Youth Open Letter to Agencies on Oil Spill Protocols

To the agencies involved in management of oil spills,

LepakinSG, the Singapore Youth Voices for Biodiversity (SYVB) and the Singapore Youth for Climate Action (SYCA) collectively address this open letter to the stakeholders involved in the 14 June Oil Spill.

This is our first time being exposed to the issue of oil spills on our shores, and observing the cleanup response coordinated by the relevant government agencies. From our understanding, agencies had acted swiftly to the best of their abilities, but were unable to fully contain the spill due to poor weather.

We would like to thank the various agencies for their efforts to ensure our shores are kept safe from the oil spill. However, the following letter lists some areas for improvement for future incidents of a similar or even larger scale. We note that while news of the spill quickly made the rounds on social media and sparked massive public interest, the 400 tonnes of oil spilled in this case was far from the largest in Singapore’s history. Furthermore, the spill fortunately occurred during the neap tides, which ensured most of the intertidal habitats were largely protected from the oil slicks.

We were lucky in this case and managed to avoid irreparable damage to local ecosystems. However, we should not take this for granted, and instead use this as a critical learning opportunity to prepare for future oil spills. Oil spills will continue to occur despite our best efforts, so swift protocols for effective oil spill response management and public engagement on these issues would still be essential.

1. Transparency of the issue (as of July 2)

(Source: The Straits Times, Media Statements, Ministerial Statement)

We have consolidated a timeline of events and the scale of the oil spill, based on news articles and the Singapore government’s media statements.

June 14:

• 2:18 p.m.: The Netherlands-flagged dredging vessel Vox Maxima lost engine and steering control. The allision occurred between the Vox Maxima and the stationary Singapore-flagged bunker vessel Marine Honour ¹ , resulting in damage to Marine Honour’s carrying tank.
• 2:22 p.m.: The Maritime and Port Authority of Singapore (MPA) was notified.
• 2:33 p.m.: The first patrol craft arrived on-site, initiating clean-up efforts by spraying dispersants to begin working on the immediate oil spill. It was noted that only 400 tonnes of oil remained in the tank, and the other half had leaked into the sea. MPA’s contractor deployed oil booms around the vessel to contain the spill. MPA, PSA, and the bunker vessel company activated oil spill response craft to the location.
• 2:55 p.m.: T&T Salvage was alerted to the incident. It took 3 - 4 hours to load all gear from Tuas warehouse to the trucks and another hour to transport all of them to Marina South Pier, before they were loaded onto the boat.
• 9:41 p.m.: Upon arrival, the team took several hours to assess the situation (e.g., safety precautions) before laying out the booms.

June 15:

• 1am - 2am: T&T Salvage started laying out 200m of booms around the vessel
• 5.15am: 200m of booms were laid out. The process (3 - 4 hours) was lengthened ² due to poor weather conditions - strong winds, poor visibility in heavy rain, and high risk of falling off-board.
• The oil spill had spread to nearby beaches. Oil and light sheens were observed at Pasir Panjang terminal, Palawan, and Siloso Beach on Sentosa Island.
• NParks deployed booms to protect Berlayer Creek and the rocky shore at Labrador Nature Reserve.
• MPA deployed containment booms and equipment to lift and sieve oil off the water surface. MPA stated that 16 oil spill response crafts were deployed to continue spraying dispersants and collecting oil slicks on the water surface. Multiple contractors were engaged to deploy booms, including T&T laying booms at Keppel Marina, Sentosa Cove and additional fence booms around Marine Honour.
• A joint media statement from MPA, NEA, NParks, and Sentosa noted that after “MPA observed that oil had spilled from the damaged tank as a result of the allision’’, MPA patrol craft was activated to spray dispersants on the spill, MPA’s oil spill response contractor was also activated to mobilise oil booms, dispersants, and oil skimmer. It was mentioned again that the oil spill from the vessel has been contained and there were no further leaks.

