training & competence

gas as a
marine fuel

environmental
Simultaneous Operations
(SIMOPs) during LNG
bunkering.

technical
safety safety

version 1.0 FP08-01

contractual
Version 1.0, May 2018.

© Society for Gas as a Marine Fuel, 2018.

ISBN: 978-0-9933164-7-0

All rights reserved. No part of this publication may be reproduced,

stored in a retrieval system, or transmitted in any form or by any means,
electronic, mechanical, photocopying, recording or otherwise, without the
prior permission of the Society for Gas as a Marine Fuel.

Disclaimer

While the advice given in this “Simultaneous Operations (SIMOPs) during

LNG bunkering” has been developed using the best currently available
information, it is intended solely as guidance to be used at the owner’s
own risk.

Acknowledgements

This document was produced by SGMF’s Working Group 8. SGMF

acknowledges the participation of the following individuals and
companies in its development:
Dan-Erik Andersson (Port of Gothenburg), Mark Bell/David Haynes (SGMF),
Stuart Carpenter/Tom Strang (Carnival Maritime), Blaise Ferrao/David
Copeland (Shell Shipping), Michael Johnson (DNV GL), Andries Krijgsman
(Royal Haskoning DHV), Marcel LaRoche (BC Ferries), Nic Read/Warwick
Pointon (Woodside Energy), Vincent Roullet (Engie), Paul Schroé (Port of
Zeebrugge), Paul Davies (Lloyds Register).

SGMF would also like to acknowledge the contributions of the following

individuals and organisations:
Tom Spencer/Jesus Larrinaga (Lloyds Register), Mark Lane (previously
Excelerate Energy), Rose Brooks (Mitsui OSK Lines), Dorata Kwasnik/Ronan
Chester (Port of Vancouver), Gary Lengle (Fortis BC), Andrew Brown (Smit
Lamnalco), Mohamed Zaitoun (previously UASC), Tony in’t Hout (Stream
Marine Training), Darren Barton (Calmac Ferries) and Ethan Lewallen (US
Coast Guard).

© Society for Gas as a Marine Fuel

 training & competence
Foreword
The use of LNG as a fuel offers ship operators significant opportunities
as environmental constraints evolve. However, LNG has different
characteristics to other marine fuels. It is important that the effects of
this are understood so that LNG is used safely and in a manner that is
practicable for all parties involved in bunkering operations. This SGMF

environmental
guidance provides stakeholders with a vital point of reference.

This document addresses the potential for interaction between LNG

bunkering and other activities, with regard to the receiving vessel and the
surrounding area. Activities carried out at the same time as bunkering are
referred to as SIMultaneous OPerations (SIMOPS). They include both regular
activities, such as cargo or passenger loading, and unplanned events.

The need to risk assess SIMOPS is not new, but the introduction of
LNG bunkering creates a new context. This guidance has therefore
concentrated on how to apply existing and well-tested techniques to LNG

technical
bunkering operations, and defines the roles and responsibilities of the
various stakeholders involved. It provides a risk-based framework and
can be applied to any bunkering arrangement, in any location.

As the demand for LNG fuel increases, and more facilities and personnel
become involved, there is a clear need to inform and set expectations.

I have been involved in researching and assessing the hazards

associated with oil and gas operations – including LNG – for nearly four
decades. A common theme in accidents is a lack of proper assessment
of the hazards and risks, particularly in environments where there are safety
multiple activities happening simultaneously. If you don’t assess the
hazards properly, you can’t control and mitigate the risks.

The framework described in this guidance is not prescriptive. Instead,

it places the onus on stakeholders to assess and understand their
operations and to control risks effectively. In this, I hope it encourages the
management of SIMOPs in such a way that LNG’s enviable safety record is
maintained as the use of LNG as a marine fuel grows.
contractual

Mike Johnson
DNV GL / Chairman, SGMF WG8 SIMOPs

© Society for Gas as a Marine Fuel I

Contents
Foreword...................................................................................I

Abbreviations............................................................................IV

1. Purpose & Scope...................................................................1

1.1. Aim................................................................................................... 1
1.2. Supporting Documentation........................................................... 2
1.3. Bunkering Types and Activities...................................................... 2

2. SIMOPs..................................................................................3
2.1. Defining SIMOPs............................................................................. 3
2.2. Risk Assessing SIMOPs.................................................................. 10
2.3. Management Systems................................................................... 16

3. Risk Management Guidelines for Operations During

Bunkering..................................................................................18
3.1. STAGE 1: Define............................................................................... 21
3.2. STAGE 2: Identify Hazards.............................................................. 22
3.3. STAGE 3: Assess Risk...................................................................... 23
3.4. STAGE 4: Accept.............................................................................. 25
3.5. STAGE 5: Check and Authorise...................................................... 27
3.6. STAGE 6: Prepare............................................................................ 28
3.7. STAGE 7: Implement....................................................................... 28
3.8. STAGE 8: Complete......................................................................... 28

4. Planning for SIMOPs.............................................................29

4.1. Considerations for Port Planning and Design............................. 29
4.2. Considerations for Gas-Fuelled Ship Design............................... 30

5. References.............................................................................32
5.1. Supplementary Reading:............................................................... 32

Appendix A: RISK Assessment & Ranking Guidance................34

A1. Additional HAZID Guidewords...................................................... 34
A2. Risk Identification and Management Methods........................... 35

© Society for Gas as a Marine Fuel II

 training & competence
Appendix B: SIMOP Considerations..........................................42
B1. Container Ship................................................................................ 42
B2. Bunker Vessel.................................................................................44
B3. Cruise Ship...................................................................................... 45
B4. Offshore Support Vessels............................................................... 47

environmental
B5. Tankers............................................................................................ 48
B6. Ro-Pax Ferry.................................................................................... 50
B7. Bulk Carriers.................................................................................... 51
B8. General Cargo................................................................................ 53
B9. Terminal Operator.......................................................................... 54

technical
safety
contractual

© Society for Gas as a Marine Fuel III

Abbreviations
ALARP/ALARA – As Low As stop operations in a controlled
Reasonably Practicable/As manner and return the system to
Low As Reasonably Achievable a safe state
without incurring excessive cost
An ESD system may have
API – American Petroleum several sequential stages, with
Institute the operation of each stage
dependent on the potential
ASME – The American Society of consequences of the situation.
Mechanical Engineers During bunkering these stages
are commonly designated ESD-1
BAT/BACT – Best Available and ESD-2:
Technology/ Best Available Control
Technology. The environmental • ESD-1 – where transfer of
equivalent of ALARP LNG to the bunkering vessel
is stopped
BOG – Boil-Off Gas. The vapour • ESD-2 – where the transfer
created by evaporation from the system is disconnected from
surface of a volume of LNG the bunkering ship
CCNR – Central Commission In some ship types there may be
for Navigation of the Rhine. The additional definitions of the ESD
body that controls regulations system but these are outside the
on the major international inland scope of this document
waterways of Europe
GIIGNL – Groupe International
Competent Authority – Any des Importateurs de Gaz Naturel
national, regional or local Liquéfié. The industry group
authority or authorities made up of the world’s main LNG
empowered, alone or together, importers
to act as the regulatory body on
LNG bunkering HAZID – HAZard IDentification.
There are a number of
EN – European (Standard) Norm recognised methods for the
formal identification of hazards.
ESD – Emergency Shut-Down. A For example, a brainstorming
control system and associated exercise using checklists where
components that when activated the potential hazards in an

© Society for Gas as a Marine Fuel IV

 training & competence
operation are identified and to the point where it is liquid at a
gathered in a risk register to be stated pressure. GNL in French,
addressed and managed Spanish and Italian (French Gaz
Naturel Liquéfié)
IAPH – The International

environmental
Association of Ports and Monitoring & Security Area
Harbours – An area around the LNG
transfer equipment that
IGF Code – The International needs to be monitored as a
Code of Safety for Ships using precautionary measure to
Gases or other Low-Flashpoint prevent interference with the
Fuels transfer operation

IMCA – The International Marine NFPA – The National Fire

Contractors Association. An Protection Association. A US-
industry group made up of the based standards body for fire,

technical
world’s main offshore, marine electrical and related hazards
and underwater engineering
contractors NGO – Non-Governmental
Organisation. A not-for-profit
IMO – The International organisation independent of
Maritime Organization. The governments or international
United Nation’s maritime governmental organisations
regulatory body
OCIMF – The Oil Companies
ISM – The International Safety International Marine Forum.
Management Code published by An association representing safety
the IMO operators of oil tankers and
terminals, dealing with safety
ISO – The International and environmental issues
Organization for Standardization. and specifically associated
An international standard- with mooring and berthing
setting body composed of guidelines
representatives from various
national standards organizations PIC – Person In Charge. The
person responsible for the
contractual

LNG – Liquefied Natural Gas. management of an operation

Natural gas that has been cooled such as bunkering

© Society for Gas as a Marine Fuel V

Abbreviations
POAC – Person in Overall a Marine Fuel. An international
Control. The person responsible organisation providing guidance
for the management of the on the safe and responsible
LNG bunkering process and use of low flashpoint fuels in a
any SIMOPs being undertaken marine context
through one or more PICs
SIGTTO – The Society of
PPE – Personal Protective International Gas Tanker
Equipment and Terminal Operators. An
organisation representing
QRA – Quantitative Risk operators of gas tankers and
Assessment. A formalised, import and export terminals,
numerical risk assessment covering all liquefied gases in
method for calculating a risk level bulk
for comparison with defined risk
criteria SIMOP – SIMultaneous
OPeration. Defined in this
Safety Zone – A three- document as “LNG bunkering
dimensional envelope of plus one, or more, other
distances inside which the activities and/or operations
majority of leak events occur conducted at the same time
and where, in exceptional where their interaction may
circumstances, there is a adversely impact safety,
recognised potential to harm ship integrity and/or the
life or damage equipment/ environment”
infrastructure in the event of a
leak of gas and/or LNG SMS – Safety Management
System, as defined by the
SGMF – The Society for Gas as ISM Code

© Society for Gas as a Marine Fuel VI

 training & competence
1. Purpose and Scope
1.1. Aim

This document aims to provide guidance on how to determine which

other ship and port operations may be conducted safely while an LNG-
fuelled ship is being bunkered. The operations occurring around the

environmental
bunkering activity are often referred to as SIMultaneous OPerations, or
SIMOPs.

The need for SIMOPs assessment is not new. It was established in the
offshore oil and gas industry – for example, by the International Marine
Contractors Association (IMCA) – and is now common practice on all types
of ships. In this document, SGMF is not creating new rules for SIMOPs but
is building on existing good practice so that it can be applied more easily
to LNG/gas-fuelled ships and bunkering locations.

