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An Analysis of MSC Zoe's Container Loss
by The Maritime Executive
Sunday, March 17, 2019

On the night of January 1, 2019, MSC Zoe lost approximately 290 containers in heavy weather on the journey from Portugal to Bremerhaven. The loss of so many containers is an exceptional event and is the second largest known container loss of a ship due to heavy weather. Only Svendborg Maersk lost more, 517, in 2014.

This article is an attempt to analyze the cause but does not claim to be able to answer all the questions, because there are, of course, a number of unknown factors.

Where do I take my findings from? I have served as  as a Nautical Officer and Captain on container vessels of various sizes for many years, from feeder to very large container ships with 8,200+ TEU and vessel lengths of 340 meters, in all weather conditions worldwide. As Captain, I have sailed many large container ships and experienced numerous extreme weather conditions, without ever having container losses or damage. In addition, I have been working for years on issues of parametric rolling, its causes and its effects on container ships, in order to be able to address these in competent specialist decisions in my profession as Captain.

Weather conditions as a starting point

The six hourly published Sea Surface weather charts from 31.12.2018 00:00 UTC to 02.1.2019 06:00 UTC from metoffice.gov.uk are available to me and give an overview of the development of the weather during this period.

A depression (978 HPa) with its center over Iceland on December 31, 2018 moved within 24 hours in ENE-ly direction to the Vestfjord / Norway. The moving speed of 35 kt /hr showed that it was a fast-moving depression, which did not further deepen. A high-pressure area (1022 HPa) formed over South Greenland in the same period, shifted in SE-direction and on January 1, its center was W-ly of Reykjavik while its air pressure increased to 1035 HPa. In the course of that day, 12:00 UTC, the depression moved from the Vestfjord with its center (979 HPa) in SE direction over the Gulf of Bothnia, while the high pressure area with its center shifted in SE-ly direction via the Faroe Islands and thereby further increased its air pressure (1042 HPa).

In the afternoon and evening hours of January 1, both systems continued to relocate to the SE. On January 2, 00:00 UTC, the depression system had its center over the Baltic (Latvia / Estonia) and the high-pressure area had its center (1044 HPa) over NW Scotland (Outer Hebrides / Isl. Of Skye), where the depression began to slowly fill up. Until January 2 06:00 UTC, it could be seen that both pressure systems remained almost stationary, whereby the depression system continued to fill up (990 HPa) and thus a noticeable reduction of the wind forces occurred.

Such fast-moving depressions are not unusual in the winter season in the northern hemisphere. They are able to reach enormous wind speeds, Hurricane Force, due to extreme air pressure opposites. A kind of chimney effect develops by the opposite rotation of both systems. In addition, in the North Atlantic, the Norwegian mountain masses form a kind of wall and strengthen this effect, because the isobars are further compressed.

Wind condition analysis

During the period in question, over the North Atlantic between Iceland and Norway, winds from NW up to N prevailed, with winds speed of about 40 to 60 knots (8-11 Bft), and gusts with hurricane force (12 Bft). Wind speed is based on rough calculation of the distance between the 4 HPa Isobars. In the central North Sea, on the South Norwegian coast and the Skagerrak, in the period from January 1, 00:00 UTC until January 2, 00:00 UTC, wind from NW up to N with wind speed from 40 to 55 kt (8-10 Bft) prevailed.

In the area of the southern North Sea, the Dutch and German Frisian Islands, from December 31, 12:00 UTC, the surface analysis showed wind from WSW with 10-15 kt (3-4 Bft). Later it becomes apparent from the weather charts that the wind is from W-ly direction, with wind speed increasing 16 to 25 kt (5-6 Bft). After the passage of the cold front over the Frisian islands on January 1 at about 06:00 UTC, the wind turned noticeably towards NW, later N and increased significantly to wind speed from 35 to 45 kt (8-9 Bft) and in gusts up to 50 kt (10 Bf). The climax can be read from the weather charts at January 1 12:00 UTC to January 2 00:00 UTC, then a waning of the wind began.