June 17:

• The oil continued to spread, reaching the waters in Changi. Oil-absorbent booms were deployed in biodiversity-sensitive areas, including Chek Jawa Wetlands in Pulau Ubin, Coney Island Park, and Pasir Ris Park, as a precautionary measure. An additional 1,600m of booms were planned for deployment, supplementing the existing 1,500m. Two buster system ³ were in operation to locate and sieve oil from seawater, with one more system to be deployed.
• A joint media statement from MPA, NEA, NParks, Sentosa, PUB, and SFA announced the next phase of clean-up operations, including the deployment of an additional 1,600m of booms and 7 oil recovery assets to skim and collect remaining oil. OSRL deployed 2 buster systems, while T&T Salvage and Singapore Salvage Engineers deployed 2 skimmer-systems to lift oil into storage tanks. 3 more vessel-towed collection booms systems will be deployed in the coming days.

To CNA’s question on why MPA did not mention in its first media statement on the possible spread of the oil spill on June 24, we note that Transport Minister, Mr Chee Tat Hong’s response was that “the immediate response was to deal with the issues at the incident site itself”. While this is a valid point, it is also important to provide an accurate representation of the situation on the ground, based on what is known to MPA at the moment.

While simple, short statements can communicate the situation quickly, it may have been misleading. For instance, MPA’s media statement dated June 14 indicated that “the spill was contained” and “some oil from the damaged cargo tank on board MARINE HONOUR spilled into the water. The affected cargo tank has been isolated and the spill contained.” The general public could easily have understood this as: (i) a small amount of oil was spilled into the sea, (ii) it was largely under control, and (iii) it was not spreading.

However, the wording from the ministerial statement on 2 July does not corroborate this: “upon confirming that a significant amount of oil had spilled into the water…” and “MPA also checked the damaged vessel to ensure that it would not sink, the crew were safe and there was no further spillage of oil”. By the time the booms were deployed on June 15, 5.15a.m., the oil had spread to nearby beaches, affecting marine wildlife. Members of the public also reported seeing oil slicks on several shores, which did not gel with what was reported.

While we understand that agencies have robust protocols in place for incident management, and that in the early stages many aspects may remain unknown, such as the unpredictability of ocean and wind conditions, we dutifully seek more transparent and accurate updates and communication from MPA and other associated governmental agencies to provide a consistent and reflective account of the situation on the ground, closing up the expectation-reality gap. Otherwise, when on-ground realities do not conform to expectations based on what is communicated by agencies studying the matter, it may raise concerns among the public regarding agencies’ preparedness and invite heavy scrutiny. In this case, while we know now that agencies had indeed been conducting their due diligence in mitigating the impacts of the oil spill, many questions regarding the protocols were still being asked publicly, and in parliament. Such issues related to effective and transparent communications of existing protocols may have been less pronounced if they had been executed well to begin with. We therefore kindly ask that public communication departments of associated governmental agencies be mobilised alongside operations when such incidents occur, and to ensure that information released accurately reflects on-ground realities. This includes publicly acknowledging unknowns and being forthcoming with agencies’ expectations of the situation, particularly in cases where little information can be confirmed.

The main questions we would like to ask for this section are:

1. When were other agencies such as NParks alerted to the spill? How were they involved in the immediate response coordination?
2. What is the existing strategy for public communication during such incidents? How will agencies strive to better understand general public concerns with regards to communications?

2. Oil Spill Response Standard Operating Procedure (SOP)

Through studying the responses that Singapore undertook in historical oil spills, we understand that MPA is the main national authority responsible for regulating and controlling oil spill response operations within Singapore’s territorial waters. However, MPA’s scope of responsibility rests only in the sea, while shore matters are handled by the National Environment Agency (NEA), which coordinates the manpower and logistical support for shore clean-ups.

