Carrying containers on bulk carriers – can you do it?

The first question is invariably “can we do it?”. Yes, you can, but it requires a lot of careful planning, collaboration and contractual scrutiny.

Owners should first liaise with underwriters, and the vessel’s classification society (‘Class’) and Flag State to seek their guidance and advice as to what modifications, if any, would be required to comply with their requirements.

Here, we look at some of the operational, contractual and insurance aspects to consider.

Operational considerations

Seaworthiness

To demonstrate the vessel’s seaworthiness at the commencement of the voyage, all related Class and statutory requirements must be satisfied. This will include making sure the vessel is suitably equipped to be able to carefully load, handle, stow carry, keep, care for and discharge containers.

It is unusual for a bulk carrier to be fitted out with suitable fittings, equipment and lashings to fulfil this obligation without modification and strengthening of cargo securing arrangements. Additional equipment may be required as well as a need to perform additional strength and stability assessments. Crew capabilities should be also assessed.

The vessel’s documentation may need updating to reflect these changes.

Ship’s structure and stability

As existing strength calculations may only allow for sea pressure loading as opposed to cargo loading weight, tank top, deck and hatch cover loading limits will need to be evaluated and adhered to.

Container securing arrangements should be comprehensively assessed. Strength calculations will be required to ensure operation load limits for securing arrangements will not be exceeded.

Hot work may be required to reinforce and/or secure deck sockets and lashing plates, which must be fully risk assessed and subject to gas freeing procedures and hot work permits. Be aware that welding may be required adjacent to fuel tanks. Any additional fittings and welding will require testing to ensure sufficient strength.

Loading containers on a bulk carrier may impact on stability and this will need to be assessed. Large values of metacentric height (GM) will place increased racking and shearing forces on the hull, cargo and lashing equipment and large roll angles may generate forces that exceed the maximum safe working load (SWL) of lashing plan limits. The limitations of some loading computers may make such calculations more complicated.

Loading calculations will be required to ensure hull stress limits are not exceeded and that load limits on deck lashings are within agreed parameters for the lashing equipment used and the agreed maximum GM of the vessel.

Hatch cover strength

Hatch covers on bulk carriers are generally not designed to accommodate containers. Overall strength, point load limits and sealing arrangements may well be compromised if containers are loaded without first checking with hatch cover manufacturers and Class.

Structural deformation and/or excessive compression of gaskets can have a detrimental impact on the vessel’s weathertightness.  The low freeboard of bulk carriers can expose deck cargo to environmental conditions not experienced on conventional container vessels.

Cargo Securing

Guidance on securing cargo is contained within the IMO publication Code of Safe Practice for Cargo Stowage and Securing (CSS Code).

Appendix 1 of the CSS Code provides some general guidance on securing containers on non-cellular container vessels and refers to the SOLAS mandatory publication the Cargo Securing Manual (CSM). The CSM should provide more detailed instructions on how containers should be secured. If the CSM does not already contain details on container lashing under ‘Non-Standardised Cargo’ it will require updating to the satisfaction of Class and Flag State.

Lashing plans will be required that identify what combination of lashing equipment should be used. Lashing equipment should ideally consist of stacking cones, deck sockets, twist locks, lashing rods and turnbuckles. They must be appropriately certified so that they demonstrate that the SWL limits can accommodate the forces that are likely to be experienced during the voyage. All lashing certification should be supplied to the Master and carried in the CSM throughout the voyage.

Practical consideration will need to be given to how lashings within the hold will be applied and inspected during the voyage. Each inspection will require an enclosed space entry by the crew which introduces additional risks. Access to devices such as twist locks during discharge must also be considered.

Dangerous Goods

Must be carried in accordance with the International Maritime Dangerous Goods (IMDG) Code.

The vessel’s Document of Compliance (DoC) may require updating to ensure reference to IMDG class of dangerous cargo is referenced and just not just the ‘Group’ as would be the case with bulk cargoes.

The DoC will indicate what can and cannot be carried and this must be complied with. Most container vessels are fitted with fixed under-deck firefighting appliances (FFA), this may not be the case with some bulk carriers.

Additional firefighting equipment may need to be placed on board with FFA plans updated and crew trained in its use.

Crew

In order to suitably ‘care for the cargo’, crew will need to be familiar with carriage requirements and shippers’ instructions for the cargo concerned. This includes the ventilation and inspection requirements as well as the action required in the event of a spill or fire.

These matters will need to be considered, discussed, planned and incorporated into the vessel’s safety management system (SMS). When carrying containerised dangerous goods, the crew must be familiar with emergency response procedures (EMS) and medical first aid guide (MFAG) entries for all cargo on board.

Contractual considerations

Bills of lading: Deck Cargo

Typically, most bills of lading (B/Ls) used in the dry bulk trade will not provide for the carriage of cargo on deck. For example, the standard Congenbill form does not contain an express term giving the carrier liberty to carry goods on deck and the simple wording often found in such pro-forma B/Ls may not be sufficient.

If a Member is to issue B/Ls for deck cargo, then it is important to ensure that the B/Ls are claused and state the cargo is actually carried on deck.

Something along the following lines should be considered:

“The cargo is carried on deck at the sole risk of the Shipper. The Carrier shall in no case be responsible for loss of or damage to deck cargo whatsoever and howsoever caused, even if caused by the negligence of the Carrier or his servants or agents.”

However, before issuing B/Ls, we would encourage Members thinking of participating in any such trade to liaise with the Club beforehand to best protect their position and discuss any potential cover issues.

Charterparties

In the context of a time charter, upon being informed of charterers’ intention to carry containers on a bulk carrier, owners should first determine whether under the terms of the charterparty, charterers are entitled to issue orders for the carriage of containers.

If there is a specific exclusion for container cargo, or if the carriage of containers would endanger the vessel or other cargoes on board, owners would likely be entitled to reject such orders.

Careful lashing and securing of container cargoes are crucial for cellular vessels but even more so for vessels converted to carry containers. Under the standard wording of the NYPE charter form, charterers are responsible to “load, stow and trim the cargo at their expense under the supervision of the Captain”. However, responsibility for damage arising due to cargo operations may pass from charterers to owners if the master either interferes in the conduct of such operations, or if he negligently fails to intervene in the conduct of such operations to ensure the safety of the vessel, crew and cargo. It is therefore important for the crew to be familiar with the various operational and safety requirements relating to container carriage in order to be able to properly supervise the cargo operations.

It also bears noting that charterparties for container vessels would usually contain specific provisions tailored to deal with particular issues arising from the container trade. These include warranties pertaining to maximum container stack height, the vessel’s fittings and equipment, and the handling of reefer containers (such as ventilation, power supply, maintenance at sea, and temperature requirements).

These provisions are not typically found in charterparties for bulk carriers and should therefore be negotiated between the parties beforehand, in order to minimise the scope for disputes later on.

Insurance Considerations

Unless already agreed with underwriters, the carriage of containers on vessels not designed for this purpose is likely to be a material alteration of the risk originally accepted.

To ensure that cover is not prejudiced, it is important that underwriters—both H&M and P&I—are notified of an owner’s intention to carry containers as soon as practicable.

Other P&I liabilities to consider include wreck removal and pollution in the event containers are lost overboard. These issues may require further consideration, so Members are encouraged to contact the Club to discuss further and to ensure they are adequately protected.