Sea state analysis

The wave heights in the area of the Frisian Islands were reported up to 10 meters. Under consideration of wind fetch, wind direction, wind duration of effect, prevailing water depth in the area of the Dutch Frisian Islands and the Borkum Reef is difficult to envisage. The average water depth of TSS Terschelling - German Bight is between 17 and 26 meters. It should also be noted that the striking 40-meter depth line runs approximately 40 - 50 nm northerly of the TSS and Borkum reef (N-tip of the new wind farm "Veja Mate"), which equates to a natural breakwater and thus the wave length from the approaching waves from the North Atlantic will reduce.

With the concomitant reduction of the wavelength, the wave period is also reduced, which in turn can be expressed in steeper waves in the transition to the 40-meter depth line. However, that is only a limited effect, which should not have a major impact on the TSS Terschelling. From my experience, I assume that the wave height by the NW up to N swell was not more than eight meters, with a wave period of 8-11 seconds. In the area of the accident, eight seconds is realistic due to the above water depths. In addition, it is difficult to estimate the wave height in the dark. Whereas eight meter waves are always high enough to develop resonances.

These wind and sea conditions are not really a major problem for ships of this size. Wind speed of up to 40 kt and related swell fields with wave heights of 6 -10 meters are not an uncommon rarity, especially in the winter and transitional months on the North Atlantic. They are by no means pleasant, but manageable, if you follow the basic principles and safety criteria for going to sea in heavy weather.

Certainly, voices will now come up that say that wave heights of 25 meters and more can occur in the North Sea. This is not denied, but it requires several factors: longer-lasting storms in storm / hurricane force, several superimposed waves from different directions, long wind fetch, greater water depths, strong ocean currents. They are the prerequisite for the now undoubtedly recognized and by Prof. Alfred Osborne (2010) scientifically proven phenomenon about nonlinear wave systems, based on the Schrödinger equation from quantum mechanics. This is now considered as one of the main prerequisites for the formation of freak waves. Until then, the assumption had always been that there are only linear wave systems. All these factors can be excluded with great certainty for the sea area of the Dutch Frisian Islands and the TSS Terschelling - German Bight that night.

 The passage along the coast of The Netherlands via TSS Off Vlieland with a true course of 024° includes a course alteration by 50° to the eastbound lane of TSS Terschelling to a true course of 073° until Borkum Riff, from Borkum Riff, then 076° to buoy Jade Weser. From the course in TSS Terschelling it becomes apparent that for MSC Zoe the sea initially came from WNW, later NW to N direction that means from portside abaft beam to port beam of the ship.

This constellation is interesting in that it can cause resonance phenomena especially in stern quarter seas and beam seas, which means that the period of encounter cycles between sea and ship coincides with its own rolling period.

 Resonance phenomena and their effects

In the literature, a distinction is made between simple (1:1 resonance) and double-natural roll period (2:1 resonance). In the 2:1 resonance a greater danger comes since each roll period coincides with two pitch periods, which has the effect that the wave crest is always at the main frame line amidship, when the ship is floating upright. Due to the resulting loss of stability, the ship has the desire to roll immediately to one side. When the maximum roll angle is reached, the wave is at the front and aft end of the ship and the ship will be uprighted very quickly. The background to this is the fact that in longitudinal waves all ships based on their shape have their lowest stability on the wave crest and their greatest stability in the wave trough. If the sea is now irregular, extreme roll angles are possible within a short time. Thereby the wave-induced lever arm fluctuations between wave trough and wave crest act as essential influencing factors.

Basically, it is necessary that the lever arm variability must take critical values in order to achieve the effects described. This is the case when the wavelength equals 0.7 -2.0 times the ship's length (the data in the technical literature varies in values), with the shorter wavelengths often representing the more dangerous wavelengths.

Behavior of container ships in the stern quarterly sea

According to present knowledge, shipbuilding experts and scientists take the view that a 2:1 resonance when riding with the stern sea can only occur at "relatively low speeds" and low stability. This is partly reflected in extreme roll angles. It is important to know that in the stern-sea state the ship's natural roll period is subject to great fluctuations, because the lever arms acting in calm water can no be used; the wave crest and wave trough are levers only.

The consequence is that the natural roll period adjusts to the respective excitation, the more the stability changes between waves crest and wave trough. Special attention must be paid to cases where negative stability occurs on the wave crest. 

