Underwriting Risk in STS Operations – a Paradox
Alexandros Glykas, DYNAMARINe
STS Operations are high risk operations. Amongst other reasons triggering threats, these operations engage various parties, unknown to each other, having very little time to prepare in order to execute a combined operation. According to applicable C/P and latest OCIMF guidelines compatibility of vessels is one main issue which needs to be satisfied prior to an STS Operation
As a paradox though, STS operation by its nature, includes a sense of incompatibility which rests to the fact that the Shipowner provides his warranty over safety matters, including those he has little power to control, such as the risk level of STS Service Provider, the lifespan of cargo hoses and others
DYNAMARINe, based on objective evidence, has raised concerns over the transparency of audits of STS Service Providers and the involved risk. Further to interest received by cargo underwriters, DYNAMARINe has worked towards providing solutions to assist industry stakeholders
In this article, the global distribution of market share of STS Service provider is presented with respect to the volume of operations and the level of sustainability of their SMS system. These parameters present an opinion over the risk of these operations, considering that in most cases, an STS Service Provider will provide the STS equipment and accordingly the appointed POAC will advise the Master of the ship.
Figure 1 presents the percentage of STS Service providers with respect to their operational capacity:
One may see that the majority of these organizations are operating locally. The prime characteristic of local STS Service Providers is that they may support a limited number of simultaneous operations and have limited access to technical resources and/or qualified personnel. Such access to resources may improve, when the number of STS Operations increases, and especially when the location becomes competitive.
When considering the safety of STS Operations in the case of local STS Service Providers, the answer is not straightforward. The outcome depends on the safety culture of the provider and the preparedness level of the shipowner, engaged in such operations. Our advice to shipowners is that they should be extremely vigilant when local providers are contracted as they need to scrutinize any available piece of information. Bear in mind that the Shipowner is totally responsible for the Safety of the STS operation
When the organization size and capacity increase on an STS Service Provider, then access to resources become easier and possibly more sustainable. It is interesting though, to compare the number of operations conducted by these organizations
One would expect that the STS Service Providers with a global profile would undertake the majority of STS Operations. This is not the case as shown in Figure 2. All Global STS providers undertake only 38% of the total STS operations while the rest 62% is undertaken by the Regional and Local providers
It was very impressive to see that the local providers perform about 32% of global STS operations as the market is spread almost evenly to all types of STS Service providers
Although the need for STS operations is high, cargo owners will deal with any available STS Service provider. They do not seem to be interested in their availability of resources and past assurance data
From a quality perspective, in locations where multiple providers exist, the locals may have an advantage over the price, a fact that inevitably compromises the quality of the service, even for global or regional providers. This fact raises concerns over safety issues
A shipowner may ask the following question: “which type amongst the STS Service Providers provides a safe service to the shipowner”? The answer is not straightforward since it depends on the safety culture of the Provider, his access to resources, the quality standards of the charterer/ cargo owner/ trader, and the number of operations involved.
It is common sense that quality standards are dropping with such market criteria over STS Service Providers
The majority of STS Service providers claim to have an SMS system which warranties continuous improvement and transparency over the management of operations. DYNAMARINe is involved in the assurance of STS Operations over the last decade and has an opinion, supported by objective evidence, on the quality of STS Service providers. For the scope of this paper, we categorise the SMS (related to Qualitative evidence), from a risk-based perspective. In doing so, we ensure to eliminate any association with commercial issues
The following categories are supported in this analysis:
Following figure 3 outlines the percentage of the STS Service providers
As a ship-owning or ship-managing organization, one may question the level of knowledge you have, over the SMS system of the STS Service Provider. When clearing participating vessels, you are aware of the risks that the counter vessel is accepting, since they are similar to those of your vessel. But what about the STS Service Provider? Do you receive a clearance request for those organizations? If the answer is negative, what is the reason? As a shipowner, you still have the liability in case of pollution due to substandard services by STS Service Providers. There is a Paradox here!
Cargo underwriters have seen this GAP when insuring cargoes. It is different when the cargo insured originates from a terminal and destinates to another terminal, compared to the case where an STS Operation takes place. In the second case, there is a weak link, which is called "STS Service Provider". Although the cargo owner claims due diligence over the selection of the provider, this case has proved flawed, non-transparent, and falls into subjectiveness due to a conflict of interests
Although vessels and ship managers are vetted by OCIMF, as this is deemed to represent quality and transparency, can the same principle apply to STS service Providers? The answer is negative because safety over STS Operations is ensured by the tanker owner and not the Cargo Owner, who appoints the STS Service Provider. With the current market status and applicable contractual relations, only the shipowner can transparently vet/ audit the STS Service Provider. Any other attempt has proved subjective and provides very little assurance to involved parties
SIRE 2.0 addresses various issues to the ship owner, related to the due diligence actions needed towards STS Service Providers, through JPO Assessment, Equipment Certification, Weather criteria, review of the location-based risk assessment, etc
DYNAMARINe has published a SIRE 2.0 GAP Assessment, to support its clients to be proactive. Should you be interested in further information, please feel free to contact us at firstname.lastname@example.org
For further information please feel free to contact DYNAMARINe at email@example.com
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