Port State Control Manual

PORT STATE CONTROL ADVICE FOR THE MASTERS AND OFFICERS OF NAFTOTRADE With special emphasis on ISM Code Table of contents 1. General company duties in connection with the ISM Code 2. General duties of the Master 3. General requirements on maintenance 4. Particular requirements on critical equipment 5. Areas of inspection that can lead to detention under the ISM Code 6. The most frequent categories of deficiencies found during PSC inspections 7. Codes and descriptions of defects used by Port State Control (SIRENAC) 8. Information on charterers 9. Initial inspection during concentrated inspection campaigns of the ISM 10. In-depth inspection during concentrated inspection of the ISM 11. Flag categorization according to risk 12. Vessel targeting in Paris MOU and Expanded Inspections 13. Refusal of access to European Union ports 14. Cancellation of refusal of access 15. Naftotrade and PSC inspections record 1. General company duties in connection with the ISM Code • • The company is under obligation to document the duties and responsibilities of staff involved with execution of works, and also of staff involved in the control of proper execution of works related to and affecting safety and environmental protection. The company is under obligation to ensure sufficient resources and assistance are available to the DPA for the execution of his duties. • The company must describe the duties of the various departments and persons involved in safety and environmental protection and also their interrelation, both onboard and ashore. Tables and organograms must be available to Port State control officers on request. 2. General duties of the Master The Master is the key person for the materialization of the requirements of the ISM Code onboard and is the sole person who enjoys the privilege of making decisions outside the framework of the company’s safety management system. The Master is expected to: • • • • • Apply the stated company policy onboard at all times. Mobilize all officers and crew in this direction and particularly in matters affecting safety and pollution prevention Issue clear orders and instructions Make sure the SMS is properly applied onboard Actively participate in reporting of deficiencies and reviews of the SMS. The PSC officer will be interested to see evidence that the Master is acting in a way that promotes the following : • • • • • • • • • • • • • • • Vessel stability and water tightness at all times. Safe navigation Safe practices on deck, accommodation, engineroom Preventive actions aiming at environmental protection Execution of fire and lifeboat drills at appropriate intervals Execution of tests and drills in connection with emergency preparedness (e.g. steering gear tests) Safe lashing/securing of cargo before sailing Precautionary measures in case of dangerous cargo Port entry and departure plans Execution of crew training schedule onboard Proper application of the company policies on consumption of alcohol and drug abuse All necessary corrections on navigation charts Formal reporting in connection with nonconformities, accidents and near misses and crew competence Warranted vessel propulsion and steering Vessel communications in distress situations 3. General requirements on maintenance The company is under obligation to maintain vessels and equipment in accordance with the relevant rules and regulations and additional company requirements, if deemed necessary by the company. In order to satisfy this requirement the PSC inspector will wish to satisfy himself that the following four practices are implemented: a. b. c. d. Inspections are taking place at regular intervals Nonconformities, with root cause –if known- are reported Corrective measures are taken, and All nonconformities are properly recorded. In addition, the PSC officer may wish to inspect the vessel’s register of requisition forms and lists of requisition items received onboard. 4. Particular requirements on critical systems and equipment The company is under obligation to identify systems and equipment onboard the sudden failure of which could create a hazardous situation. The exact itemization of critical equipment rests with the company. However, the PSC inspector may be particularly keen to see that the following indicative systems are subject to proper maintenance and inspections: • • • • • • Main and emergency fire pumps Electricity generators Steering systems Fuel lines Watertight doors Life saving equipment Our own SMS pays particular attention to inspections and checks concerning critical systems and equipment (see Chapter 10 of the SMS Manual). 5. Areas of inspection that can lead to detention under the ISM Code Chapter 1: Missing ISM Manuals or relevant publications. Chapter 3: Senior officers do not know the name of the DPA, or the name of the ship management company, or both. Chapter 6: SMS related documents are in a different working language from that of the SMS, or, in a language not understood by the crew. Chapter 13: Missing ISM certificates Chapter 13: Different company names mentioned in DoC and SMC 6. The most frequent categories of deficiencies found during PSC inspections It is common knowledge that the general areas of lifesaving, firefighting, safety and loadline account for the vast majority of deficiencies. For your guidance we list below the first four most frequent categories of deficiencies found on ships during inspections by Port State Control. Lifesaving 1st Lifeboats 2nd Inventory 3rd Lifebuoys 4th Launching equipment Firefighting 1st Ventilators/Dampers 2nd Fixed installations 3rd Fire pumps 4th Personal equipment General Safety 1st Various 2nd Electrical installations 3rd Emergency lighting 4th Watertight closing devices Engineroom 1st Various machinery 2nd Engineroom cleanliness 3rd Auxiliaries 4th Main engine Loadline 1st Air pipes 2nd Watertight doors 3rd Hatchways 4th Hatch covers Navigation 1st Nautical publications 2nd Charts 3rd Lights/shapes/signals 4th Magnetic compass Pollution prevention 1st Oily water separator 2nd Oil record book 3rd ODMC 4th Oil retention Operational deficiencies 1st Machinery manuals/ instructions 2nd Fire drills 3rd Fire control 4th Abandon ship drills 7. Codes and descriptions used by Port State Control (SIRENAC) The attached lists explain the code numbers used by PSC officers to communicate with the central PSC database in France (SIRENAC). Studying of the explanations of the codes provides an accurate and extensive insight of the areas of concern of PSC officers during inspections. 