A key partner of MPA for oil spill response is the International Tanker Owners Pollution Federation Limited (ITOPF). It is noted that the use of dispersants is “the primary response where practical and where the advantages in terms of environmental protection outweigh the disadvantages of cost and ecological damage”, and that “dispersants are also used to clean beaches once bulk oil has been removed manually”. As supplementary measures, booms and skimmers are also used to protect key resources including biodiversity-sensitive areas.

It is clear that based on historical oil spill responses, such as Evoikos in 1997 (28,500T), Natuna Sea in 2000 (7,000T), and Bunga Kelana in 2010 (2,500T), MPA is experienced with leading coordinated response measures towards addressing any oil spill at sea. Taking the Bunga Kelana 3 Oil Spill in 2010 as an example, the collision between the tanker MT Bunga Kelana 3 and the bulk carrier MV Waily spilled up to 2,500T of oil. Immediate steps were taken by MPA to deploy 4 patrol craft to survey the situation at sea. Both the Emergency Operation Committee (EOC) and salvage and oil spill response companies were activated. Immediate clean-up operations included the deployment of dispersant spraying, booms for containment purposes, and oil recovery via skimmers. Following which, protective booms were deployed to biodiversity-sensitive areas based on oil spill coverage projections, and flotsam collectors were sent to sea for any retrieval of weathered tar and oily debris.

The above gives us a glimpse of MPA’s Oil Spill Contingency Plan. This was also observed in MPA’s response to the Marine Honour-Vox Maxima’s 400T oil spill. While commendable, the flurry of events and delayed communication from relevant agencies caused considerable anxiety among concerned citizens eager to assist. Hence, we respectfully request the inclusion of the general public and civil society groups as additional stakeholders in this plan, with a clear outline of how active citizens can contribute during an oil spill. Specifically, engagement with civic groups such as nature and clean-up groups would be helpful as they could represent as additional points of contact to aid with animal rescue and volunteer mobilisation. This ensures an orderly and systematic execution, paying attention to public health and safety. We noted that there is currently a coordinated call for volunteers to support the removal of tar balls from the beaches affected by the oil spill. This could also be included as an actionable step for the general public. Civil society groups can also quickly disseminate information and mobilise members of the public in times of crisis where agencies may face manpower crunches - involvement of such organisations in regular oil spill drills would be useful to this end.

We understand that following oil spill incidents in the 2010s, a Standard Operating Procedure (SOP) proposal was put forward in 2016 by N. Sivasothi (NUS), Ria Tan (WildSingapore), and Anbarasi Boopal (ACRES). This proposed active coordination of experienced volunteers from cleanup and nature groups and included information gathering and dissemination during oil spills. Between 2012 and 2016, this proposal was shared with the National Parks Board’s Coastal and Marine Division, the National Biodiversity Centre, the Biodiversity Roundtable, the National Volunteer & Philanthropy Centre and the Green Roundtable. However, newer members of the nature community were not privy to these discussions and so we remain unclear on the status of the proposed SOP. However, in recognising the value of a published SOP we have taken the initiative to include a preliminary version (see Appendix A) for your consideration. We hope to have a response to dictate the possibility of an improved SOP, thereby addressing this topic comprehensively and ensuring that future coordination of oil spill responses does not repeat any mistakes previously made.

The main questions we would like to ask for this section are:

1. What actions were taken after members of the nature community submitted the proposal for an SOP in 2016?
2. Are there current plans to create an SOP for active citizen and volunteer support during oil spills and similar incidents in the future? If yes, what are these plans?

3. Environmental impact from the oil spill and use of dispersants

We would like to clarify the use of dispersants undertaken by MPA and Oil Spill Response Pte Ltd during the clean up process. It is well-established that dispersants can be toxic. Studies as early as the 2010s have shown that oil-dispersant mix can be 52 times more damaging to microorganisms than the oil alone by increasing toxic hydrocarbon levels. The resultant increase of oil-in-water and oil-dispersant mix significantly affects a range of marine fauna in the surrounding waters, especially at sensitive stages of life, killing fish eggs and contaminating corals.

