245_001.pdf

Rescuers continue to diein significant numbers

Coincident with the UK Marine Accident

Investigation Branch (MAIB) report on fatalities

on board three separate vessels in the last year,

the Marine Accident Investigators International

Forum (MAIIF) has identified a large number of

fatalities in the shipping industry world-wide

which relate to work in confined or enclosed

spaces.The investigation by the MAIIF hasrevealed 129 fatalities and 123 injuries resulting

from entry into confined spaces

since 1991.

The three specific investigations by the MAIB

into the VIKING ISLAY, the SAGA ROSE and the

SAVA LAKE illustrate the tragedy of the initial

deaths often being multiplied by the highly

understandable, but nevertheless lethal, human

instinct to help a colleague in danger.

All three incidents involved either ballast tanks

or void/store spaces which had become

depleted of oxygen. In the VIKING ISLAY a third

seaman, improperly entering the space in order

to rescue two collapsed seafarers, died along

with his colleagues. In the SAVA LAKE and the

SAGA ROSE, seafarers were again tempted into

the enclosed/confined spaces in order to rescue

their fellow seafarers. Fortuitously the Chief

Officer on the SAVA LAKE having entered the

space, recognised the danger and turned back.

On the SAGA ROSE, the motor man collapsed

whilst attempting a rescue; thankfully he was

rescued following a prompt and efficient rescue

operation and made a recovery.

It cannot be over emphasised how critical it is

that seafarers, upon noticing the collapse or

unusual behaviour of a fellow crew member

whilst in any confined or enclosed space,resist

the temptation to assist by entering that space.

The MAIB report into VIKING ISLAY has already

been published and the other two reports will

be available shortly through the MAIB website.

Such reports could usefully be distributed

amongst all crew members who are likely toenter enclosed spaces by virtue of their duties.

http://www.maib.gov.uk/cms_resources/SB2-

08.pdf

Safety


6/8


Containers and cargoes

Problems loading hot cement clinker in bulk the Club managers havebeen assisting Members with two cases where the loading of hot cementclinker, in excess of 100 degrees centigrade, has posed a safety hazard andrisked damage to vessel hold paint coatings.

The remedy of course is to wait for it to cool

down before loading,but this too gives rise to

costs and delay that may be the subject of later

dispute between owner and charterers.Thisarticle seeks to highlight some of the issues

involved.

The background is that cement clinker is often

loaded directly from the processing plant

where it is baked at high temperatures.This

may have two problematical effects upon the

vessel.The first is that unless holds are coated

with temperature resistant coatings- typically

glass fibre the hold paint coatings will be

damaged, as may the ballast tank coatings.The

second and more important problem is that

the temperature of the IFO in double bottom

fuel tanks may be raised above the flash point

with attendant risk of explosion.In one of the

cases that we saw, the paint coatings were

severely damaged, and bubbled off over large

surface areas, requiring complete re-painting of

the affected holds,with attendant downtime.

Expert advice received by the Club is that for

vessels not equipped with a temperature

resistant hold coating,the means to avoid

these risks is to equip the vessel with suitable

thermometers capable of measuring

temperatures up to 200 C. Prior to loading,the

Master should verify the temperature of the

clinker presented at ships side by physically

measuring temperatures within the bulk of the

stow in barges or lorries. No cargo in excess of

the FP of the IFO should be accepted, and

cargo in excess of 80 C should be allowed to

cool before loading.Protest letters should be

issued as necessary. Many cement clinker load

ports are well used to taking these precautions,

and their protests will be minimal.

During loading of cement clinker, double bottom

tanks should remain filled as long as longitudinal

stress, trim and draft permit, as these provide

boundary cooling to fuel tanks and holds.

Throughout the loading ships staff should

continue to monitor temperatures as cargo is

brought to the vessels side,and any over-heated

cargo should be rejected until it has cooledsufficiently. A record must be kept showing

where temperatures are taken, by what means,

by whom, times and of course temperatures.

The practice of trying to admix the cargo using

grabs in an attempt to cool it has little value

in so far as hold coatings are concerned, as the

damage is done whilst loading.The only sensible

preventive measure is to not permit overheated

cargo to be loaded as described above.

