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INTERTANKO Position Paper on Safety of Navigation in China
During the INTERTANKO Asian Panel meeting held in Hong Kong in April 2015, members raised
concerns in respect to safety of navigation in Chinese coastal waters. The following provides an
overview of these concerns together with recommendations on how to overcome some of the
challenges.
1. Pilotage
1.1 Pilotage Boarding
In general, INTERTANKO’s members are of the view that the pilotage boarding procedures in
Chinese coastal waters need to be more consistent and regulated across all major ports and as
close to international requirements1 as possible. Until a standardised and regulated procedure
can be established, INTERTANKO would recommend establishing the procedure of conveying
the Pilot Boarding Position and Arrangement via the agent to the vessel in advance. The pilot
boarding arrangements should be made uniform and be provided to the Master in writing in
advance of the pilot boarding. Such information should include:
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The boarding position
Height above the water of the pilot ladder
Side of the vessel the pilot ladder shall be rigged
Speed of the vessel when boarding
Pilot ladders will be rigged according to IMO guidance as contained in A960(23)1
Any other information to enable a safe boarding of the pilot and safe manoeuvring of
the vessel.
1.2 Pilotage Experience and Competence
There is a concern that some pilots are not experienced enough to use good judgement and
instead strictly follow the rules and regulations rather than apply good seamanship. Pilots need
to take into account the operation of the bridge team and the dynamic environment of
navigating in a busy seaway.
The latter point is often made more difficult when English is not adequately spoken by some
pilots. Furthermore, extensive dialogue between the pilot to tug Masters, VTIS, other local
Masters and pilots is undertaken in Chinese. While it may be necessary to communicate with
local vessels in Chinese, when this occurs a summary of the dialogue should be relayed to the
Bridge Team in English to improve communication and information exchange. In this context
reference should be made to the IMO's Standard Marine Communication Phrases A.988(22).
1
http://www.impahq.org/admin/resources/pilottransferarrangementsbrochure.pdf
Improving the level of competence in English should not be limited to pilots but should also
extend to VTS operators, pilot launch coxswains and loading masters.
Of particular concern is the lack of an adequate Master-Pilot exchange. In particular, pilots
rarely offer or share information with the Master on a voluntary basis. This is not in compliance
with the accepted necessity for a proper Master-Pilot exchange as contained in IMO Resolution
A.960(23).
Many pilots continue to use cell phones and access the internet during pilotage. This is deemed
dangerous and distracting unless it is specific for the transit, in which case a summary of the
dialogue or communication should be relayed to the Bridge Team in English.
The Bridge Team and Master is not always advised when a trainee pilot takes over from a senior
pilot. Trainee pilots do not always understand the manoeuvrability of ocean going vessels and
issue impossible instructions without considering the critical RPM, e.g. no consideration is given
for the time taken to move from sea speed to harbour speed.
INTERTANKO encourage communication between the Master and the pilot but frequently any
feedback or discussion is viewed as criticism by the pilot. Pilots should be encouraged to enter
into a professional and measured discussion with the Master and his Bridge Team to improve
relations, communication and safety of navigation in general.
In summary, INTERTANKO encourages full compliance with the contents of IMO Resolution
A.960(23).
INTERTANKO’s members have advised of positive experience with Chang Jiang Kou sea pilots (in
particular between the Baoshan River and CJK pilot stations).
2. Hydrographic information at tanker berths and terminals
While some BA charts contain information on depth there is still a number of errors or lack of
accurate information for many tanker terminals. As such, INTERTANKO’s members are reliant on
pilots and agents for providing this information. It would be better to have the official
information provided. This would also apply for under keel clearance at many tanker terminals.
Therefore, INTERTANKO encourages the authorities to pass on the correct hydrographic
information to the relevant hydrographic offices. Furthermore, INTERTANKO encourages the
hydrographic office in China to release INT charts for all areas where vessels engaged in
international trade load and discharge.
3. Small craft and fishing vessel traffic
This is considered a challenge in most entrances to main oil terminals and ports in China.
Particular cases have been observed at:
 Hainan Island
 North entrance to Ningbo which passes through Hangzhou Wan Bay, off Zhousan Island

Yangtze River
Tug-and-tow barges are frequently cited as manoeuvring in or close to shipping lanes where
deep draught vessels sail when they should sail outside these shipping lanes. Such occurrences
frequently happen with (river and harbour) pilots aboard who also frequently fail to
communicate with them and other small crafts.
It is noted that the South entrance to Ningbo is relatively safe in comparison to the north
entrance due to a lower concentration of small craft and coastal traffic.
4. Ningbo and Zhousan Island
Particular attention should be given to the areas around Ningbo and Zhousan Island. A
combination of factors beyond small craft and fishing vessel traffic add to the risk of navigating
these waters. In particular, INTERTANKO has received reports of a high number of rudder fouling
incidents in the area due to fishing nets. Furthermore, the passage to Zhapu from Ningbo has
shallow depths for long stretches adding to the risk. It has been noted that local pilotage
services in the area recommend avoiding bay transits by night which is duly noted by
INTERTANKO members.
One proposal was to introduce an appropriately scaled chart for the transit from Majishan No. 1
Anchorage to Jishan Channel which is about 31nm so that the buoyed channel may be seen.
More positively, while the shallow depths provide a degree of risk for navigating these busy
waterways, the BA charts in this area are considered accurate and fair.
Options to improve the situation in this region:
a. Regulate traffic by designating Passage for Sea Going Vessel, Coasters and Fishing Areas.
b. Monitor more closely and communicate more actively through AIS and VTS traffic
movement. See Straits of Singapore VTIS as an example.
c. Recommend sea going vessels to ensure ships engines are in Manoeuvring Mode while
entering the area, as per common practice in Straits of Singapore and English Channel.
d. Greater use could be made of AIS-B for the small crafts and fishing vessels. One could
even argue for compulsory use of AIS B for small crafts engaged in fishing in or close to
shipping lanes for deep draught vessels.
5. Phantom collision claims
INTERTANKO has been advised that some fishing vessel Masters will actively place the fishing
vessel across the bow of a merchant vessel in the belief that this will increase the haul of the
fishing vessel. Such traditional views should be countered through education by the local
authorities.
Furthermore, it is understood that some fishing vessels may make deliberate attempts to collide
with merchant vessels in order to put claims against the owners.
6. New tanker terminals and port developments
As new ports are developed, greater consideration should be being given to basic navigational
safety issues such as the above list.