We understand that dispersants were applied to protect shoreline areas and surface-dwelling fauna, as well as to prevent the formation of persistent oil emulsions, yet this decision comes at the expense of ecosystems within the water column. We are concerned about the long-term ramifications that usage of dispersants would have in biodiversity-sensitive locations, such as the Sisters’ Island Marine Park and the surrounding coral reefs (which also include the proposed site of Singapore’s second marine park). Compounded with the ongoing mass bleaching event, this could have been disastrous for our reefs.

We would therefore like to humbly challenge the usage of dispersants as a first response measure, and clarify how their efficacy and eventual impacts would be measured and communicated to the public. A news report mentioned that dispersal use was in line with MPA standard operating procedures and global best practices. However, we are still keen to clarify the rigorous process that MPA has taken to conclude that dispersants were the most appropriate and ideal solution.

We are aware that MPA has published a list of dispersants approved for use in Singapore waters. However, this does little to allay public fears that these dispersants are unsafe. Many exact chemical components and hazards remain unknown to the public. Hence, we would also like to understand the short-term and long-term impacts of these dispersants on the health of our marine and coastal environments, and how these impacts will be/are being monitored and communicated to the public.

We also seek to understand if MPA has considered any alternatives to dispersants as the first response measure, such as the deployment of skimmer craft and/or other mechanical recovery options following the allision between the two vessels. An ITOPF technical information paper outlined the operational efficacy of oleophilic skimmers in spite of challenging weather conditions and noted their capability of collecting and removing freshly spilled, medium-to-high viscosity crude oils effectively. It raises the question on whether skimmer craft can possibly be deployed as a first response measure to reduce the quantity of oil that is needed to be cleaned before resorting to chemical-based solutions like dispersants, as dispersants will prolong clean-up efforts and increase the geographic spread of the spill. Additionally, we would like to inquire if bioremediation and bioremediation-accelerator solutions (that herd soluble and insoluble hydrocarbons to the water surface to be naturally degraded by hydrocarbon-consuming bacteria) were considered as part of response measures.

We are aware that oil spills are not an uncommon occurrence in Singapore waters (see Appendix B), and the impacts of these oil spills on our marine and coastal biodiversity could accumulate over time, even after clean-ups have been conducted. As such, the main questions we would like to ask for this section are:

1. What are the monitoring plans in place to track the short-term and long-term cumulative environmental and human health effects of the oil spills?
2. How do agencies decide on the specific type of response measure to be used, and how frequently are these protocols reviewed for efficacy?
3. How are agencies currently studying the short-term and long-term effects of dispersants on the atmosphere and marine environment? How will these impacts be communicated to the public?

4. Use of modelling in oil spill management

During the parliamentary session on 2 July 2024, Mr Melvin Yong Yik Chye (Radin Mas) asked about the effectiveness of the predictive modelling used by MPA when trying to predict movement of oil slicks based on tidal predictions and real-time weather data.

Minister for Transport Chee Hong Tat’s response did not exactly answer the question, only stating that modelling was a part of the multi-pronged approach adopted by MPA, which also included the “old-fashioned way” of using visual sighting of oil slicks, as well as through drone footage and satellite imagery.

However, poor visibility due to weather conditions and the nighttime darkness were cited as reasons for a delayed oil spill response. Effective modelling should have, in theory, enabled prediction of oil slick movement for preemptive action even under those circumstances.

We would therefore like to clarify aspects of the model used by MPA:

1. Which models are used for modelling oil spills? MIKE 21/3 Oil Spill, OILMAPWeb, or other models?
2. How, specifically, was the model used alongside other methods in the management of oil spills?
3. Was the density of oil used in the model the same as that of the spilled oil? How would the use of dispersants affect the density of oil, and would that affect model accuracy?
4. How was the use of dispersants generally accounted for in the model?
5. How accurately does the model predict oil spill movements, and is this accuracy level comparable to other models used internationally?