LNG is a boiling liquid at fuel storage conditions and normally there is

technical
a gas phase associated with the liquid. It presents different hazards
compared with bunker oil so there is a need to manage these
appropriately during bunkering. As a consequence, at this early stage of
the industry there is a need for more detailed guidance and procedures to
reflect the different hazard profile of LNG. The Society for Gas as a Marine
Fuel (SGMF) has applied the latest thinking in this guidance to assist ships,
ports, and bunkering facility owners and operators to achieve good
practice and to encourage consistency.

This document:
safety
• identifies the additional risks that SIMOPs might generate
• examines strategies to reduce SIMOPs risks
• reviews risk assessment and decision-making techniques involved in
allowing SIMOPs
• provides an overview of the documentation likely to be necessary to
justify SIMOPs taking place

For most combinations of gas-fuelled vessels, bunkering infrastructure

contractual

and ports it should be possible to identify operations, both routine and

© Society for Gas as a Marine Fuel 1

more occasional, that may need to be carried out at the same time as
LNG bunkering. This analysis should also be able to identify risks and
restrictions to allow the development of SIMOPs plans, transportable
without major modification across a range of locations.

1.2. Supporting Documentation

These guidelines were created collaboratively by industry members

of SGMF. The guidance assumes that receiving ships and LNG supply
facilities are designed according to the relevant and applicable codes,
regulations and guidelines. These include those published by the
International Maritime Organization (IMO), ISO, API, ASME, EN and NFPA
standards-making bodies, Classification Societies, and international
industry bodies such as SGMF, SIGTTO and OCIMF.

International, national or local regulating bodies will define the minimum

safety requirements. Competent authorities will enforce the regulations
and will define procedures for compliance. The applicable regulations
should be clearly identified and known by all parties involved in LNG
bunkering before operations begin and should be reviewed in the
planning stage of bunkering.

Besides the statutory regulations, the participants in LNG bunkering

operations must anticipate and comply with company and terminal policy,
procedures and good practice guidelines.

1.3. Bunkering Types and Activities

These guidelines address the following operational scenarios:

• ship-to-ship bunkering
• truck-to-ship bunkering
• shore-based terminal-to-ship bunkering
• portable LNG tanks used as fuel tanks

More details of each are provided in the SGMF publication “FP07-1 – gas
as a marine fuel, safety guidelines, bunkering”.

© Society for Gas as a Marine Fuel 2

 training & competence
2. SIMOPs
2.1. Defining SIMOPs

SGMF expects SIMOPs during LNG bunkering to be the norm, as is the

case for oil bunkering. SIMOPs will need to be reviewed to identify
potential interactions and determine if any measures need to be

environmental
implemented before the activity can proceed. In certain circumstances
it may not be possible for a SIMOP to take place at the same time as
bunkering.

SIMOPs can take place anywhere around the bunkering location,

including on the receiving ship, on the bunker vessel, on the quayside, or
in surrounding waters.

SGMF defines SIMOPs as:

LNG bunkering plus one, or more, other activity and/or operation
conducted at the same time where their interaction may adversely

technical
impact safety, ship integrity and/or the environment

This can be broken down into the following elements:

i. LNG bunkering plus one, or more, other activities and/or operations

ii. where their interaction may adversely impact safety, ship integrity
and/or the environment
The following paragraphs go through each element in more detail.

i. LNG bunkering plus one, or more, other activities and/or operations safety

For this guidance, “LNG bunkering” as an operation includes: lifting

and placing of the bunker hoses using a mechanical handling device;
connecting and leak testing; transferring LNG and managing vapour
return; monitoring LNG tank pressures and temperatures; and purging
and disconnection.

Cargo handling (even if it is LNG on a LNG carrier), bunkering of other

fuels, loading of stores, passenger movements, maintenance and testing
contractual

are all operations independent of LNG bunkering.

© Society for Gas as a Marine Fuel 3

Four types of SIMOPs have been identified:

Table 2.1: SIMOPs Types

Regular SIMOPs Non-standard but planned

Operations that happen in the same or

Operations that happen infrequently but
very similar way on a frequent basis, such
are known and can be planned for. For
as people/passenger/crew movements
example, maintenance or life boat drills.
and cargo loading and unloading.

Non-standard and unplanned External activities

Activities or events, normally short-term

Operations that occur unexpectedly and and irregular, that are beyond the control
infrequently and need immediate atten- of the bunkering stakeholders and
tion. For example, breakdowns. potentially the terminal/port. For example,
security alerts or public festivals.

Below is a non-exhaustive list of regular and planned operations that

might be considered as SIMOPs:

Planned SIMOPs (Regular & Non-standard)

people/passenger/crew movements
• passenger/vehicle embarking/disembarking near LNG bunkering
• vehicle movements delivering passengers/crew/visitors
cargo loading/unloading
• lifting of cargo from/to dockside to/from ship
• loading/unloading of heat generating or other hazardous cargoes
• operation of hatch covers
• loading/unloading of pumped cargoes and solid cargoes using
conveyor belts that may create static electricity
• loading/unloading of cargoes that create noise and airborne dust
loading supplies and removing waste
• service vessels/deliveries (for example, stores, port officials, oil
bunkers, lube oils, crew change, laundry and garbage collection)

© Society for Gas as a Marine Fuel 4

 training & competence
port/terminal activities
• construction and maintenance activities
• operation of local generators (sparking engines)
• hot work, welding, grinding or paint removal (using a blow torch)

environmental
• disposal of waste and rubbish by burning
• vehicle movements
monitoring of mooring lines, particularly between bunker vessels and
gas-fuelled ships
maintenance, inspection and cleaning of vessel areas and
equipment
• use of non-intrinsically safe electric or sparking machinery or tools
• testing of stabilisation systems
• testing of high-power radio and radar systems

technical
• testing of ballast water systems
• maintenance and testing of power generation systems (black-out
concerns)
• maintenance and testing of control systems (full functionality not
available/spurious alarms distract)
• testing of cargo equipment (cranes, conveyors, pumps, and so on)
• control system software upgrades (local or centralised systems)
• hold cleaning
• inspection of hull using divers safety
• maintenance and testing of non-intrinsically safe electrical
equipment
• hot work, welding, grinding or paint removal (using blow torch),
use of sparking tools
• cabin/common area cleaning
life boat drills
ballasting operations
contractual

simultaneous bunkering with other fuels

© Society for Gas as a Marine Fuel 5

 Specialist operations
• Dynamic Positioning (DP) system operation and/or testing
• helicopter operations

All of these operations may have their own precautions and many may
have similar risk management requirements to LNG bunkering, for
example, prohibiting smoking.

Many of these processes may be routine but some, particularly periodic

maintenance and inspection, may be infrequent or even one-off (non-
standard) operations.

All these SIMOPs need to be risk assessed and approved (or prohibited/
delayed, as necessary). The only difference is in the timescales; regular
and planned SIMOPs can be evaluated significantly in advance of
ship arrival. Unplanned and external events must be risk assessed
immediately before bunkering. If the event occurs during LNG transfer, the
flow of LNG should be halted until risk assessment has been completed
and further mitigations, if any, agreed. Special attention should be
given to unusual activities that might significantly increase the assessed
consequences of an incident.

ii. where their interaction may adversely impact safety, ship integrity
and/or the environment

The POAC/PIC controls the bunkering safety zone (SGMF FP02-01

“Recommendations of Controlled Zones during LNG bunkering”) and
observes the monitoring and security area.

The key roles of the PIC/POAC are to:

• stop the transfer of LNG if an event, including a SIMOP, occurs which

significantly increases risks or makes the process unsafe or they
believe that such an event is imminent
• ensure that only authorised personnel (trained, required for their role
and properly equipped) are within the safety zone

© Society for Gas as a Marine Fuel 6

 training & competence
• ensure that any risk mitigations, including SIMOP restrictions, are in
place and remain in place and uncompromised throughout bunkering
• communicate clearly, effectively and continuously with all parties involved

Additional responsibilities of the PIC/POAC are documented in SGMF’s

environmental
publication “FP07-1 gas as a marine fuel, safety guidelines, bunkering”.

SGMF defines the safety zone as

the three-dimensional envelope of distances inside which the majority
of leak events occur and where in exceptional circumstances there is a
recognised potential to harm life or damage equipment/infrastructure
as the result of a leak of gas/LNG

The zone is temporary in nature, only being present during LNG

bunkering. It may extend beyond the gas-fuelled ship/LNG road
tanker/bunker vessel, interconnecting pipework, ISO containers, and

technical
so on. The bunkering safety zone is shown diagrammatically in Figure
2.1. A full description of the safety zone is provided in SGMF’s “FP02-1
Recommendation of Controlled Zones during LNG Bunkering”. A tool to
estimate the safety zone is provided on SGMF’s website (www.sgmf.info).

Figure 2.1: Bunkering Management Zones (road tanker-to-ship example)

LNG BUNKERING
ZONES ILLUSTRATION
(Truck to ship Method
shown as example)

safety
contractual

I HAZARDOUS ZONE IV MARINE ZONE

II SAFETY ZONE V EXTERNAL ZONE
III MONITORING AND SECURITY AREA

© Society for Gas as a Marine Fuel 7

The purpose of the safety zone is to minimise the risk of harm to people,
impact on the environment and damage to equipment. This is achieved
by controlling all activities that take place within the zone and observing
and assessing the risks of activities within the monitoring and security
area which, if left to continue without management, could subsequently
impact the safety zone.

Typical control measures in the bunkering safety zone should include:

• excluding non-essential people and vehicle movements

• protecting staff through use of appropriate PPE
• avoiding (or controlling) ignition sources
• effective communication between the POAC/PIC(s) and all involved
• a method for quickly and effectively shutting down operations should
an unplanned event occur
SIMOPs must not compromise these basic requirements for the safety
zone. If additional personnel or activities are required, they must observe
these control measures.

Each SIMOP may also have an area associated with it where any hazards
associated with this task may occur, for example:

• areas of the deck where cargo will be loaded and where any cargo
may be dropped
• hazardous zones around any non-intrinsically safe electrical
equipment which may escalate another hazard
• the hazardous nature of some cargoes
• areas where untrained people and vehicles congregate

If the bunkering safety zones can be demonstrated not to overlap

with these SIMOPs risk areas, then it is likely there would be no
interaction between the two activities. However, it should be noted
that while the vast majority of LNG releases would not present a
hazard outside the safety zone, there are credible but very low
frequency events that could. In cases where there is vulnerability to

© Society for Gas as a Marine Fuel 8

 training & competence
high consequences, measures to assess SIMOPs may need to extend
beyond the safety zone.

