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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: 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.