Unfortunately, the term "relatively low speed" is not defined further. From practical experience in extreme weather conditions and sea conditions, especially in seas from aft, I would consider there the range of six to 12 knots as realistic, depending on how fast the sea from aft is moving, which would be assigned as definition for "relatively low speed." But it can certainly be discussed. I emphasize once again that I'm particularly referencing my background in container shipping and especially Post Panmax container ships.

It follows, also confirmed by practical experience on board, that in the irregular aft seas no sharp resonance prevails, in contrast to regular sea state. It has been repeatedly found at sea that there are areas with courses or speeds where large roll angles can occur. The dimension of this areas increases with decreasing stability on the wave crest, because, as previously stated, then the ship increasingly tends to modulate its roll behavior to the sea state excitation.

Parametric Rolling

The term "Parametric Rolling" is often used, but it should be noted that to many nautical officers, the meaning of this term and especially the causes and characteristics of parametric rolling are not known. This means that in such situations wrong decisions may not be excluded which can cause loss of cargo, damage to the ship or even total loss of the ship. So here is an explanation of what "Parametric Rolling" means. I rely on Prof. Dr.-Ing. Stefan Krüger from the Hamburg University of Technology, Institute for Ship Design and Ship Safety.

Prof. Dr.-Ing. Stefan Krüger has it in his interesting article:

Zur Frage des Erkennens von gefährlich großen Rollwinkeln im praktischen Bordbetrieb (On the question of recognizing dangerously large roll angles in practical on-board operation)

It is also explained to non-professionals very understandable and I would like to quote him:

"In heavy seas, ships are essentially at risk when the sea comes from the front or aft. These lies essential (but not alone) at the periodically in sea changing lever arms. The ship will thereby not directly excitated to roll motions (how e.g. in beam-sea), but indirectly over the periodically changing lever arms. However, it is important to note that in addition to the parametric excitation, always a direct sea excitation through in the ship introduced sea moments take place, which be superimposed on the parametric excitation. Only in the case of the ship traveling exactly in the longitudinal direction of regular waves, the direct sea excitation is not present. 

“Put simply, the direct sea excitation changes the current width center of gravity of the displacement and thus directly introduces a moment into the ship, whereas the parametric component changes the height center of gravity of the displacement and therefore does not directly introduce a moment into the ship, but rather via a parameter. Both effects are inherently forced vibrations, and in practice it depends on which effect is dominant in which situation. "

(Source: Prof Dr. Ing. Stefan Krüger, Hamburg University of Technology, Institute for Ship Design and Ship Safety in Hansa 2007: Zur Frage des Erkennens von gefährlich großen Rollwinkeln im praktischen Bordbetrieb)

It must also be pointed out that "parametric rolling" is a very special behavior of container ships, almost exclusively of container ships.

It has been known since the 1990s that container ships have a special feature due to their underwater design, which is unique compared to any other type of ship in this dimension. This refers to the phenomenon of parametric rolling. Container ships were optimized in their underwater ship design in that they were geared primarily for speed. Especially the end of the 90s and in the 2000s the initiated competition, who crossed the ocean the fastest, reached the next port first, was a trademark of container shipping for a long time.

Speed and maximum payload resulted in an underwater design which was very slim to minimize water resistance and a hull design that was in the width outer drawn. This made it possible to create large cargo storage possibilities in holds and on deck. Slim long drawn bulb bow designs should additionally optimize the fast forward movement. While stern sections above the waterline are designed as mirror and wide overhanging side walls to maximize storage capacity in holds and on deck, so is the design of the underwater stern section very slim. Such an extreme design we find only on container vessels and it explains why with head / stern sea this type has such roll/ pitch motion problems in heavy sea. 

Even in the technology euphoria of increasing gigantism in container shipping, voices from engineers and scientists rose who demonstrated in their shipbuilding research institutes, simulation channels and maritime research facilities that these ships pose a risk that should not be underestimated, the risk of parametric rolling.

The first time I heard about parametric rolling, I felt like many others, I had no idea what that meant. One reason to deal with it is because it frames a very important, essential basis for working as a nautical officer aboard container ships to correctly assess ship behavior on the basis of existing stability criteria and the associated risks in bad weather under the influence of heavy seas and associated decisions to avoid extreme situations.