Figure 2.2 shows the bunkering safety zone for a generic container
ship receiving LNG from a bunker vessel. In this example the safety

environmental
zone reaches around the hull of the vessel and to a limited extent
across the main deck of the container ship; four rows of containers
(20 stacks, 11% of the 175 stacks available) lie partially within the zone.
Safety zone procedures should limit activities in this area, such as
removing and loading containers, operations of reefer containers
(non-intrinsically safe electric motors) unless a risk assessment
indicates otherwise. Locating hazardous cargo containers might
also need to be avoided. The rest of the container ship, the other 16
rows, could be loaded and unloaded as normal unless these loading
operations pass through the safety zone.

technical
Figure 2.2: Bunkering Safety Zone for a Container Ship
Container stacks that need risk assessment to show that
they can be safely loaded/unloaded during bunkering

10,000 TEU Container Ship

7,500 m3 LNG bunker vessel

LNG bunker manifold

Bunkering safety zone © SGMF 2017
safety

Dropping a container or stack of containers onto the bunker vessel could

cause injury, damage and potentially a spill of LNG. During the HAZID
process the container vessel therefore would need to examine where
its containers could fall and consider extending its loading/unloading
restrictions to cover this possibility. Figure 2.3 shows these additional
safety zone interactions.
contractual

© Society for Gas as a Marine Fuel 9

 Figure 2.3: Modified Bunkering Safety Zone for a Container Ship
Container stacks that need risk assessment to show that
they can be safely loaded/unloaded during bunkering
Risk to In Safety Risk to
LNGC Zone LNGC 10,000 TEU Container Ship

7,500 m3 LNG bunker vessel Container fall – safety zones

Bunkering safety zone LNG bunker manifold © SGMF 2017

A further 12 container stacks could be affected by loading restrictions

under this scenario.

2.2. Risk Assessing SIMOPs

As discussed previously, SIMOPs can create additional risks by introducing

additional hazards, increasing the likelihood of an LNG/gas leak, and/or
escalating an event, should it occur, by increasing the severity of consequences.

With respect to SIMOPs, risk management and mitigation is all about

placing barriers between threats and consequences.

Definitions:
Threats A threat is an event that has the potential to cause a hazard
such as a release of LNG from the transfer hose. In this
case it is only a threat when LNG is present in the hose.
Also known as an Initiating Event

Hazards A hazard is an event that has the potential to cause

harm or damage, for example, an LNG hose leak.
Also known as an Unwanted Event

Consequences Consequences are the potential outcomes if a hazard

occurs. Again, actions can be included to prevent or
mitigate these consequences, for example, no smoking
in areas where flammable gases may be present.

© Society for Gas as a Marine Fuel 10

 training & competence
Barrier Barriers are actions, policies, physical design features
and/or active and passive safety systems which stop
a threat leading to a hazard or prevent/mitigate the
consequences.

environmental
LNG bunkering, like any transfer of material from one place to another,
may result in some of the LNG or the returning gas being lost in the
process. There are many potential threats and several of these can be
caused by SIMOPs. A non-exhaustive list is provided in Table 2.2.

Table 2.2 Threats during bunkering

Independent of SIMOPs SIMOPs related

LNG bunkering transfer system badly Damage to the LNG bunkering transfer
connected, causing leaks which were not system from dropped objects, for example,
identified during leak checking cargo/container loading

technical
Damage to the LNG bunkering transfer
LNG bunkering transfer system assem-
system from a collision by a road vehicle
bled or operated incorrectly, for example,
or another vessel either directly or through
removal without proper draining
causing excessive movement

Excessive movement such as testing stabi-

LNG bunkering transfer system badly lisation systems, poor ballast management
supported leading to stress in specific or poor loading management (may over-
components stress connectors allowing them to leak or
even break away)

LNG bunkering transfer system or its com- If the LNG bunkering personnel become
ponents damaged or corroded through distracted by other SIMOPs then overfilling safety
long-term poor operation and/or storage and venting of gas is more likely

If there are activities like maintenance or

testing that could trigger or disable control
and monitoring (alarm) systems or result
in power failure (Note: The IGF Code and
Class rules require that power failures lead
to a fail-to-safe mode but this could result
in venting of gas)
contractual

Once a leak has occurred, various outcomes that affect the behaviour of
the gas/LNG are possible. Some of these scenarios result in no further

© Society for Gas as a Marine Fuel 11

impacts while others may escalate to become more serious by impacting
additional items of equipment, personnel or the surrounding environment.
A non-exhaustive list is provided in Table 2.3.
Table 2.3: Consequences

Escalations independent of SIMOPs SIMOPs related escalations

Some maintenance and construction

activities (SIMOPs) will involve naked flames
such as blow torches, removing paint, and
fires (burning rubbish)

Some cargo operations maintenance and

construction activities (SIMOPs) will involve
The PIC does not appropriately control the non-intrinsically safe electrical equipment,
safety zone and/or does not monitor the gasoline/petrol engines of vehicles, main-
surrounding area, resulting in the pres- tenance activities such as welding and
ence of ignition sources such as sparks grinding, testing of radio/radar equipment,
and naked flames clashing of two metal/stone surfaces dur-
ing cargo unloading or construction activity
which can produce sparks

Some cargo operations such as conveyor

belts and some fluid pumping systems
can create static electricity which may also
cause sparks

Additional people, probably as passengers

but also crew and port workers marshalling
passengers, placing and securing cargo or
Failure of the LNG bunkering system or performing construction and maintenance,
its components through damage or could be present in both small and large
corrosion from long-term poor operation numbers and be exposed to the conse-
and/or storage quences of any hazard that occurs

Outside the port, local population levels

may change significantly for festivals, sports
matches, and so on, on a day-to-day basis

Other fuel transfers and some cargo may

have hazards of their own associated with
them – for example, coal and oil are flam-
mable – which leads to an increase in the
amount of hazardous material involved

Table 2.4 links these threats and consequences with generic types of SIMOPs.

© Society for Gas as a Marine Fuel 12

 Table 2.4: Escalation routes of threats resulting from SIMOPs while LNG bunkering
Threat Consequence

SIMOP Freeboard Loss of Increased

Dropped Ignition Additional
Collisions / location power or hazard
object source people
changes control inventory
People/passenger/
Yes – Possible – Yes Yes –
crew movements

Cargo loading/
Yes Yes Yes – Yes Yes Possible
unloading

Loading supplies
Yes Yes – – Yes – –
and removing waste

Ballasting – – Yes – – – –

© Society for Gas as a Marine Fuel

Bunkering with other
Yes – Possible – – – Yes
fuels

Maintenance of
deck/terminal – Possible Possible Yes Yes – –
equipment

Accommodation
– Possible – – Yes Yes –
cleaning

Lifeboat drills Yes Possible – – Possible Yes –

Helicopter
Specialist operations – DP Systems – – – –
operations

13
Port/terminal activities Yes Yes – Possible Yes Yes –

contractual safety technical environmental training & competence

A way of visualizing barriers is through a so-called Swiss cheese model,
Figure 2.4. The holes in the slices represent potential failures of a specific
barrier. For example, the barrier could be a procedure for an activity
and the hole could be the failure of the responsible person to follow that
procedure. Where there are multiple barriers, failure of one is unlikely to
result in the hazard being realised. However, there are circumstances
where multiple barriers fail, and this is illustrated in Figure 2.4 as the holes
align to allow a free path from the threat to the hazard.

Figure 2.4: Swiss Cheese Model

Personnel behaviour
Policies & Design features
procedures
Safety equipment
Unmitigated
THREATS

THREATS Potential for

CONSEQUENCES
BARRIERS

There are primarily three types of barrier:

• personnel – for example, ensuring competency by appropriate

training in the bunkering process
• procedures and processes – for example, a safety management
system such as a SIMOP procedure and checklist (barrier) to prevent
an item of cargo being dropped on the bunkering system (threat)
• engineering/equipment/technology – for example, a pressure-
relief valve (barrier) that lifts when a certain pressure is reached,
preventing any further increase (threat)

Barriers also exist for consequences. For example:

• a drip tray (barrier) stops LNG hitting a steel deck structure causing it
to undergo brittle fracture (consequence)

© Society for Gas as a Marine Fuel 14

 training & competence
• training of personnel (barrier) to stop leaking LNG (consequence) as
fast as possible

Reducing risk is about putting the right barriers in the right place at the
right time.

environmental
Many techniques, both physical and procedural, can be used to reduce
the likelihood of a risk occurring or the scale of the consequences. These
include:

Physical systems

• size of transfer system and pressure and rate of transfer

• location of the bunker station
• pressure and temperature relief valves and vent mast location

technical
• spill trays and water curtains
• fire-fighting equipment
• electrical equipment certified for hazardous area use
• personal protective equipment
• dockside layout for cargo/passenger operations
• port terminal siting and layout – passing marine traffic, proximity to
people

Personnel behaviours safety

• trained and competent staff

• effective communication and management of the transfer process
Management systems

• operating and safety manuals

• no smoking areas/protocols
contractual

• risk assessment
• permit to work system

© Society for Gas as a Marine Fuel 15

2.3. Management Systems

A range of stakeholders must approve the bunkering process and any

SIMOPs.

The approval will be at two levels: firstly confirmation of the bunkering

process on a generic level for a stated period of time: and, secondly, for
specific bunkerings on a day-to-day basis.

At a generic level, and prior to any day-to-day bunkering agreement, the

LNG supplier and receiver will require:

• approval under the IMO International Safety Management (ISM)

Code, which requires ship owners (or charterers, if in control) to
create a Safety Management System (SMS) for their vessel which
includes allowable operations and risk management processes; and
for this to be approved by the Flag Administration (Class may wish to
be consulted)
• some form of authorisation, permitting or licensing process for LNG
bunkering supply to be present, under which the authorised local/
national authority will allow the bunkering of LNG within a specified
area; this process should confirm that the bunkerer/LNG supplier,
either shore-based or from a bunker vessel, has an appropriate SMS
and other risk mitigation measures in place
On a day-to-day basis, the LNG supplier and the receiving ship must
confirm that the bunkering takes place as stated in their bunker
management plan which implements the generic approvals. The process
is summarised in Figure 2.5. The tasks partly in the yellow area are
undertaken each time a vessel bunkers to ensure that the local conditions
– for example weather – do not breach any conditions imposed by local
authorities and facility owners.

