We have recently experienced an increase in liquid cargo contamination claims, especially
where the ‘First Foot Sample’ was found to be off-specification upon analysis.
Many of these claims occur when a cargo of Jet A1 Fuel, a kerosene-type jet fuel, is loaded
into tanks that had previously carried other commodities such as Un-Leaded Gasoline
(ULG 95). As a result, the cargo is found to be off-spec at their freezing point, flash point
Generally, when a first foot sample is found to be off-spec, questions are raised regarding
the effectiveness of tank cleaning and pipeline flushing techniques. A detailed analysis of
such claims has revealed that these are a contributing factor in the majority of claims.
In some cases, cargo tanks are issued with a Clean Tank certificate by attending surveyors,
yet the first foot sample taken shows that the cargo is contaminated. In such cases,
although the ship’s tanks are cleaned and well prepared, the pipelines still have residues of
the previous cargoes which lead to contamination.
We recommend the following to our Members:
• Review any existing on board procedures and ensure proper tank cleaning
procedures are in place, including those that take into account aspects such as
ensuring the vessel has adequate trim to enable a smooth operation.
• Prepare a comprehensive tank cleaning plan. This may include, but is not limited to the
following stages (as applicable) precleaning, cleaning, rinsing, flushing, steaming, draining
and drying. The plan should cross-reference the cargo to be loaded with the previous
cargoes carried in the designated tanks and reference should be made to various
industry recommended tank cleaning manuals, such as Dr. Verwey’s Tank Cleaning
Guide. The charterer’s tank cleaning instructions should take precedence over these
recommended methods. However, if they are of a lesser standard the same may need
to be brought to the charterer’s attention in advance; the onus of presenting tanks fit
to load the designated cargo usually rests with the Member.
• Ensure suitable training is imparted to ship officers on the above mentioned
procedures and if possible, tank cleaning operations are monitored for effectiveness
by the shore office.
• Ensure adequate sampling to safeguard the Member’s interests against possible claims.
Please refer to our earlier Lookout, Reissue of Sampling Procedures for Clean Product
Tankers for further guidance.
We would like to take this opportunity to kindly remind all our Members on the
importance of carrying out proper tank cleaning and pipeline flushing in an effort to
minimise their exposure to such claims.