In technical scientific publications there are numerous graphics, e.g. polar diagrams from tests and simulations to sea effects under different stability states in ship technical test plants and simulation centers. They show the significant effects of wave height at different wavelengths, on container ships with small and large GM, different speeds, different seaward angles of inclination to the ship on rolling motions and roll angles and which resonances come. For this reason, I abstain from making representations of polar diagrams, which are usually used for this purpose, and give references to relevant engineering research and articles.

 Conclusions

The facts I have described, at least in broad terms, show that in the case of MSC Zoe, when cruising with wind and waves abaft beam at low/ medium speed and wave heights of up to eight meters and an angel of encounter from port 0° to 90°, there is a real danger the ship may be exposed to extreme roll angles, which lead to enormous centrifugal forces, especially in the high container tiers on deck. This may lead to container damage or loss of containers caused by broken lashing rods / turnbuckle or twistlocks when the effecting forces exceed many times over the safety force.

The maximum transverse accelerations acting on a container are usually introduced when the vessel is at an extreme roll angle. Maximum rolling normally occurs when the vessel encounters heavy beam or quartering stern seas.

 Effects by large roll angle and fast uprighting moment on the forces acting

Newton's law: F = m * a, is also valid in seafaring. The acceleration "a" defined as a speed change in a certain time interval illustrates which enormous forces can act at large roll angles and quick-uprighting moment in a short time interval. It is interesting to consider the effective weight force G, which is calculated from G = m * g, the mass of the object and the acceleration due to gravity (g = 9.81 m/s2 = 1 g). This can be explained by the example of a 20t container. If a 20t container has a weight force G in 1 "g" of about 20 tons and if now "g" will multiplied five times, this results in a weight of 100 tons. Since this calculation must be taken into account for each individual container, it becomes apparent which weight forces in a row, with eight tiers are acting. 160t become 800t weight. This notion is necessary to understand how tremendous powers multiply when large roll angles and quick upright moments coincide. The consequence: The load securing, is no longer able to absorb these forces and the lashing material is literally torn apart. 

No man on land has any idea of what incredible power the sea can unleash. Especially considering that today's VLCS / ULCS are stiff ships due to their width, which means that they have a high stability, a big GM, hence they have a strong uprighting moment. To reduce the stability effect, heavy containers are therefore not only stowed in the holds, but also on deck, even at higher altitudes, to lift the center of gravity and thus to reduce the GM. If we talk about lifting forces, compression forces and tension forces in container shipping, then experienced loading officers and captains know what forces they talking about that can be in the multiple G range. If they do occur, you have no way of effectively encountering them. Only course and speed alterations are helpful measures in such cases.

But that's only half truth. Improper load securing, i.e. not lashed or insufficiently tightening lashing rods and turnbuckles, not placing lashing rods according Cargo Securing Manual corresponding, not closing twistlocks, invite themselves to be destroyed in extreme situations and thus lead to container damage or losses and to damage to ships too.

Further details are available here.

Costa Smeralda Floated Out
by The Maritime Executive
Saturday, March 16, 2019

The 180,000GT, LNG-powered Costa Smeralda was floated out at Meyer Turku in Finland on Friday.

The vessel is expected to be ready for delivery to Costa Cruises in October 2019. She will be the first LNG powered cruise ship in the Costa fleet.

The ship's name, Costa Smeralda, recalls one of the  most beautiful tourist destinations in Sardinia (Emerald Coast). The ship will feature 11 restaurants, 19 bars, a spa area with  16 treatment rooms, a water park with slides, four swimming pools and an area  fully dedicated to kids. Costa Smeralda will also have the Costa  Desing Museum, “The CoDe,” dedicated to the excellence of Italian design.

The Costa Group has 28 ships in service, which equates to more than 85,000 beds. The fleet will be further strengthened by five new vessels by 2023, including two for  Costa Cruises, one for Costa Asia and two for Germany-based AIDA Cruises. Once the  new ships have entered service, the Costa Group’s capacity will have increased  by over 50 percent to meet rising  consumer demand for cruising over the next several years.