The competent authority must, at a minimum, have the ability to remove

their consent for the SIMOP and/or bunkering operation if participants do
not follow the procedures and observe the limitations of the consent.

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 training & competence
Figure 2.5: Example Bunkering Approval Process

Single or multiple bunkerings at a defined

location for specific bunkering equipment to
a named vessel

Receiving ship

environmental
Bunker supply Bunkering

Competent authority for Flag administration

area/country
Location factor
multiple bunkerings over a multiple bunkerings over a
defined period Terminal owner defined period
and/or Port authority

Regular and non-standard but planned SIMOPs (see Table 2.1 on p4)
can be risk assessed and approved well in advance of the bunkering
taking place. This is because the risks can be identified and applied to
all supply situations envisaged in the bunkering contract via the bunker

technical
management plan.

Non-standard and unplanned operations need to be risk assessed and

approved but this must happen before or on their occurrence. Competent
authorities (port, local authority and/or flag administration, depending on
the stakeholders involved) should provide general guidance to all ships
about what they will require in these situations – for example, schemes of
work, permit to work systems and/or specific formats of risk assessment –
to streamline this process.

It is easy to envisage physical activities that can impact safety. It is more safety
difficult, but equally important, to look at how human resources can
impact safety. In many cases, it is a human making a mistake that leads
to consequences, sometimes unforeseen. Having the right number of
staff – properly trained and unimpaired by fatigue – to concentrate on
their specific roles is crucial to safe bunkering. With SIMOPs the issues
are magnified and additional competent staff will be required to manage
additional operations.
contractual

© Society for Gas as a Marine Fuel 17

3. Risk Management Guidelines
for Operations During Bunkering
SGMF believes that procedures and rules can be designed to successfully
allow appropriate SIMOPs through co-ordination between the competent
authority, terminal operator, LNG supplier/bunker infrastructure owner
and gas-fuelled ship.

SIMOPs should only take place if every party involved agrees that:

• the risk assessment indicates a tolerable level of residual risk (for

example, ALARP)
• all the mitigations requested have been provided
• all personnel involved understand their roles and the limitations
imposed by the SIMOPs

The following sections detail an approach to developing procedures

and rules and backing these up with risk assessments. The approach is
summarised in Figures 3.1 and 3.2, which show that there are multiple
steps in some of these stages. Three colours have been used to define
the role of the SIMOP initiator and the regulatory stakeholders within the
figure:

• green signifies activities in which the regulator/other stakeholders

must be involved
• yellow signifies activities where it is preferable for the regulator/other
stakeholders to be involved as increased understanding will lead to
an easier decision-making process
• white signifies activities which can be conducted without outside
input (other than the PIC) but may benefit from wider representation
of stakeholders

Figure 3.1 and 3.2 show eight stages, over two phases, to get a SIMOP
approved and operational. Two phases are shown to differentiate
the planning process – which can be achieved early, say during ship
construction or port planning – from day-to-day operational issues.

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 training & competence
Planning phase (Figure 3.1)
1. Define – defining what the SIMOP is, what assumptions are made,
and the risk criteria it should be judged against
2. Identify Hazards – identification of potential interactions between the

environmental
operation and LNG bunkering, the hazards resulting from this, and
the control measures that exist or could be considered
3. Assess Risk – estimating the risks and reviewing these against
industry/local good practice to decide what barriers/mitigations may
be required to reduce risk to acceptable levels, or deciding to prohibit
the SIMOP
4. Accept – gaining acceptance from the local stakeholders and
regulators that the SIMOP is appropriate and can be used in planned
circumstances
Figure 3.1: SIMOPs Risk Assessment – Planning Phase

technical
PLANNING PHASE
STAGE 1 : DEFINE
Define Risk Levels Define SIMOP

STAGE 2: IDENTIFY HAZARDS Identify SIMOP

Review SIMOP Identify additional
escalation
consequences risks of SIMOP
poetntial

STAGE 3: ASSESS RISKS Risk Asses SIMOP

Yes No No
Is risk low? Is risk medium? risk is high safety
Yes

Yes
Document SIMOP Is risk ALARP? mitigate risk
procedure
No

Is SIMOP Redevelop SIMOP Fundamental

STAGE 4: ACCEPT No acceptable? procedure No issue? Yes
Yes

IMPLEMENTATION PHASE
To From
implementation implementation
contractual

phase phase

© Society for Gas as a Marine Fuel 19

Implementation phase (figure 3.2)
1. Check and Authorise – checking on the day of the bunkering that
everything remains within the planned agreed SIMOP plan (Planning
phase. Accept above)
2. Prepare – putting in place the agreed mitigations and controls on the
SIMOP
3. Implement – performing the SIMOP and monitoring and controlling
the process to ensure that planned and agreed conditions persist
throughout
4. Complete – reviewing the SIMOP to consider whether risks remain
that require the plan to be improved

Figure 3.2: SIMOPs Risk Assessment – Implementation Phase

From planning To planning

PLANNING PHASE phase phase

IMPLEMENTATION PHASE
Can SIMOP SIMOP not
No
happen on allowed on this
STAGE 5: AUTHORISE this occasion? occasion
Yes

Place barriers
STAGE 6: PREPARE and controls

Document and
sign off

STAGE 7: IMPLEMENT Start bunkering

Yes
Check periodically
Do SIMOPs No Attempt to Are SIMOPs
STOP
conditions remain resolve SIMOP – issues
BUNKERING
valid? ? bunkering issue resolved?

Yes No

Continue
bunkering

Has
bunkering been
No completed?

STAGE 8: COMPLETION Yes

Review
END SIMOPs
ok performance Needs revisions

© Society for Gas as a Marine Fuel 20

 training & competence
3.1. STAGE 1: Define

This stage defines the basis of the SIMOPs evaluation and is in two parts:
firstly defining the SIMOP(s) to be reviewed; and, secondly, specifying risk
criteria to be used in assessing the risk tolerability.

environmental
3.1.1. SIMOP
If a SIMOP is fully described, it is more likely that the hazards and risks are
fully examined and mitigated using the minimum number of barriers/
mitigations. This will also help the competent authority (regulator) to
understand and make a decision on the proposed SIMOP.

The minimum amount of information required includes:

• a description of the work activity

• the proximity of the work activity to the safety zone of the bunker

technical
supplier and those on the LNG-fuelled vessel
• the number of personnel involved and whether they are employees
or contractors supervised by employees
• whether any special equipment is required that may present a
hazard (non-intrinsically safe electrics, cutting, welding, grinding,
cranes, and so on)
• whether staff involved in LNG bunkering also need to be involved in
this activity
• whether the ESD system has been developed to cover this activity safety
• whether common control can be achieved – and how
communication is handled
• whether escape routes are affected by this SIMOP activity
• whether the activity is consistent with the port plan for bunkering

3.1.2. Risk criteria

Individuals and organisations can perceive risks very differently so it is
essential for the risk acceptability criteria to be established jointly across
contractual

all the stakeholders at an early stage.

© Society for Gas as a Marine Fuel 21

A minimum of three levels of risk need to be defined:
• high – where action to reduce/mitigate the risk must be implemented
or the SIMOPs prohibited
• medium – where practicable actions to reduce/mitigate the risk
should be implemented
• low – where action to reduce/mitigate the risk is unlikely to be required

The risk criteria need to reflect both the likelihood of occurrence and the
consequences. In addition to injury/fatality, there may be a requirement
to address environmental impact, asset damage, financial loss and
reputational impact. Use, if needed, of these additional criteria should be
agreed with all stakeholders. The criteria should also reflect whether the
assessment is qualitative or quantitative (see Stage 3).

Additional resources to assist in this process are provided in Appendix A.

3.2. STAGE 2: Identify Hazards

SIMOPs include additional operations, procedures and potential hazards

beyond stand-alone LNG bunkering. Like the LNG bunkering operation
itself, each SIMOP must go through a HAZard IDentification (HAZID) process
to determine its potential for interaction with the bunkering process. The
causes of such interaction should be determined and existing control
measures – physical and procedural – examined for fitness-for-purpose.

Additional resources to assist in this process are provided in Appendix A.

SIMOPs have the potential to both create additional initiating events – for
example, dropped cargo – and to escalate the consequences of standard
bunkering events by adding new ignition sources or compromising some
control methods.

The key questions are therefore:

Does the SIMOP either directly, or by nullifying a mitigation strategy,
• increase the likelihood of an existing/identified event occurring?
• magnify the consequences of an existing/identified event?
Does the SIMOP create any new hazards/events not previously identified?

© Society for Gas as a Marine Fuel 22

 training & competence
There are many methods available to identify risks and hazards (see
SGMF’s publication “FP07-1 gas as a marine fuel, safety guidelines,
bunkering”). One such method, the “bow tie” method, is shown in
Appendix A. Risk and hazard assessment is essentially a two-phase
process: firstly, identifying the hazards; and then, secondly, identifying the

environmental
risks. The technique is described in ISO 17776, ISO 18683 and IACS 146.

It is often possible to streamline the hazard and risk assessment process

by conducting stages 2 and 3 simultaneously. In this case, at each
keyword where a hazard is identified, a level of risk (a minimum of high,
medium and low) is assigned to both the likely consequences and to the
probable likelihood of occurrence.

3.3. STAGE 3: Assess Risk

The aim of this stage is to assess the likelihood and consequence of the

technical
additional hazards resulting from the SIMOP (Stage 2). For example,
in quantitative assessments the likelihood of a potential event is often
expressed as a probability (such as 0.5) or as a likelihood (such as 0.5
events per year per km) whereas, in qualitative assessments, descriptions
are commonly used (for example, once in a ship’s lifetime).

If not conducted simultaneously with Stage 2, a likelihood and

consequence assessment needs to be made for each identified hazard.
Three options are possible:

• if a qualitative approach is used, this is a straightforward assigning safety

of high/medium/low or a category number to each risk
• if a semi-quantitative approach is taken, then guide numbers and
descriptions are used for each classification
• if a quantitative approach is used, a number will need to be calculated
for each risk, on both an individual and a societal risk basis

Often, the regulator at the location of the bunkering operation will decide
which method is acceptable. One method, the risk matrix, is described in
contractual

Appendix A.

© Society for Gas as a Marine Fuel 23

The assessed risks then need to be compared to norms (or ALARP) at the
bunker location for acceptability. If intolerable, the risks will need to be
reduced by adding barriers/mitigations to reduce either or both of the
likelihood and/or consequence.

What is ALARP?