The alternative to the above is to upgrade the

hold coatings to an alkyd based heat resistant

coating of a type that will tolerate loading at

temperatures up to 160 C without damage to

the coating. Such coating may have an

aluminium or glass pigment that is designed to

withstand the much higher temperatures

encountered when cargo is loaded direct from

the bake house or k iln.

The charterer stated, in one of the cases

handled here, that the risk of heating bunkers

in tanks adjacent to very hot cargo, up to their

flashpoint,was minimal, since the atmosphere

would be too rich for ignition within the tank,

and further there was no source of ignition

within the tank.

The expert advice in response was that vapour

may vent on to the deck via the air pipes of

each of the fuel tanks.The vapour leaving the

tank may well still be above the flashpoint. On

deck there are plenty of sources of ignition.

Stevedores smoking, mobile phones, non-

intrinsically safe lighting, motors, radios, etc. Any

of these could cause ignition of the vapour ondeck. Provided the flash screens in the air pipes

are intact it is not likely that a major fire would

result.However if the flash screen is inefficient

then there could be a blow back into the tank.


7/8

7

More cement cargo problemsThe Association continues to have problems

with cement cargoes that have hardened

because of leaking ballast tanks.The price of

cement has risen significantly in line with

most commodities in recent years but the

cost of any cargo damage is quite often

overshadowed by the significant

operational difficulties in loosening and

disposing of hardened cement cargoes.

Masters and crew are reminded of the

importance of pressing up all ballast tanks

adjacent to cargo holds destined to receive

cement, and to closely inspect those holds

for any signs of leakage.Particular attention

should be paid to vent pipes and sounding

pipes passing through the hold.

Inspecting holds on a ballast voyage may

be quite difficult and cherry pickers are

rarely available to Chief Officers inspecting

the upper reaches of a hold, and it is

recognised that inspection of piping can

be especially difficult.

A somewhat old fashioned practice

amongst deck officers was to carry

binoculars whilst working cargo alongside

for the purpose of inspecting derrick and

crane rigging. Given the difficulties that arise

from the smallest of leaks, deck officers may

consider this practice when undertaking the

pre-load inspection of holds.

Beware bankrupt cargo interestThose Members operating liner services would

especially be aware of the expense and nuisance

generated by cargo which is uncollected by

reason of cargo receivers becoming bankrupt.The

Association has recent experience of the difficulties

which Member's agents face when confronted

with the need to dispose of the uncollected

cargo and at the same time the complex and

powerful legal rights given to Court-appointed

administrators of an insolvent company.

In the subject case cargo had not been collected

for over 6 weeks, in which period the Member

had sent several warnings and notices to the

receiver that a lien would be enforced and the

cargo disposed of.None of those notices received

an answer but shortly thereafter a firm of

accountants contacted the Member by

telephone advising that they were the

administrators of the consignee company, which

was in financial difficulty.The administrators

requested extra time to arrange their own sale of

the cargo.Members agent agreed to give the

administrators a week to do so on the expressunderstanding that the lien would be exercised

(i.e. they would force the sale of the goods) if the

administrators failed to pay Members by that

date.The existence of the Administration Order

was only referred to in oral telephone

communication and the time extension agreed

by e-mail.The administrators did not explain that

they were appointed by the Court or what their

powers were nor did they request any further

extension of time.The deadline passed without

any further contact from the administrator and

the Members accordingly arranged the sale of

cargo to salvage buyers to defray their own cost.

After the administrators became aware of the sale

they accused Members of acting in contempt of

Court by breaching the Administration Order.

They subsequently brought proceedings against

the Members in that regard.The Member argued

that the administrators had failed to properly

serve the statutory notice of their appointment.

The legal issues were complex and rather than

embark on an expensive legal battle the claim

was settled on a negotiated basis.

The salutary lesson to be learned is that

Members and their agents, when contacted by

anyone purporting to be a Court appointed

administrator of an insolvent consignee

concerning uncollected cargo should be very

wary of assuming contractual rights of sale and

if in any doubt whatsoever should seek the

assistance of the Association and/or lawyers.