Costa Smeralda

Delivery: October 2019 (sister ship in 2021)
Flag: Italy
Length: 337m
Width: 42m
Draft max: approx. 8.8m
Gross Tonnage: 183,900
Passenger cabins: 2610
Total passengers: approx. 6,554
Balcony cabin ratio: 63.7 percent
Total crew: 1,646
Service speed: 17 knots
No. of main engines: four

Funnel Lay

Report: Only Ten Vaquita Left
by The Maritime Executive
Saturday, March 16, 2019

Scientists announced last week that only 10 vaquita porpoises likely remain in the world and that the animal’s extinction is virtually assured without bold and immediate action. 

The vaquita, the world’s smallest and most endangered cetacean, is found only in Mexico’s northern Gulf of California. The release of the new vaquita estimate came two days after reports of the first possible vaquita mortality of 2019 by Sea Shepherd. Sea Shepherd has been present in the Upper Gulf of California since 2015. In that time, the organization's crews have documented the entanglement of 36 marine mammals trapped in illegal gillnets. Nine were cetaceans, and only one was able to be saved – a juvenile humpback whale in early 2016. Although Sea Shepherd has found several dead vaquitas, confirmed by scientists to have been killed from entanglement, this is the first time one has potentially been discovered still trapped in a gillnet.  

The announcement of vaquita numbers from the International Committee for the Recovery of the Vaquita (CIRVA) also calls on Mexico President Andres Manuel Lopez Obrador to end all gillnet fishing and adopt a “zero tolerance” policy of enforcement in the vaquita’s small remaining habitat. CIRVA is an international team of scientific experts assembled in 1996 to assist in vaquita recovery efforts.

“One of Earth’s most incredible creatures is about to be wiped off the planet forever,” said Sarah Uhlemann, international program director at the Center for Biological Diversity. “Yet Mexico has only made paper promises to protect these porpoises from deadly nets, without enforcement on the water. Time is running out for President Lopez Obrador to stop all gillnet fishing and save the vaquita.”

The vaquita faces a single threat: entanglement in illegal gillnets set for shrimp and various fish species, including endangered totoaba. Totoaba swim bladders are illegally exported by organized criminal syndicates from Mexico to China, where they are highly valued for their perceived medicinal properties.

Despite efforts in Mexico to curb gillnet fishing of shrimp and other fish and efforts in China to reduce demand for totoaba, the vaquita’s population dropped 50 percent in 2018, leaving an estimate of around 10 remaining vaquita, with no more than 22 and perhaps as few as  six.

“There is only the tiniest sliver of hope remaining for the vaquita,” said Kate O’Connell, marine wildlife consultant with the Animal Welfare Institute. “Mexico must act decisively to ensure that all gillnet fishing is brought to an end throughout the Upper Gulf. If the vaquita is not immediately protected from this deadly fishing gear, it will go extinct on President Lopez Obrador’s watch.”

In 2017, in the face of international pressure, Mexico banned the use of most gillnets within the vaquita’s range, but enforcement has been lacking. For example, during the 2018 illegal totoaba fishing season, nearly 400 active totoaba gillnets were documented in a small portion of the vaquita’s range, and gillnets continue to be found within the vaquita refuge. Recent violence against conservationists in the region has limited critically important net removal efforts, says the Animal Welfare Institute.

Despite the marine mammal’s alarming decline, CIRVA emphasized that the vaquita is not extinct and that recovery remains possible. They are still producing offspring, and the remaining animals are healthy, showing no signs of disease or malnutrition.

In 2018, a U.S. court temporarily banned the import of seafood caught with gillnets in vaquita habitat. This year, parties to the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) and the World Heritage Convention are considering additional conservation measures for the vaquita and totoaba.

Sewage Chlorination Without De-chlorination: A Certified Impossibility
by The Maritime Executive
Saturday, March 16, 2019

The approval regime has been in the blood of the marine industry. It has served well to safety equipment, but can the same be said when it comes to environmental technologies? An earlier publication suggested far reaching consequence of poorly enforced marine sewage rules. They have has gone beyond poor treatment performance status and started to erode the credibility of the approval regime. 

This joint publication explores one of the non-conformity issues in greater detail. The questions are simple: how can the approval assessment bodies have certified an impossible feature for sewage disinfection that they would not do for ballast water disinfection? How could “good test results” be obtained in the first place for impossibilities such as this and “no-sludge” claim to be certified?