As Low As Reasonably Practicable (ALARP) is a concept where an

operator assesses the benefit obtained from risk reduction measures to
determine if the cost of implementation is disproportionate to the benefit
gained. Risks are ALARP when all practicable measures have been
implemented. Good practice is always considered to be practicable.

In the US, ALARP is also known as ALARA (As Low As Reasonably

Achievable). In environmental analysis ALARP is known as BAT (Best
Available Technology) or BACT (Best Available Control Technology).

ALARP is about reducing risk to the lowest reasonably practicable level.

However, in some situations, although risks have been reduced to
ALARP, the risks of the activity may still be considered intolerable to the
authorising bodies. In this scenario, the SIMOP would not be allowed at
the same time as LNG bunkering. Other risk mitigation strategies need
to be considered to demonstrate that the method chosen achieves the
maximum cost-effective impact. This leads to a four-step process:

1. Identify risk barriers/mitigation options, and briefly describe each

option
2. Rank the risk barrier/mitigation options based on effectiveness,
confirm that the measures reduce the risk and by how much, and
rank larger risk reductions higher
3. Evaluate the risk barrier/mitigation options – comparing costs/
resource impacts of each option – and estimate capital and
operating costs of the option and any impacts on resources, such as
staffing levels
4. Select option(s) to reduce risks to ALARP level

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 training & competence
3.4. STAGE 4: Accept

In this context, acceptance is to approve the transfer of LNG between the

supplier/bunkerer and the gas-fuelled ship on the basis that only approved
SIMOPs are taking place and that all risk reduction measures identified at

environmental
Stage 3 have been implemented. It is assumed that the procedures for
the transfer/bunkering process and the LNG-fuelled ship (Figure 2.5) have
already been approved by the appropriate authorities.

Three parties need to be involved in developing the risk assessment. These

are:
• the LNG supplier (and/or bunkerer)
• gas-fuelled ship receiving LNG,
• location – port or terminal – where the bunkering occurs

technical
The LNG supplier (and/or bunkerer) and gas-fuelled ship receiving LNG, whose
equipment and procedures must minimise the potential for leaks through the
correct identification and management of risks associated with SIMOPs.

The port/terminal should review local factors to determine that the

bunkering management plan proposed by the LNG supplier/gas
receiver does not include any risks that the terminal operator would find
unacceptable. The terminal operator will operate within parameters
provided by its owners and the relevant port authority.

If the terminal/port is requesting SIMOPs, then the member of the safety

terminal/port adjudicating the decision should be independent of the line
management of the terminal/port applicant.

All three parties should agree that the SIMOP proposed is acceptable. If a
single party disagrees, the SIMOP should not be allowed.

Any party may wish to include or consult with the port authority/port state
or to request specialist advice (for example, from the fire service) if the
hazard potential is considerable – particularly if further justifications and risk
contractual

assessments/mitigations are required to achieve unanimous agreement.

© Society for Gas as a Marine Fuel 25

Once completed, the risk assessment will be submitted to the local
competent authorities for approval. The competent authorities will vary
from place to place and potentially by the method of bunkering used
(quayside or ship-to-ship).

Approvals should be time limited. The likelihood of equipment, personnel

and regulatory change over the approval period should determine the
renewal criteria and timescale. For example:

• for a regular SIMOP, such as loading cargo or transferring passengers

where the task is easily defined and occurs regularly, a single SIMOP
decision might cover multiple operations or operations over a fixed
timescale; for example, up to the next safety management system audit
• for non-standard planned SIMOPs that occur infrequently a much
shorter timescale, perhaps a single event, should be contemplated,
based on the level of familiarity of the crew with the task to be
performed

3.4.1. Documenting the SIMOP

To facilitate approval by the responsible authorities, each SIMOP will need to
be described and accompanied with a minimum level of documentation.
Decision-makers in different countries are likely to require different formats and
levels of detail. Many LNG suppliers, ship operators and terminal operators
already have systems in place that fulfil this role. These documents should be
included in the operational safety manuals of the LNG suppliers/bunkerers,
ship operators (for example, in their Safety Management System) and terminal
operators and could also be included within the Bunker Management Plan.

Each port, local safety regulator or other appropriate body should publish
guidance on their requirements for demonstrating that a SIMOP should
be allowed.

For ship owners, LNG suppliers/bunkerers, port/terminal operators and/

or competent authorities that do not have these documents, SGMF includes
the following information to help define and assess SIMOPs.

Overview of SIMOP
• an overview of the SIMOP should be provided, describing the SIMOP

© Society for Gas as a Marine Fuel 26

 training & competence
required and linking this to the vessel (and if necessary the port/
terminal) involved

Detailed description of SIMOP

• a full description of the SIMOP should include how the task will be

environmental
performed (for example, a job plan or method statement) and the
resources and training necessary, if any; links should be provided to
hazard identification and risk assessments; and any mitigation measures
and/or additional equipment required should be clearly stated

Organisation and control systems

• a summary should be provided of who is in charge of the SIMOP
(the PIC), who else is involved, how the various parties interact/
communicate, and how they are managed
• details should be provided of how the planning for the SIMOP is
approved (during planning) and authorised (during implementation),

technical
for example, via a permit-to-work system
Contingency plans
• a summary should be provided of how an incident will be handled, if it
occurs, and, where necessary, evidence of consultations with emergency
response organisation regarding how to implement the plans

3.5. STAGE 5: Check and Authorise

During the pre-bunkering meeting, the POAC/PIC and PICs/representatives

of the LNG supplier/gas receiver should review the authority for the SIMOP safety
and any restrictions/caveats included. These individuals should then
agree, unanimously, that the current conditions do not differ from the
accepted approval (see Stage 4) in any significant way and whether the
SIMOP can go ahead.

The terminal operator must have the right to attend this meeting and take
part in the decision-making process. However, if the terminal operator
does not attend, this should not prevent the bunkering and SIMOP taking
place, provided the LNG supplier and gas receiving ship agree that existing
contractual

approvals have been met.

© Society for Gas as a Marine Fuel 27

The stakeholders should document their decision by signing a form of
authority to proceed.

The method of communication between the POAC and the various PICs
should be established at this time, and any physical and human control
limitations discussed.

3.6. STAGE 6: Prepare

Before the bunkering/SIMOP goes ahead, all the checks, isolations and
other precautions required by the authority (based on the original method
statement) must be put in place, and signed off, or otherwise confirmed
(for example, using a checklist).

The PIC should review the checklist, and each of the precautions, before
authorising the bunkering/SIMOP operation(s).

3.7. STAGE 7: Implement

Once the LNG bunkering has begun, the POAC/PIC must continually ensure
that the SIMOP is not detrimentally affecting the safety of the bunkering
process. If anyone has any concerns about the SIMOP, they should stop the
bunkering process until the SIMOP has stopped, the adverse conditions or
behaviours have ended, or the SIMOP has been completed.

Loss of communication between the POAC responsible for the SIMOP and
the PIC responsible for LNG bunkering would be one reason to stop the
LNG bunkering, as the PIC no longer has control.

3.8. STAGE 8: Complete

On completion of the LNG bunkering process, the POAC/PIC should

review each SIMOP and determine whether the limit of the authority,
the preparations taken, and the behaviour of those involved were
satisfactory. If not, the POAC/PIC should contact the appropriate stake-
holders/competent authority, along with those involved, to ensure that
outstanding issues are resolved before any further bunkering/SIMOP
operation(s) go ahead.

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 training & competence
4. Planning for SIMOPs
Competent authorities will wish to be involved in, or review, the plans for
a bunkering facility, or an area where bunkering will take place, to ensure
the safety of individuals in the local area and that commercial activity
elsewhere in the port is not interrupted.

environmental
The planning process may identify that the location needs additional
equipment, staffing and/or training. It may also identify activities that
– for example, as a result of limited space at a terminal/port – should
not be allowed during bunkering or require extra procedures for traffic/
operational controls and restrictions.

Similarly, the capacity for SIMOPs may also be vessel specific. How
the vessel is designed and constructed may limit the ability to perform
SIMOPs. The ship’s owner should define what he/she wants to happen
and discuss this with the ship designer/constructor to ensure suitable
design features are incorporated. Modifying the vessel design will not

technical
necessarily ensure that SIMOPs are permissible, but should improve the
chances of a positive decision by the port/regulators.

Advance planning in terms of port/terminal layout and gas-fuelled ship

manifold location is highly recommended to minimise limitations on LNG
bunkering and SIMOPs.

4.1. Considerations for Port Planning and Design

Port design is primarily about space. New ports often have lots of space
available and so can be laid out to minimise interactions between port safety
services and ships. Older ports where wharves are being redeveloped
usually lack this luxury and may be constrained in what operations can
be allowed.

Spatial planning for LNG bunkering is dominated by the distance that

gas from LNG leaks remains flammable as it disperses. SIMOPs are
unlikely to affect the potential dispersion distances but may alter the
likelihood or the potential consequences of an LNG leak. For example, a
dropped object from a SIMOP may cause damage that leads to a leak,
contractual

or there may be additional people present that could be exposed to a

potential hazard.

© Society for Gas as a Marine Fuel 29

SIMOPs assessments therefore need to consider:

• how a SIMOP might fail to go as planned and how this may affect
the bunkering system in a way that has the potential to cause an
LNG leak; the more operations that are taking place, the greater the
probability of a failure
• many SIMOPs operations expose more people (crew/dock workers/
passengers) to any hazards that might arise during an incident;
the potential for ignition of a gas cloud may also increase; SIMOPs
therefore may cause an escalation of a hazardous event whether or
not it has been caused by the SIMOPs
Port design is therefore primarily about whether bunkering should be
allowed at a particular location and whether there should be limitations to
this consent as a result of certain specific, local, circumstances. Examples
include weather conditions, bunkering type, and other port activities. This
is covered by SGMF’s publication FP02-1 “Recommendations of Controlled
Zones during LNG Bunkering”.

If the use of the port permanently changes, either through relocation of

facilities or the construction of new facilities/berths (and external industrial/
infrastructure facilities), the planning process needs to repeated. Such
changes may impact the viability of bunkering, with or without SIMOPs.

4.2. Considerations for Gas-Fuelled Ship Design

It is important to consider regular SIMOPs at the ship design stage.

Location of the bunkering manifold can then be optimised to be away
from cargo operations and passenger movements, or to include
ventilation systems to prevent flammable gases entering the ship or the
build-up of flammable atmospheres.