5. Alternative Fuels

In light of decarbonisation efforts in the shipping industry, alternative fuels such as Liquefied Natural Gas, Ammonia, and Methanol will see an increase in usage and presence in our ports. Given that these fuels have unique chemical properties and would interact differently when spilled, they would require unique approaches and protocols in handling, storage, and removal.

We understand that government agencies have already conducted pilot tests and simulations. Though these efforts are laudable, there has been little communication on the successes of these exercises with the public, as well as the operational and response procedures developed from said exercises.

The risks posed by these novel fuels are varied. Most acutely, an at-sea ammonia spill carries significant risk to human and environmental health. The caustic and corrosive properties of ammonia gas causes burns and irritation when contact is made with skin, eyes, and when inhaled, necessitating the use of full-body encapsulating suits and self-contained breathing apparatus for clean-up personnel. In water, the formation of ammonia hydroxide, even at small concentrations at 1 ppm can be highly toxic in the short term to marine organisms across trophic levels. A long-term consequence of any ammonia spill would be increased eutrophication of the receiving waters, which would cause the continuous degradation of water quality. For reptiles, fish, birds, and marine mammals, exposure to ammonia spills result in physiological damage and mortality at toxic levels. However, there is currently a lack of literature investigating the impacts of ammonia release when used as shipping fuel and the safety regulations, training, and emissions mitigation that will be required to prevent significant impacts to aquatic environments and their constituent species (Environmental Defense Fund). Similar to this allision incident, ammonia spills could occur during bunkering or as the result of damage to ship hulls and fuel tanks. What may differ, however, may be the magnitude of damage wreaked and complexity of clean-up responses required.

Considering the air and water-borne nature of an at-sea ammonia spill, response procedures for novel fuels are highly complicated and specialised (Nanyang Technological University). Therefore, we seek to understand the progress relevant agencies and contractors have undertaken in developing safety protocols and mitigation plans for alternative fuels thus far, and whether said agencies have sufficiently prepared for, and are ready to mobilise in a spill event.

The main questions we would like to ask for this section are:

1. What are the government agencies’ specific risk management plans and procedures in dealing with other types of spills such as alternative, novel fuels and hazardous chemicals?
2. Does the government intend to set up an independent expert panel focused on reviewing the whole incident and how the authorities responded to the said crisis?

Conclusion

The June 14th Oil Spill, while relatively small in comparison to other spills in Singapore’s history, marks a watershed moment. It was the first time a local oil spill went viral on social media, garnering significant public interest and sparking discourse on the policies governing responses to oil spills.

What is certain is that this oil spill will not be the last. What is uncertain is the scale of future oil spills, and if current measures are sufficient to protect our ecosystems then. As highlighted in the introduction, the confluence of both the neap tides and the relatively small volume of oil spilled was an incredible stroke of luck for the local marine environment. Had the tides been different or the volume spilled much greater, our habitats may have suffered much more significant losses.

Therefore, we must not squander this golden opportunity. The time to review existing processes and protocols is now, especially as this remains the most well-documented oil spill in recent history. We commend the agencies for their hard work throughout the process, for continuing to monitor the long-term impacts of oil spills, and for their commitment to involving more stakeholders in crafting policies. We hope to be able to collaborate with the various agencies involved towards a more proactive, inclusive and ecocentric approach to managing oil spills in the future.

It is imperative that we work together to protect our environment, our communities, and our future, especially as environmental stewardship continues to be a major pillar in our governance. We look forward to your prompt response and are prepared to support efforts in better coordinating civic engagement and participation more effectively in face of future oil and any other chemical spills.

Thank you.

