96010 Near Miss Crossing TSS SING

 Can a TSS be Considered a Narrow Channel?
Singapore Strait

Report No. 96010

I am Master on a container vessel which transits the Singapore Strait severaltimes a month. The Strait and approaches to Singapore are, as you know,areas open to much 'Rule of the Road' abuse. I frequently observe closequarter situations mainly involving vessels exiting the Keppel Fairway andthe many anchorages off Singapore which lie immediately to the north ofthe westbound traffic lane, getting involved with traffic passing throughthat lane. There is at times obvious confusion as to who has the right ofway, south bound vessels exiting the Fairway or westbound vessels in thetraffic lane. The reason for this appears to be that due to the geographicalrestraints of the TSS in this particular area (limited manoeuvring spaceoutside the lane) westbound ships consider themselves to be in a "narrowchannel or fairway" and are therefore privileged because they can "safelynavigate only within such channel or fairway" (Rule 9d).
A glance at charts BA 2556 and 3831 shows that this could be a legitimateclaim as I well know from much experience here. Westbound traffic is invariablyon full sea or manoeuvring speed and it is not uncommon to meet 100,000dwt tankers in ballast making 15 knots with the west-going stream up to4 knots. Can they realistically be expected to alter their course to starboardor slow down for a ship coming out of the Keppel Fairway or anchorages flankingthe TSS. Due to their location, these exiting vessels have to be at "stations"which includes having their engines ready for manoeuvring. The westboundtraffic has to (as I do) rely on Rule 2(b) and maintain course and speed.Yet M1280 clearly states that being in a traffic lane affords no privilegesor rights of way to these westbound vessels it requires them to giveway the only exemptions being under Rules 10 (k) and (l).

There is a great difference between the English Channel TSS and the SingaporeStrait TSS. In the English Channel TSS the requirements of M1280 can moreeasily complied with because the give way vessel has the space available a course alteration is not going to take it into a petroleum anchorage.In the Singapore Strait, compliance with M1280 could have dire consequences.Yet I have seen many times ships dropping their pilot at the Fairway Buoyin the Keppel Channel and then quickly building speed up to 10 or 12 knots(regardless of the "blind spot" of P. Tembakul which obscureseastbound traffic in the southern fairway. This also applies to trafficmanoeuvring out of an anchorage heading south to cross the westbound lanebefore turning east. Their tactic is to get across or into the lane as fastas possible and in doing so expect any westbound traffic to give way tothem under Rule 15. Perilously close quarters situations often result withsound signals, Aldis lights and VHF all in use.

I have discussed these situations with other masters, Singapore pilotsand even find conflicting opinions amongst my officers as to who is theburdened of the privileged vessel. My position on the matter is that, ifin a TSS where I am the burdened vessel, I will give way if I have the searoom to safely do so. Where space is severely restricted, such as in theSingapore Strait, I invoke Rule 2(b) considering that "a departurefrom these Rules is necessary to avoid immediate danger". I can onlyhope that this is the correct interpretation and that it would "standup" at any marine inquiry. A further complication exists to add toan often chaotic situation. Owing to land reclamation in the Changi areaof Singapore Island, tugs towing barges of landfill cross the TSS from theIndonesia side around the clock. The Tug Masters often consider themselvesto have the right of way under Rule 3 (g) (vi) "restricted in theirability to manoeuvre" and that power driven vessels should keep outof their way under Rule 18 (a - ii). As mentioned earlier, westbound vesselsin the Singapore Strait often tend to treat it as a restricted fairway with some justification and believe that they are, under Rule 9 (d),privileged. Hence more close quarter scrapes. Singapore pilots, in conversation,very often relate "near miss" incidents which are all attributableto misinterpretation of the Collision Regulations.

It is certain that it is a lot easier to enforce Traffic Separation Schemesin some areas than it is in others. Perhaps if the Singapore Strait wereto be considered a "fairway" instead of a TSS, mariners proceedingthrough the area would have more definite right of way over crossing traffic.In this particular location I think it is right and sensible for trafficwho are able to give way to do so. I am sure that there are many other mastersand watchkeeping mates who share my views and concerns and have a feelingthat "something has to be don soon" to improve the present, farfrom satisfactory, situation in this region. I would welcome your views,criticisms and ideas of how the present ambiguity can best be resolved.

This is a very interesting report which deserves considerable thought and I would be interested to hear the reactions of other regular users of the Singapore Strait to these proposals. It would seem to be an ideal subject for the Singapore Nautical Institute to debate. The wording of the present Regulations, particularly Rule 10, suggests that our reporter is not correct in his interpretation and his arguments would not hold up at an inquiry. There have been other near miss reports from this area and I have recently received the following from a Master who takes a contrary view to the one expressed above. I am not suggesting that he was right in this case as I think that vessels should proceed from an anchorage or pilot boarding ground with extreme caution until they are satisfied that they will not obstruct other traffic by increasing speed.