Some may argue the existing sewage guidelines are vague and weak, but it is no excuse for the marine industry to be served with what is scientifically impossible. A certified impossibility need not happen in any industries, even without any guidelines. But, let’s hope to understand the root cause, so that corrective actions may be developed.

Sewage Treatment Plants Using Chlorination Disinfection without De-chlorination – A False Claim, and a Non-Conformity 

Co-authored by

Dr. Wei Chen, Future Program Development Manager, Wartsila Water Systems Ltd, UK 
Mark Beavis, IEng IMarEng FIMarEST, Managing Director, ACO Marine s.r.o., Czech Republic, ACO Marine Systems GmbH, Germany
Dr. Elmar Dorgeloh, Manager Director, Development and Assessment Institute in Waste Water Technology at RWTH-Aachen University (PIA), Germany
Felix von Bredow, Board of Hamman AG, Hamman AG, Germany
Endorsed by: 
Antony Chan, Engineering Manager, Victor Marine Ltd., UK
Dr. Daniel Todt, Project Manager R&D, Ecomotive AS, Norway
Helge Østby, Senior Technical Advisor, Jets Vacuum AS, Norway
Markus Joswig, Head of Marine Department, Testing Institute for Wastewater Technology GmbH (PIA GmbH), Germany
Benny Carlson, Chairman and owner, Marinfloc, Sweden
Tobias Kaulfuss, Manager - Marine Sewage Treatment, RWO - Veolia Water Technologies Deutschland GmbH, Germany
Greg Shannon, Technical Sales Director, JOWA AB, Sweden 

Chlorination has been used to prevent the spread of waterborne diseases such as cholera, dysentery, and typhoid. As one of the greatest advances of the modern era, it has saved millions of lives. Today, despite concerns regarding disinfection by-products (DBP) and the advance of other disinfection technologies, such as UV, it continues to be commonly used, especially when a residual is required to control the risk of microbial re-growth [1,2].  

Wastewater Chlorination 

The disinfection of wastewater has been extensively studied since the early 1900s [3] because of the potential exposure to humans via contaminated drinking water sources, recreation, and the consumption of fish/shellfish, etc. 

International shipping involves tens of thousands of ships drawing from and discharging into the sea (see map above). The sewage from ships includes that from onboard hospitals. It is only correct, therefore, to be ever mindful of the environmental impact and the risk of endemic diseases, not just in times of crisis. The coliform limits set in the marine rules are more stringent than those for equivalent coastal wastewater discharges from land.  

So, what does it take to reach the 100 counts/100ml limit specified in the MEPC.227(64) Guidelines? The effectiveness of chlorination depends on the wastewater quality, and the chlorine dosage that follows a time-concentration relationship. The removal of organics and particles from wastewater prior to disinfection is desirable if not essential [4,5]. Other influential factors include the pH, the temperature, and the presence of ammonia, etc. Wastewater can contain more than 106~107 counts/100ml of faecal coliforms. Conventional treatment processes can achieve 90 percent, or a one log, reduction. But a further 99.9 percent ~99.99 percent removal, or 3~4 log-kill, is needed. To achieve this, a chlorine dosage of 5-20 mg/l is required with a chlorine contact time of 30 minutes [4, 6]. 

Chlorination is only half of the job.

De-chlorination

Since the 1970s, chlorine and other disinfectants have been found to form DBP that may be carcinogenic or harmful to the environment. Residual disinfectants themselves also cause harm to aquatic species. This has led to the adoption of a maximum residual chlorine target of 0.5 mg/l, as specified in MEPC.227(64). Although chlorine decays naturally, it takes many hours if not days [1,7]. 

The contact time in a sewage treatment plant is typically less than 30 minutes at its designed peak flow capacity. A chlorine concentration of 5-20 mg/l will not drop below the 0.5 mg/l limit in such a short time without a de-chlorination step. De-chlorination is a must prior to discharge. Otherwise, it is impossible to satisfy both microbial and residual chlorine limits, no matter how well the plant is operated.

Non-conformity

However, de-chlorination is absent in some marine sewage treatment plants that use chlorination disinfection. The approval assessment bodies have accredited such equipment with IMO and MED certificates, based on “good laboratory results.” Thus, they have certified impossibilities. These “magic boxes” contravene science. These are non-conformities, and they turn certificates into licenses to pollute.