The question of who is liable for damage to

coatings and loss of time in such cases will be a

complex one. Under a time charter it may often

be the responsibility of charterers to load, stow,

trim and discharge the cargo at their risk and

expense. But this may not absolve the Master of

his duties to supervise the loading insofar as it

impacts on the safety of the vessel, and where

the Master fails to intervene when it is clear

that a cargo is hot enough to damage the tank

coatings, this too will impact on the partiesrespective liabilities for the consequences.

Other charter clauses that may be relevant are

the Clause Paramount incorporating the Hague

Rules which provide that the vessel is not to be

employed in the carriage of dangerous or

injurious cargo.

A Member cannot be certain that his experts

view may go unchallenged in any subsequent

arbitration.The lawyer instructed for our

Members on one of the above cases advised:

In relation to the decision not to load cargo

above 80 C, I should hope that an arbitrator

would accept that,given the safety issues

involved, neither the Master nor owners should

be criticised for refusing to load said cargoes

until they had cooled.Further there may be

issues relating to the ability of the hold paint to

tolerate cargoes in excess of 80 C. There is a

risk that owners may be found liable if it is

found that the paint in the hold should have

been able to withstand higher temperatures.

These factors underline the importance of

Members knowing in detail about the coatings

in the vessel holds,and the manufacturers

guidelines for what they can withstand, before

fixing cargoes of this type.Where Members

seek expert guidance before loading and

before damage to the vessel has occurred, this

will do much to mitigate possible subsequent

losses that may be the subject of lengthy and

expensive litigation.


8/8

Brazilian coastal trade foreign crews beware

We are grateful to our correspondents in

Santos, Brazil,Pandibra McLintock, for this

advice about crew visas in Brazil.

The immigration authorities in Brazil are

currently insisting that crews of foreign ships

working in the coastal trade for more than

30 days must have a full working visas. Such

visas are quite difficult to obtain and can only

be issued from consular offices outside Brazil.

This rule is, in fact, inconsistent with Brazil ian

law on the subject, which does allow foreign

crews to work in the coastal trade without full

working visas. However,the immigration

authorities nevertheless insist on the visa

Regulatory update

Publications

Integrated Bridge Systems Volume 1

Radar and AIS By Dr Andy Norris

From 1 July 2008, all new radars required

mandatory AIS integration;this combined use

of data is an innovative example of the power

and capability of modern shipboard

technology to display two completely separate

systems on the same display.While much effort

has gone into ensuring the AIS, radar and chart

information is consistent,with uniform symbols

and a standard resolution, operators still needguidance and instruction.

This new book by Dr Andy Norris and

published by the Nautical Institute builds on

the basic radar theory and target tracking

knowledge that seagoing officers already have

while looking ahead into the future where

New Technology (NT) radars will provide

significantly enhanced performance.

For more details and order information please

go to:

http://www.nautinst.org/press/pdf/radarAIS.pdf

or www.nautinst.org

Editors message We are always looking for ways to maintain and increase the usefulness, relevance and general interest of the articleswithin Risk Watch. Please forward any comments to: [email protected]

8 Britannia RISK WATCH RISK WATCH is published by The Britannia Steam

Ship Insurance Association Limited, and can be

found at www.britanniapandi.com/publications

The Britannia Steam Ship Insurance Association

Limited is happy for any of the material in Risk

Watch to be reproduced but would ask that

written permission is obtained in advance from

the Editor.

Tindall Riley (Britannia) Limited

New City Court

20 St Thomas Street

London SE1 9RR

Tel +44 (0)20 7407 3588

Fax +44 (0)20 7403 3942

www.britanniapandi.com

Miscellaneous

requirement.In order to challenge the

immigration department, it is necessary to start

legal proceedings, which inevitably means that

ships can face delays.While such disputes arebeing resolved, crew members could also face

forced repatriation by the authorities.

Members are advised to check carefully with

local agents to make sure that they are aware

of the current situation and visa requirements

in Brazilian ports to avoid any possible

problems with the immigration authorities.

Documents

Risk Watch Vol 15 No 3