In March 2014, the Club reissued its bulletin on sampling procedures for clean product tankers after experiencing an increase in liquid cargo contamination claims on sea going vessels. One of the main issues raised when reviewing these claims was that the vessels’ crews had failed to efficiently obtain and preserve cargo samples. This in turn has led to difficulties in defending the associated claims.
More recently, in late 2015, the Club saw an increase in liquid cargo contamination incidents occurring on inland vessels. In many of these incidents it was noted that the vessel’s crew did not obtain/retain any cargo samples. The Club acknowledges that sampling is not a regulatory requirement for some inland vessels however, it is a vital source of evidence to best protect the Member’s interests in the event of a cargo contamination claim.
To enable the Club to defend our Members’ position in the event of a related claim we recommend the following advice is taken into account. In addition, the Club would like to remind Members that oil terminals may have their own procedures regarding sampling and these will need to be adhered to at all times.
Samples should be drawn in the following circumstances:
Sampling equipment must be clean and suitable for the cargo being loaded. Particular care should be taken when sampling sensitive cargoes such as jet fuel. There have been many instances where claims for contamination have occurred when the cargo was in good condition but the samples were contaminated by dirty sampling equipment. Ideally, there should be a set of sampling equipment for each type of product to be handled.
Note: The manifold sampling point should be blown into prior to the first sample being drawn, to ensure that no water or residues of previous cargo remain trapped in the sample point.
At the start of loading
One sample should be drawn from the cargo manifold for each grade being loaded.
One sample should be drawn from each of the vessel’s tanks when approximately 25cm (or one ‘foot’) has been loaded into the tank.
Furthermore, it is advisable to draw samples at the ship’s manifold at intervals, during the loading operation. This is to protect the Member’s interest whilst loading from several sources, for example trucks and/or tanks, and/or upon completion of delivery from a shore tank which has been emptied. Particularly, in the latter case, it may be possible that sediment in the shore tank is transferred on board which could lead to a high level of concentration in the tank.
Note: Almost all shore terminals will draw ‘first foots’ when loading jet fuels and lubricating oils. They may or may not draw these first foots with other grades. Notwithstanding the shipper’s requirements it is always prudent for the ship staff to draw their own first foot samples. Loading need not be stopped when drawing the first foots however, many terminals may insist that tank loading is suspended until analysis of the sample is carried out by their representatives.
At the start of discharge
One sample should be drawn from each cargo manifold at the start of discharging for each and every grade.
Examination of samples
All Samples must visually be examined when they are drawn, and they must be checked for:
- Water – Are there any droplets of water on the inside of the sample receptacle? Is there any free water in the sample?
- Particles – Are there any visible particles? If so, what are they and where did they come from?
- Colour – Is the sample colour typical for that grade? Is there any deterioration in colour? Officers should be familiar with the expected colour of each grade. A comparison can be made with the samples drawn from the shore tanks before loading (if available).
- Odour – Is the odour typical for that grade? NOTE: it is often very easy to detect the presence of a highly volatile product (such as gasoline) in a less volatile product (such as diesel) by smell.
If it is suspected that the samples are contaminated in any way then in the first instance it is prudent to take a second sample to confirm the findings. The Chief Officer and/or Master must be informed immediately if the officer has any doubt about the quality of the samples.
Labels are to be fixed to each sample receptacle showing:
- Name of ship
- Port and berth number
- Tank or manifold number
- Grade of product, and load or discharge operation
- Date and time
- Name, rank and signature of the sampler
- Name and signature of a witness (preferably a shore representative). Samples should always be sealed and the seal numbers should be recorded in a separate sample log book.
It is recommended that samples are retained for a minimum of three months, or until the cargo has been delivered without complaint (whichever is the longer). Samples must be kept in a designated space, locked up and out of direct sunlight.
Samples must only be disposed of in a proper way and in accordance with environmental legislation. Samples must not, under any circumstances, be “dumped” into the sea. The Club recommends the vessel’s slop tank can be utilised for disposal of samples.
When disposing of samples the labels must be removed from the receptacles.
We thank BMT Surveys (Antwerp) NV for their valuable contributions to this bulletin.