Over the years, such “magic boxes” have found their way onto many ships, contributing to the poor performance status of the sewage treatment plants. They set the “bar,” putting conforming technologies under “competitive” pressure by forcing them into a race towards the lowest levels of functionalities. In reality, coliform concentrations in treated effluent have been found to exceed the limits by a long way across all kinds of disinfection technologies employed in marine sewage treatment plants [8]. 

Ballast water management systems (BWMS), which perform less arduous disinfection duties than sewage treatment plants, may lend a useful reference. Chlorination-based BWMS have target chlorine concentrations ranging from 3 to 20 mg/l. Almost all of them incorporated de-chlorination prior to de-ballasting. Those that do not are subject to a certified minimum hold time of many days. The apparent inconsistencies between the approval processes of these two marine environmental products are hard to comprehend. 

There is a lot at stake. It may be time for the IMO, its Member States, and the assigned approval assessment bodies to acknowledge this issue, to undertake transparent and timely reviews, to identify the root cause and to prevent such non-conformities from reoccurring. 

For those who wish to be contacted for supporting further updates on this subject, please email wei.chen2@wartsila.com.
 
References

[1] Wastewater Technology Fact Sheet – Chlorine Disinfection, USEPA (1999)
[2] Assessing the Need for Wastewater Disinfection. Haas, C.N., et al. Journal of the Water Pollution Control Federation 59: 856-64 (1987)
[3] The Disinfection of Sewage and Sewage Filter Effluents, Phelps, E. B., Water Supply Paper 229, United State Geological Survey (1909). https://pubs.usgs.gov/wsp/0229/report.pdf
[4] Wastewater Engineering, Treatment and Reuse, 4th ed, Metcalf & Eddy (2004)
[5] Guidelines for Environmental Management – Disinfection of Treated Wastewater, EPA Victoria, Australia (2002) 
[6] Wastewater Technology Fact Sheet – Disinfection for Small Systems, USEPA (2003)
[7] Technical Report: Chlorine Decay Study of Wastewater Discharges to Marine Waters from Stationary Small Commercial Passenger Vessels in Southeast Alaska, CH2M Hill, Alaska Department of Environmental Conversation (2006)
[8] Prevention of pollution by sewage from ships – rules and realities, Chen, W., ShipInsight (2018). https://maritime-executive.com/editorials/sewage-from-ships-rules-and-realities-1  

Dr. Wei Chen is Future Program Development Manager for Wärtsilä Water Systems.

Abandoned Seafarer's Family Spirals Down Into Debt
by The Maritime Executive
Saturday, March 16, 2019

The U.K.-based charity Human Rights at sea has released a family impact statement for Indian Chief Engineer Gorropotu Venkatarao, abandoned of the coast of the UAE for 23 months.

Venkataroa is on the MT Tamin in Sharjah OPL anchorage offshore UAE due to a lack of charter.

On arrival in Sector 11, East Navi Mumbai, India, the Human Rights at Sea team were met by Bharath Bylapudi, the nephew of Venkatarao. “My Uncle is a strong man, but he does not have any hope left. His only hope has been to stay sane and to get back some of the wages that are owed to him to take home.”

Venkataroa supports his wife, son, 15, and daughter, 22. A month after he stopped receiving pay, the family savings had been used up. The bank threatening that they would lose their home if mortgage payments were not made. Three extended families stepped in to help, but after 18 months, they too are suffering financially and have had to reduce their aid. 

Venkataroa's wife has had to take out another loan to keep the household running. She is suffering and is supported by her daughter, who has stopped her studies but is unable to find a job. Both have tried to protect Venkataroa's son, who is excelling at school, from the details of their financial difficulties.

The charity is witnessing an underlying trend of what it is now calling the “second abandonment.” This occurs when supporting family members and friends themselves run out of money, having used up all their savings and assets to assist, and are thereby put into a similar financial and mental position.

This has serious mental health implications, says the charity. Iranian Researcher, Sayedeh Hajar Hejazi, commented: “The ripple effect of the first commercial abandonment is having far greater ramifications on the wider family unit than was previously known. We need to better understand and expose this trend to try to stop this pattern of human rights abuse.”

The family statement is available here.