Does Time Count While a Vessel Bunkers at a Waiting Anchorage?

In London Arbitration 8/08 we saw the tribunal rule that time during which a vessel bunkers at a waiting anchorage (i.e. charterers’ berth is not available) is to count as laytime or as time on demurrage. In making their ruling, the panel concluded that no time was lost as the vessel would not have been able to attend to the berth even had she not been bunkering nor was the ship’s readiness deemed impaired as she was doing what the charterer had ordered her to do; wait at the anchorage.
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