For example, placing a bunker manifold midships has the greatest

chance of affecting passenger and cargo operations as material
handling/crane operations are unlikely to be allowed above the LNG
bunkering supply and transfer equipment. Placing the manifold aft could
limit the impact of SIMOPs for a Ro-Ro ferry, as passengers/vehicles could

© Society for Gas as a Marine Fuel 30

 training & competence
load via the bow while the vessel is bunkered at the stern. Conversely, on
an offshore support vessel (OSV) the reverse may be preferable as cargo
is loaded on the rear of the vessel.

The position of the vent mast of the smaller vessel (bunker vessel or gas-

environmental
fuelled ship) may also be an issue. Any gas vented during an emergency
must be able to disperse freely and not result in flammable gas
dispersing across the larger vessel. Siting the vent mast to IGF Code rules
for normal operation – for example, midships – may not be appropriate
for bunkering operations where it needs to be on one side (away from the
bunkering operation). Two vent masts would be possible but then one
would need to be isolated/disabled during bunkering.

The location of air intakes also needs to be considered (for example, IGF
Code, section 13.3.5). These need to be sited so that any LNG/gas leaks
cannot be immediately drawn into the ship, given the size and shape of

technical
the safety zone.

Working beneath lifeboats and other overhanging structures is far from

ideal. It means that there is a potential hazard overhead and that the
amount of air that can be entrained to disperse a gas leak is potentially
limited.

Lifting a containerised/cassette LNG tank will require the cessation of any

other activity (including SIMOPs) within its lifting or transit route. However,
this cessation of operations should be relatively short.
safety
contractual

© Society for Gas as a Marine Fuel 31

5. References
Documents referenced in this publication:

• SGMF, FP02-01, “Gas as a Marine Fuel, Safety Guidelines –

Recommendation of Controlled Zoned during LNG Bunkering”, v1.0,
May 2018
• SGMF, FP07-01, “Gas as a Marine Fuel Safety Guidelines – Bunkering”,
v2.0, March 2017
• International Maritime Organization, “The International Code of Safety
for Ships using Gases or other Low-flashpoint Fuels (IGF Code)”
• IMCA M 203, “Guidance on Simultaneous Operations”
• International Maritime Organization, “International Safety
Management (ISM) Code”
• IACS 146, “Risk assessment as required by the IGF Code”, 2016
• ISO 17776, “Petroleum and natural gas industries – Offshore
production installations – Major accident hazard management
during the design of new installations”, 2016
• ISO 18683 – Guidelines for systems and installations for supply of
LNG as fuel for ships, 2015

5.1. Supplementary Reading:

The following documents discuss SIMOPs for gas-fuelled ships

• American Petroleum Institute/DNV GL, “Considerations for

Proponents when Conducting QRA for LNG Bunkering SIMOPS” rev
3 of report PP142228-2, dated June 2016 (http://www.api.org/~/
media/Files/Policy/LNG-Exports/API-Paper-QRA-for-LNG-Bunkering-
SIMOPS.pdf)
• Conducting Simultaneous Operations (SIMOPS) While Bunkering LNG-
Fueled Vessels, Chemical Tanker Advisory Committee (C-TAC)
• USCG Policy Letter – “CG-OES Policy Letter No. 01-15 – Liquefied
Natural Gas Fuel Transfer Operation and Training of Personnel on
Vessels Using Natural Gas as Fuel”

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 training & competence
• USCG Work Instruction – “Quantitative Risk Assessment Review
Checklist for SIMOPs”, June 2017
• USCG Field Notice – “Evaluation and Authorization of Simultaneous
Operations (SIMOPS) during Liquefied Natural Gas (LNG) Bunkering”,
February 2017

environmental
• USCG Field Notice – “Recommended process for analyzing risk of
simultaneous operations (SIMOPS) during Liquefied Natural Gas (LNG)
Bunkering”, August 2017
• BV Guidance Note “NI 618 DT R00 E”
• ABS, “LNG Bunkering: Addressing SIMOPS”, 2017

technical
safety
contractual

© Society for Gas as a Marine Fuel 33

Appendix A: RISK Assessment
& Ranking Guidance
A1. Additional HAZID Guidewords

SGMF’s Bunkering guidelines (FP07-1) provides guidance on how to

conduct a HAZID. This guidance is not reproduced here. This section
suggests some additional features that relate to SIMOPs and summarises
one HAZID method that has often been used to evaluate SIMOPs.

Additional guidewords that are relevant when considering SIMOPs are:

Table A1: Additional HAZID Guidewords for SIMOPs

Guideword Comments

During SIMOPs communication be-

tween the various PICs is key to safety. A
communication failure therefore needs to
Communication failure
be considered, for example, no shared
language, battery failure on radio, back-
ground noise, and so on

Bunkering safety zones may overlap with

SIMOPs risk areas, for example, areas of
Safety zone overlaps
the deck where cargo will be loaded and
where any cargo may be dropped

Transferring material and cargo can be

noisy, create sparks and/or static electricity,
Material/cargo handling
and allow the escape of dust or hazardous
materials

Crew, officials, stevedores and passengers

and their vehicles are potentially ignition
People movement
sources and potentially present in large
numbers

Maintenance may involve hot work, testing

Planned and unplanned maintenance
of electrical and control systems, and
activities
distraction of crew members

Increased vehicle and vessel movements

Collision and potential for collisions with the re-fuel-
ling ship or its LNG supply

© Society for Gas as a Marine Fuel 34

 training & competence
Guideword Comments

Potential damage to the LNG transfer sys-

Dropped object tem and/or supply from a dropped object
(for example, cargo)

environmental
Loading of cargo and vehicles and mainte-
Vessel stability
nance activities may affect vessel stability

Normal access and escape routes may be

Accessibility
compromised by SIMOPs activities

A2. Risk Identification and Management Methods

A variety of methods are available to identify and examine the impact

of various scenarios on safety. SGMF’s Bunkering guidelines (FP07-1)
provides guidance on these.

technical
The success of risk identification and assessment is primarily about
having present at the risk assessment the right individuals, who between
them have appropriate experience of the operations and the use of LNG.

It is also essential that the methodology and results of the risk assessment
process are recorded and that any actions on individuals and/or
organisations can be formally closed out.

This section describes two methods which are regularly applied to

SIMOPs. SGMF believes they are helpful but recognises that they are only safety
options and that alternatives which are equally effective are available.

A2.1. Bow tie Method

A bow tie diagram is a means of visualising how things might go
wrong, and the causes and consequences (Figure A1). The mitigations/
barriers/control measures employed for each major hazard can then
be added, all within a single diagram. Though not essential, it can aid
the development of an understanding of how the threats to the LNG
bunkering process are managed. It can be applied both to general
contractual

management of the safety of the bunkering and in managing SIMOPs.

© Society for Gas as a Marine Fuel 35

With the hazard (a single point) in the centre, and multiple causes/threats
to the left and consequences to the right, the figure resembles a bow tie.

Figure A1: Bow tie diagram example

Hazard

Barrier Barrier Consequence

Threat Barrier Barrier

Top
event Barrier Consequence

Threat Barrier

Example
Figures A2 and A3 show separately (and non-exhaustively) the two sides
of a bow tie diagram for a leak from the LNG transfer system (top event).
The events are divided into two categories: LNG bunkering alone (light
blue); and bunkering with SIMOPs (dark blue). Barriers to prevent each
threat occurring have been added to reduce the potential for the top
event, a LNG transfer leak, occurring. Figure A3 shows the right-hand
side of the same bow tie diagram, based on the potential consequences.
Barriers to prevent each consequence occurring have been added to
reduce the potential impact from the top event. There is no distinction
between a SIMOPs event and a LNG bunkering event – the consequences
are the same.

© Society for Gas as a Marine Fuel 36

 training & competence
Figure A2: Threats and Barriers Example
SIMOPs related
Training of Hoses stored Physical
Hose run operators correctly on
Assist driver
Barriers eg
over and drivers racks
with parking
ARMCO

Modified No lifting over Interlocks on cranes/

Dropped LNG

environmental
cargo loading LNG transfer gangways to limit
object plan system movement

No testing of
Ship Ballasting or Break away
stabiliser systems
movement loading plan coupling
during bunkering

LNG
Marine Mooring
Ship break
exclusion plan and
Break away Transfer
away zone monitoring
coupling Leak

Maintenance & Wear & tear

Hose in poor
replacement checks before
condition plan assembly

Operator
Hose poorly
training & Checklists
assembled supervision LNG bunkering alone

technical
Figure A3: Consequences and Barriers Example

Water
Drip tray in Fire & gas Cold
curtain ESD system
LNG position
operating
detection embrittlement

Access Crew/visitor
restrictions in training & PPE Injury/Fatality
safety zone supervision

LNG
Transfer Fire & gas Greenhouse gas
Leak ESD system
detection release safety

Safety zone No hot work

Fire & gas Emergency Fire fighting Fire or
ignition source during ESD system
detection procedures equipment explosion
restrictions bunkering

A2.2. Risk Matrix Method

A Risk Matrix, shown in Figure A4, is one method that is often used to
report a risk assessment. It consists of two axes, one for likelihood and
one for consequence. Each SIMOP is assigned a value for each and
contractual

located in the appropriate box. Each box is colour-coded, with the colours

© Society for Gas as a Marine Fuel 37

chosen to qualitatively rank the risks of each scenario as acceptable,
unacceptable or in-between (and potentially subject to further analysis).

Like traffic lights for road users, the colours red (unacceptable), yellow/
orange (warning = think, do further analysis to demonstrate ALARP) and
light/dark green (acceptable = highly likely to be ALARP) are often used.
The regulator at the location of the bunkering operation will frequently be
involved in deciding these regions.

Risks in each area should be managed as follows:

• green = generally acceptable (tolerable) and should be managed for

continuous improvement
• yellow = need further evaluation to demonstrate that they are ALARP,
that is, further risk reduction is not cost-effective
• orange and red = risks are unacceptable and must be reduced

Risks, both likelihood of occurrence and level of consequence, can be

reduced during the HAZID process through:

• eliminating or reducing hazards by doing the SIMOP differently with,

for example, fewer people or less or more distant equipment
• reducing risk levels by improving existing operations, and/or
• identifying further controls and barriers

Figure A4: Example Risk Matrix

Likelihood
Very low Low Medium High Very high
Consequence Very low 5 6
Low
Medium 1, 3 4
High
Very high 2

© Society for Gas as a Marine Fuel 38

 training & competence
The numbers in the risk matrix such as Figure A4 refer to a specific
scenario. For example, 1 could refer to the assessment of SIMOP 1, loading
cargo while bunkering.

