Hold Cleaning - when is clean, clean enough?

Hold cleaning disputes are not infrequent and can result in the need for multiple surveys and significant delays and costs. This article discusses some of the practical aspects of cleaning cargo holds, including the factors which will be relevant to the extent of cleaning required, and also how appropriate systems can be put into place to carry this out in an efficient manner. It also comments on a recent London arbitration which considered an implied term in relation to the standard of cleanliness required and whether charterparty requirements were met in circumstances where there were contradictory survey results.

Introduction to Hold Cleaning

Preparation of cargo holds for the next cargo is an important operational consideration on all bulk carriers. If not properly planned and carried out inadequate hold cleaning can lead to several different claim types. Claims in respect of the cargo, such as for shortage, contamination or water damage, can be directly linked to the hold cleaning, in addition to which charterparty disputes resulting from delays and berth costs may arise. By way of an example, unless the hatch cover seating surfaces are clean, a weathertight seal will not be possible resulting in a risk of water accumulating and dripping into the hold and causing cargo damage.

The extent of hold cleaning and preparation required for the next cargo will depend on several factors; most importantly, the cargo to be loaded and its intended use. In the bulk carrier trade a number of terms are often used to describe the cleanliness requirements but Members should be aware that there is no universal definition of these terms and very often surveyors will inspect holds subjectively based purely on their previous experiences rather than set criteria. ‘Standards’ such as ‘hospital’, ‘ grain’, ‘normal’ and ‘shovel’ are all in common use and are often included in charterparties. However, even when one of these commonly used terms is used, disputes can arise in relation to the cleaning standard required as some countries interpret the requirements differently and what may be acceptable as ‘grain clean’ in one port may not be acceptable in another. For instance, it is well known that Australia, USA and Canada require very high standards of hold cleanliness prior to loading grain cargoes.

A broad guide to these commonly used terms is:

“Hospital Clean” is the most stringent and requires all hold surfaces to have 100% intact paint coatings on all surfaces (including the tank top, all ladder rungs and undersides of hatches).

“Grain Clean” requires the holds to be free from insects, odour, residue of previous cargo, lashing material, loose rust scale and paint flakes, etc. Prior to loading the holds must be swept, washed down with fresh water, dried and well ventilated. Light atmospheric rusting of exposed steel is generally acceptable but loose scale or paint, such that it may become detached and mix with the cargo, certainly is not.

“Normal Clean” requires the holds to be swept to remove all residues of the previous cargo, washed down and dried ready to receive a similar or compatible cargo.

“Shovel Clean” does not require washing but only the removal of the previous cargo by rough hand or mechanical sweeping.

It should however be noted that there is no universally accepted definition of these terms. Therefore, wherever possible, it is important to use as clear a description as possible when describing the cleaning standard required in a charterparty or voyage order.

A significant distinction in so far as hold cleanliness is the obligation that applies on delivery under charters and that which applies for intermediate hold cleaning. For a discussion on this issue see: 'Intermediate Hold Cleaning - Owners' Duty' and 'Hold Cleaning - Who Bears The Cost?'

Planning and Preparation for Hold Cleaning

To reduce the amount of hold cleaning required for the next cargo masters may utilise the discharge/cleaning facilities at the current port. By removing as much remnant of the prior cargo from the holds, disposal and clean-up costs can be reduced and time can be saved before the next load port. In order to effectively and quickly clean holds it is also important to have access to sufficient cleaning materials, including chemicals (if appropriate for the next cargo) and high pressure washing equipment on board.

When planning the hold cleaning operation the master should also properly assess the risks of this. For instance, if chemicals are to be used as part of the washing-down procedure, accurate data (MSDS) should be provided to the vessel to ensure the risks are understood and safe handling implemented. This will include a job specific risk assessment, a tool box talk and the correct use of personal protective equipment. Moreover, agreement on compatibility of the clean with the next intended cargo should be obtained from the shippers/charterers in order to ensure that there is clarity on the precise level of cleanliness they require the vessel to achieve, for example no loose rust, no bare steel or fully painted and cured.