Sincerely,

Appendix A: Draft Standard Operating Procedure (SOP) for Active Citizens and Coordinating Public Volunteer Support

Context	Singapore has a network of volunteers eager to assist in oil spill response efforts to protect the environment. Many members of the general public are also willing to help in the event of an environmental crisis. In the event of an oil spill, the general public, including volunteers, should avoid entering areas of direct impact to prevent interference with professional clean-up services and ensure their own safety. However, there are still other ways in which volunteers can play a crucial role in supporting a coordinated response plan if provided with adequate information and effective management.
The following is suggested as a Standard Operating Procedure.
Government Action	Public Communication Invitation for Active and Concerned Public to Contribute Designate and Publicise Helplines: Establish helplines for the public to report incidents. Monitoring and Documentation: Patrol and help to monitor and document observable threats in both affected and unaffected areas and report on any animals who are affected by the oil spill Incident Updates: Provide a webpage for incident updates and support via Facebook, X (previously Twitter), Telegram, and WhatsApp channels. Health & Safety: Emphasise on what the general public can and cannot do What we can do: provide passive support via active biodiversity monitoring, area patrolling to spot potentially threatened wildlife, report sightings of oil spills and affected wildlife to designated helplines What we cannot do: entering premises affected by the oil spill and being in direct contact with the oil slicks found on beaches Cleanup Management Clean-up Timeline and Milestones: Manage the main cleanup operations and provide timely updates and milestones to the public. Live Updates: Actively share about the situation on-ground, communicate options being studied and acknowledge unknowns to ensure full transparency. Health & Safety: Ensure that key operators are donning on personal protective equipment (PPE) to avoid direct contact and exposure to the pollutants.
NGO Action	Coordinate Information Dissemination Report Submission Monitor unaffected/affected shorelines and provide updates using a standardised reporting form. Report mass mortalities or other deaths using a standardised reporting form. Report vertebrate and large animal mortalities to ACRES. Share assessments and insights from specialist volunteers, which could include: Zonal/District heads: Volunteers familiar with sites, access, safety issues, and SOPs. Marine Naturalists: Volunteers experienced in handling and caring for marine organisms, assessing conditions, and familiar with SOPs.

Appendix B: List of Oil Spills in Singapore/Near Singapore (2024-2014)

Date	Location	Type of Spill	Volume of Spill	Reason
14 June 2024	Pasir Panjang Terminal, Singapore	Low-sulfur fuel	400	Allision; rupturing of oil cargo tanks
25 March 2024	Tuas Port, Singapore	Unknown oil slicks	-	Inland pollution
28 June 2023	East Coast Park, Singapore	Crude oil/Sludge Oil Slick	-	Unknown
11 July 2021	14.1 nautical miles southwest of Kuala Sungai (Straits of Malacca), Malaysia	Hydraulic oil	Unknown	Collision
19 July 2017	400m section of the beach was covered with an oil slick; near the Central Thai restaurant and Carpark F2	Unknown	Unknown	Unknown
15 June 2017	4.6 nautical miles off Tanjung Pengelih	Crude oil	Unknown	Exploded and capsized
3 January 2017	Pasir Gudang Port, Johor, Malaysia	Fuel oil	300	Collision
24 August 2016	ATT Tanjung Bin (ATB), Tanjong Pelepas, Johor, Malaysia	Bunker fuel	60	Accident when refueling
26 July 2016	Straits of Malacca off of Tanjung Piai, Malaysia	Heavy fuel oil	1	Leak
12 July 2015	Area C3 East Coast Beach, area near the rock bund and shoreline	Oil slick	unknown	unknown
2 January 2015	20.3km northeast of Pedra Branca, Singapore	Crude oil	4500	Collision
10 February 2014	off Sebarok Island, Singapore	Bunker fuel	80	Collision
30 January 2014	East Keppel Fairway at about 4km south of Marina South	Bunker fuel	400	Collision
29 January 2014	2.7 km, south of Jurong Island	Bunker fuel	280	Collision