From the example, scenarios 1, 3 and 5 are broadly acceptable, meaning

environmental
that most regulators would accept these risks. Scenario 4 is unacceptable
and more work would be required for this SIMOP to be accepted.
Scenarios 2 and 6 may be acceptable or may need more work. A strong
justification would be required for the regulator to accept these risks/
consequences. Scenario 2 may be harder to accept than Scenario 6 as the
consequences of scenario 2 are very high.

The severities used for both likelihood and consequence will be based on
the appetite for risk, the financial capability of the vessel/port owner, and
the wishes of the local regulatory body.

technical
Likelihood would be assessed against criteria similar to those set out in
Table A2. Severity of the consequences can be assessed against a variety of
impacts as set out in Table A3 (or similar). Often multiple categories are used
for assessing consequence with the maximum value defining the measures
required for mitigation. A financial column is also usually added to Table A3.

As well as considering risks in isolation, the cumulative risk of all the

operations should be considered.

Table A2: Likelihood Assessment Example

safety
Level Name Definition

1 Very rare

To be defined by the participants with advice from experienced

2 Rare individuals

3 Uncommon To be agreed by all stakeholders who should be present

4 Common Guidance is provided by international standards, for example,

IACS 146 or ISO 31010 or national bodies such as UK HSE
contractual

5 Frequent

© Society for Gas as a Marine Fuel 39

 Table A3: Consequence Assessment Examples

Level Safety Environmental Community/Public

1 No injury or health effect No impact to the environment No impact to the community

Infrequent slight interference with

First aid case
reasonable comforts and enjoyments of
Illnesses that result in noticeable Small spill/slight environmental damage life, day-to-day activities or enjoyment
2 discomfort, minor irritation or contained within the premises that of land
transient effects that are reversible quickly dissipates
Local public awareness but no discerni-
after exposure stops
ble concern

Medical treatment case

Minor environmental damage, but no Limited short term nuisance – limited
Lost workday case or restricted work lasting effect. For example: effects on livelihood and/or social or
case, where either has a duration of cultural assets, community health

© Society for Gas as a Marine Fuel

3 up to and including five days • Small, on-site environment
damaging spill, no off site impacts No observable adverse effect on com-
Illnesses with reversible health • Groundwater contamination on site munity security
effects, such as food poisoning and only Local public concern
dermatitis

Lost workday case or restricted work Limited environmental damage that

case, where either has a duration will persist or require cleaning up. For Persistent nuisance
exceeding 5 days example:
Effects on livelihood and/or social and
Illnesses with irreversible health ef- • Environment damaging spill that cultural assets, community health
4 fects, such as sensitisation, noise-in- requires removal and disposal of
duced hearing loss, chronic back Limited observable effects on community
over 100 m3 of impacted soil/sand
disorders or repetitive strain injury security
• Off-site habitat effects or damage,
Mental illness due to stress, with such as fish kill or damaged Local or regional public concern
irreversible health effects vegetation

40
 Table A3 continued: Consequence Assessment Examples

Level Safety Environmental Community/Public

Severe environmental damage that will Persistent effects on livelihood and/or

Up to three fatalities require extensive measures to restore social and cultural assets, community
beneficial uses of the environment. For health
Illnesses with irreversible health example:
effects, such as corrosive burns, Effects on community security and/or
5 • Off-site contamination of surface or
asbestosis and silicosis, cancer human rights infringements that are
groundwater over an extensive area serious and/or at a community level
Mental illness due to stress, with • Off-site habitat and/or ecology
irreversible health effects effects or damage for greater than Impact on local and national stakehold-
one year ers relations

Persistent severe environmental dam- Persistent, severe impact on livelihood,

age that will lead to loss of natural re- social and cultural assets, community

© Society for Gas as a Marine Fuel

More than three fatalities sources over a wide area. For example: security, community health, and/ or
Illnesses with irreversible health • Spill resulting in pollution of a large human rights infringements. Impact
effects, such as multiple asbestosis tract of wetlands, ocean, river or may affect a large geographic area or
6 population
cases traced to a single exposure estuary
situation • International public concern International public concern
Cancer in a large exposed population Persistent off-site habitat and/or ecology High level of concern and action(s) by
effects or damage with proven long- governments and/or by international
term effect NGOs

41
contractual safety technical environmental training & competence
Appendix B: SIMOP Considerations
This appendix provides high-level examples of typical SIMOPs. Individual
ships and ports may require different or additional information to be
documented.

B1. Container Ship

Container vessels make up about 20% of the world’s fleet. They can
range from short sea, small, feeder vessels to the ultra-large vessels that
dominate world trade.

Figure B1: Container Ship © Maersk

For commercial reasons, container ship port stays are short, and
bunkering and cargo operations need to happen simultaneously.
Container ships stack their cargo in containers one on top of each other.
During cargo (container) loading and unloading there is the potential
to drop a container. When positioned containers are locked together in
stacks. It is therefore possible that a dropped container may dislodge a
complete stack of containers. The impacts of a dropped container/stack
of containers was demonstrated in Figures 2.2 and 2.3 of the main report.

© Society for Gas as a Marine Fuel 42

 training & competence
Mitigation can only really be achieved by not lifting containers into stacks
near the bunkering station or above the bunkering vessel/road tanker.
Impacts can be limited by how and when containers are loaded through
the cargo plan. These complex plans need to consider a variety of factors
for the optimal layout of containers and bunkering operations and may

environmental
need to be planned a few port visits ahead of the actual bunkering.

Some containers are refrigerated and have built-in electric motors to drive
refrigeration packages. These motors may not be intrinsically safe and
their operation may need to be prohibited during bunkering, if they are
positioned close to the LNG transfer system, or alternatively have an ESD
system to shut them down if a leak occurs.

Container port cranes and stacker/tractor-trailer units are unlikely to have

intrinsically safe operating procedures. These should be excluded from
the safety zone or have a system to shut them down quickly and safely

technical
should a leak occur.

Other SIMOPs are similar to most other ship types:

• dropped objects are possible during stores loading/waste removal;

these are likely to be smaller/lighter than containers but they present
the same issues and have the same mitigations; delivery vehicles
should be located outside the safety zone
• bunkering of diesel may also be taking place with any ignited diesel
spill potentially impacting the integrity of the LNG transfer system;
and, vice-versa, the cold from a LNG spill damaging the diesel hose safety
• freeboard changes during container loading are small but frequent;
they are unlikely to have a major impact and, again, can be
controlled by the cargo plan
• some container vessels use rolling hatch covers, with the potential for
sparks and heat from electric motors and/or metal surfaces grinding
against each other
• crew movements, visitors (personnel, inspectors and ship owners) and
contractual

the vehicles involved should be restricted in the safety zone, as they

present potential ignition sources and/or sources of (collision) damage

© Society for Gas as a Marine Fuel 43

 • maintenance and inspection may trigger instrument or control
system actions which compromise the bunkering operation;
additional tools/equipment may be in use, such as welding and
grinding equipment which provides an ignition source; confined
hull spaces may be partially open to the atmosphere to allow
maintenance work to take place allowing any released LNG/gas to
enter, potentially resulting in a confined-space explosion; additional
crew members are expected to be present for the maintenance,
inspection or to participate in inspections/drills, potentially distracting
the bunkering PIC and/or limiting immediate emergency response

B2. Bunker Vessel

The whole purpose of a bunker vessel is to supply LNG as fuel to other

gas-fuelled vessels. The vessel is designed and crewed to this end. The
limited crew complement, the number of those crew members who are
assigned to the bunkering operation, and the requirement to fulfil rest
hours requirements, are considered as obstacles to conducting any
SIMOPs. LNG transfer happens while water side of the fuelling vessel
which effectively prevents many SIMOP activities such as loading and
unloading stores and waste products.

Figure B2: Bunker vessel © Engie

The bunker vessel – as the highest inventory of LNG – should be

able to disconnect and move away from a gas-fuelled ship at
any moment should an incident occur. This does not allow for
maintenance and inspection tasks on the components related to
navigation, propulsion, safety, cargo, automation, communication,
ballast and other essential items.

© Society for Gas as a Marine Fuel 44

 training & competence
SIMOPs are therefore only possible on routine tasks such as hull
maintenance, for example painting or ballast tank cleaning. Should these
activities be necessary the bunker vessel would need an agreed SIMOPs
plan with the competent authorities.

environmental
(Shore based LNG road tankers have similar restrictions as only the driver
is generally present and he is required to monitor and control the LNG
transfer process).

B3. Cruise Ship

Cruise ships transport large numbers of passengers and crew over extended
distances, visiting a variety of destinations along a set route. Cruise ships
range from 200 passengers to over 5,000, with crews of up to 2,000.

Figure B3: Cruise Liner © Carnival Corporation

technical
safety

Passenger movement is the key SIMOP for a cruise liner. Passengers

and crew are normally only exposed to the risk of LNG when outdoors,
which primarily means during embarking and disembarking. Passengers
spend most of their time onboard either inside the vessel or enjoying
amenities a significant distance from the bunkering location. However,
the large numbers of people involved, and their vulnerability should an
incident occur, mean that passenger embarkation/disembarkation should
contractual

take place only outside the safety zone.

© Society for Gas as a Marine Fuel 45

Passengers and crew are required to take part in safety drills which
involve the whole crew congregating outdoors at muster stations
without any personal protective equipment relevant to LNG scenarios.
Drills should only be conducted outside the safety zone. Additional risk
assessment is needed to demonstrate that these events are acceptable
during LNG bunkering.

Terminal buildings may also be present, which may restrict dispersion of any
LNG leak and heighten the chance of ignition (and, in very confined areas, an
explosion). Terminals are also likely to attract more vehicle movements.

Passengers are accompanied by large volumes of luggage, consume

large quantities of food and drink, and produce significant quantities of
waste that need to be collected and transferred on and off the cruise liner
by crane, pipe and other means to vehicles or small ships/barges. These
activities present the following risks:

• objects may be dropped during stores loading/waste removal; so

delivery vehicles should be located outside the safety zone
• increased vehicle movements and additional people involved with
delivery of luggage, stores and waste removal
• potential collisions between vehicles and road tanker-based LNG
bunkering systems or barges with bunker vessel-based LNG
bunkering systems

If conducted alongside LNG bunkering, these activities need to occur

outside the safety zone and avoid passing through it. The ability for the
PIC to monitor all the additional vehicle/people movements close to the
safety zone may require limitations on the total number of movements in
any given period.

Other SIMOPs are similar to most other ship types (see container vessel
section for a list).

© Society for Gas as a Marine Fuel 46

 training & competence
B4. Offshore Support Vessels

Offshore Support Vessels (OSVs) are used in the oil and gas industry for
a wide variety of operations. They can be categorised according to the
operations they perform: seismic survey ships; platform supply vessels

environmental
(PSVs); anchor handling tugs; anchor handling tug and supply (AHTS)
vessels; offshore construction vessels (OCVs); ROV support vessels; dive
support vessels; stand-by vessels; inspection, maintenance and repair
(IMR) vessels; and a variety of combinations of these.

Figure B4: Offshore Support Vessel © Woodside

technical
Generally these vessels are in port and alongside when the key activities
that can lead to a SIMOP could occur. These activities can be categorised safety
as follows:

• loading/back loading the rear decks with containerised and non-

containerised cargo
• loading of bulk liquid and dry products, such as marine diesel oil,
water, mud, cement and barites
• planned and unplanned maintenance
• loading vessel stores and spare parts
contractual

• crew movements, visitors and vehicles

© Society for Gas as a Marine Fuel 47

Before commencing to load LNG, the cargo on the back deck must be
taken into consideration as there may be dangerous goods, refrigerated
containers which are not intrinsically safe or other risks in the open,
nearby the bunkering manifold and in the safety zones that have been
set up. Deck cargo may be required to be unloaded prior to bunkering to
remove any risks from the deck cargo that may exist.

Mitigation of risk for these types of activities generally involves:

• refraining from loading/unloading the vessels during LNG bunkering

as the vessels are generally small, it can be hard to not encroach into
the safety zones
• manning levels on board are generally too small to cope with any
SIMOPs during LNG bunkering.
SIMOPs may still be permissible, though risks should be assessed to
ensure they are acceptable before activities begin.

B5. Tankers

Tankers carry a wide variety of products, ranging from food stuffs, through
crude oils, to highly refined products, liquefied gases and hazardous
chemicals. In size they can range from short sea, small, feeder vessels to
ultra-large vessels.

Tankers make up slightly more than 20% of the world’s fleet.

© Society for Gas as a Marine Fuel 48

 training & competence
Figure B5: Product tanker © Maersk

environmental
Most tankers move flammable and/or hazardous products. So they

technical
have management systems and equipment and design features that are
intended to minimise the possibility of ignition of their flammable cargoes.
If the cargo is a low flashpoint cargo (below 30°C) or liquefied gas, this
is particularly true, but most hydrocarbon and petrochemical vessels
have some degree of flammable or toxic vapours (such as vinyl chloride
monomer or ammonia) present.

The jetty where these products are loaded and offloaded should be
designed to a similar standard. All cargoes will be pumped on and off
the vessel via marine arms or flexible hoses. The pumping should be
by intrinsically safe equipment and any static electricity build-up should safety
be managed. Gas compressors, designed and operated to similar
standards, may be involved in transferring vapours in the opposite
direction to the liquid transfer.

Should a marine loading arm or a (typically rubber) hose fail or leak

because of movements exceeding the operating envelope, a flammable
product would be released close to the bunkering transfer system.

Other SIMOPs are similar to most other ship types (see the container
contractual

vessel section for a list).

© Society for Gas as a Marine Fuel 49

B6. Ro-Pax Ferry

Passenger/vehicle ferries work within a wide variety of operational

scenarios and, in general, are expected to maintain exceptionally
high uptime availability as they provide essential services to front-line
transportation systems. Although the sector is represented by a wide
spectrum of operational scenarios, one common factor is that the time
allotted for provisioning the vessels (including the loading of consumables
such as fuel) is designed to be kept to a minimum so as to maximise the
time available for the loading/unloading of passengers and vehicles. In
many cases, so as to support quick run-around times in port, the two
activities are designed to occur simultaneously (SIMOPs).

Figure B6: Ro-Pax Ferry © BC Ferries

While provisioning and re-fuelling of operational Ro-Pax ferries is likely

the highest profile SIMOPs, many other activities can occur as well. For
example, ferry operators, where their operational schedules permit,
may perform a number of other essential activities during brief non-
operational periods (of less than six hours). These could include ongoing
maintenance, inspections and re-certification of ship systems, as well as
running safety drills and other activities requiring participation of the crew.

© Society for Gas as a Marine Fuel 50

 training & competence
Ro-Pax operators need to consider at early stages of a new vessel
design (or refit to LNG fuel) how LNG bunkering will be integrated into the
operational requirements of the ferry system. Referring to earlier aspects
of this guidance document, where and when bunkering will occur are
paramount.

environmental
If bunkering must occur during passenger/vehicle loading/unloading
activities, consideration must be given to the fact that passengers and
vehicles can each represent a potential ignition source. This should be
incorporated into planning when developing the controlled zones that are
to be applied during bunkering.

Shipboard maintenance and operational safety drills must be planned to

avoid negatively affecting bunkering operations. This should include any
drill, test or other procedure that may impact the integrity of any safety
or auxiliary engineering system that supports safe and uninterrupted

technical
bunkering of LNG. Equally, any of the former activities must not distract
the team assigned to the LNG bunkering operation. Their attention needs
to be fully focused on the bunkering activities.

B7. Bulk Carriers

Bulk carriers carry a wide variety of solid products, from powders

to large chunks of material. Some of these cargoes have hazards
associated with them – for example, coal which may generate a
flammable vapour during handling. A range of vessels from small to
large are in use in short sea and international trades. Bulk carriers safety
make up about 15% of the world’s fleet.
contractual

© Society for Gas as a Marine Fuel 51

 Figure B7: Bulk Carrier © Arista Shipping

Cargo loading is the primary area of interest for SIMOPs:

• vessels that use rolling hatch covers have the potential to generate
sparks and heat from electric motors and/or metal surfaces grinding
against each other
• cranes and stacker/reclaimer units are unlikely to have intrinsically
safe operating procedures; these should be excluded from the safety
zone or have a system that shuts them down quickly and safely
should a leak occur
• some cargoes, particularly those loaded using conveyer belts, may
generate high levels of static electricity which could ignite a gas leak
• dropping large items of cargo into the hull or using mechanical
equipment to redistribute cargo may also cause sparks through the
striking of metal within the cargo hold

Other SIMOPs are similar to most other ship types (see the container
vessel section for a list).

© Society for Gas as a Marine Fuel 52

 training & competence
B8. General Cargo

General cargo vessels make up about 30% of the fleet. General cargo
vessels carry any form of packaged item that has not been containerised
– for example, pallets of drums of chemicals, sacks of food, crates of

environmental
furniture or machinery and motor vehicles. Vessels often have their own
cranes for loading and offloading cargo.

The diversity of the general cargo trades makes identifying generic

SIMOPs difficult. SIMOPs may include:

• dropped objects from cargo loading/unloading but also from stores

loading/waste removal; delivery vehicles should be located outside
the safety zone
• bunkering of diesel may also be taking place, with any ignited diesel
spill potentially impacting the integrity of the LNG transfer system;

technical
conversely, the cold from a LNG spill could damage the diesel hose
• freeboard changes during cargo loading are small but frequent;
these are unlikely to have a major impact and can be controlled by
the cargo plan
• vessels that use rolling hatch covers have the potential to generate
sparks and heat from electric motors and/or metal surfaces grinding
against each other
• crew movements, visitors (personnel, inspectors and ship owners) and
the vehicles involved should be restricted in the safety zone as they
present potential ignition sources and/or sources of (collision) damage safety
• maintenance and inspection may trigger instrument or control
system actions which compromise the bunkering operation;
additional tools/equipment may be in use, for example, welding
and grinding equipment which provides an ignition source; confined
spaces may be partially open/open to allow maintenance work
to take place and any released LNG/gas may enter, potentially
resulting in a confined-space explosion; additional crew members
are expected to be present for maintenance and inspection, or to
contractual

participate in inspections/drills, potentially distracting the bunkering

PIC and/or limiting immediate emergency response

© Society for Gas as a Marine Fuel 53

B9. Terminal Operator

Port-managed activities that can be the “plus one” operation in a SIMOPs

activity during bunkering of LNG are relatively rare. The main reason is
that the area where the combined “operations may impact or increase the
impact on personnel safety, ship integrity and/or the environment” around
the LNG bunkering is relatively small and the activities by the port will usually
stay relatively far away. In general, activities by the port – for example,
to maintain the mooring facilities or infrastructure on the quay/jetty – are
scheduled to take place when vessels are not occupying the berth.

However, in the rare case that a vessel is at its berth, and LNG bunkering
is to be performed, and activities by the port are taking place close by,
appropriate measures should be put in place.

Activities by the port (or under control of the port) could be, for instance:
• pavement removal, excavation work and welding on the quay side
to repair damaged bollards/ladders/fenders or other quayside
infrastructure (land side)
• hydrographic surveying of the quay area to determine whether the
required depth at the quay is still present (waterside)
• trailing suction hopper dredging activities to maintain the required
depth at the quay and other passing vessels (waterside)

The most appropriate measure would be to cease these activities

temporarily, or to ensure that they avoid encroaching on the “impacted
area” of the LNG bunkering activity. This requires communication between
the LNG bunker vessel, the receiving vessel and the PIC of the port-
managed activities. If stopping the activity is not possible, and continuing
the port-activity close to the LNG bunkering activity cannot be avoided,
it should be agreed between the PICs in advance of the LNG bunkering
what activity can and what cannot proceed and what additional
measures should be taken.

The activities by the port will usually not be the cause of LNG transfer
leakage, or have other direct impact on the LNG transfer. The one

© Society for Gas as a Marine Fuel 54

 training & competence
major exception to this would be control of passing vessels (speed
and distance).

Vessel movement within a terminal or port will be the responsibility of

local pilots or the vessel traffic system management. The port/terminal

environmental
rules should control vessel speed and passing distances to minimise
the risk of collision or mooring line failure. In addition, terminals, or
their subcontractors such as towage companies, will be responsible for
mooring vessels and handling incidents such as mooring equipment
failure/ship break away. If port rules are inappropriate, or poorly
enforced, the passing vessel may create waves of sufficient size to break
the mooring lines and then potentially the transfer system connection
between a bunker vessel and the fuelling ship, resulting in a spill of LNG
and/or gas.

Regulatory processes may require additional visitors to ships and

technical
quaysides, such as independent surveyors, vetting inspectors, port state
control, customs, and so on. These individuals may lack the necessary
training and PPE to be able to operate independently and so will need to
be supervised by the LNG-fuelled vessel. They should not be allowed to
enter the safety zone during bunkering.

safety
contractual

© Society for Gas as a Marine Fuel 55

 ISBN: 978-0-9933164-7-0

© SGMF — www.sgmf.info — [email protected]

£80