8. Information on charterers At present the interest of PSC on charterers identity is quite limited and restricted to the type of charterparty used, the type of cargo carried and the charterer’s name and address. 9. Initial inspection concerns during a Concentrated Campaign on ISM During the initial inspection the PSC inspector will need to satisfy himself on the following ten questions. Negative replies to one or more can lead to an in-depth inspection. • Is the ISM Code applicable on this particular ship? The inspector will examine the DoC and the SMC to make sure these refer to the vessel under inspection and are valid. The documents will be invalid in case the company is not certified for the management of the ship type in question, or there are missing renewal inspections. • • • • • • • • • Is ISM certification onboard? The officer will check the names of the vessel and the company on all ISM certificates. Are certificates and particulars in order? In case the vessel carries provisional certification the PSC officer will seek to check these have been issued in accordance with IMO Resolution A.788(19). In the event of a negative answer, the PSC inspector will exercise his professional judgment to proceed to an in-depth inspection. Is SMS documentation readily available onboard? The PSC officer will check that SMS Manuals are available onboard and that officers can identify the management company and the DPA. Is the SMS in a working language or languages understood by the ship’s personnel? Are procedures in place for establishing and maintaining contact with shore management in case of an emergency? Are programmes for drills and exercises to prepare for emergency situations in place? Can the Master provide proof of his responsibilities and authority including overriding authority? Does the vessel have a maintenance routine and records are available? Do detainable deficiencies – if found- indicate a failure of the SMS? This is a key question and relies on two parameters. Firstly, there must be detainable deficiencies. Secondly, the PSC inspector will need to consider if these are serious enough to constitute a failure of the company’s SMS. In the latter case he will have to undertake a more detailed inspection. 10. In depth inspection during an ISM Concentration Campaign. There are no specific rules for the in-depth inspection on a vessel’s ISM compliance and a lot depends on the individual judgment of the inspector. The in-depth inspection covers all the areas of the initial inspection and additional items such as the following: • • • • • How are joining crew members familiarized with their duties before sailing and other important directions? Has the vessel a Planned Maintenance System (PMS) in place ? Have nonconformities, near misses and accidents been reported to the management company without undue delay? Are valid documents available at all relevant locations, changes to documents are reviewed and approved and old documents removed? Have internal audits taken place as per SMS requirements? ( Please be advised that PSC officers should not normally scrutinize the contents of nonconformity notes following internal audits). 11. Flag categories according to risk The most recent categories shown in the Port State Control Annual Report for the year 2002 are the following: • Black List Very high risk flags (15) High risk flags (3) Medium high risk flags (7) • Grey List (29) • White List (26) Vessels flying blacklisted flags are in high risk for banning from EU ports following multiple detentions ( See Sections 13 and 14 ) 12. Vessel targeting in Paris MOU and Expanded Inspections Ta r ge t Fa ct or Ca lcu la t or By a n sw e r in g t h e qu e st ion s t h e t a r ge t fa ct or for a ce r t a in ve sse l ca n be de t e r m in e d. Th e ou t com e of t h is ca lcula t ion doe s n ot in dica t e a n yt h in g a bou t t h e qu a lit y of a sh ip. Th e Ta r ge t Fa ct or is in u se w it h in t h e Pa r is M OU on PSC a s a t ool for se le ct in g sh ips e ligible for a n in spe ct ion on ly pdf t he calculat ion of t he Target Fact or is divided in t wo part s: Ge n e r ic fa ct or - based on elem ent s of t he ships profile H ist or y fa ct or - based on t he ships inspect ion hist ory in t he Paris MOU. The generic fact or is updat ed when t he part iculars of t he ship change or t he st at us of it s exist ing flag or class change. The hist ory fact or is updat ed at t he end of each day. Ta r ge t e d Fla g On annual ParisMOU black list Medium risk Medium t o high risk high risk Very high risk Point s: EU r e cogn ise d cla ssifica t ion socie t y Click for a list of recognised classificat ion societ ies Yes No Point s: Ta r ge t e d sh ip t ype I s t he vessel a : Bulk Carrier m ore t han 12 years old, a Gas Carrier m ore t han 10 years old, a Chem ical Tanker m ore t han 10 years old, an Oil Tanker > 3000gt and > 15 years old or a Passengership/ Ro- Ro ferry? Yes No Point s: Sh ips m or e t h a n 1 2 ye a r s old graduat ed for non- t arget ed ship t ypes ( ref. above) and passenger ships Age: > 25 years 21- 24 years 13- 20 years Point s Fla g st a t e h a s r a t ifie d a ll con ven t ion s ( ref. relevant inst rum ent s in Paris Mem orandum t ext , rat ificat ion inform at ion can be found on Yes No www.im o.org & www.ilo.org ) Point s: Cla ss de ficie n cy r a t io a bove a ve r a ge as ident ified in MOU annual st at ist ics 0% or less 0% - 2% 2% - 4% 4% or m ore Point s En t e r in g a r e gion por t for t h e fir st t im e in t h e la st 1 2 m on t h s Yes No N ot in spe ct e d in la st 6 m on t h s Yes No Point s D e t a in e d du r ing pa st 1 2 m on t h s No Once Twice Three Tim es Point s N u m be r of de ficien cie s pe r in spe ct ion du r in g t h e la st 1 2 m on t h s Click t o calculat e t he t ot al point s for t his cat egory Point s Ou t st a n din g deficie n cie s fr om la st in spe ct ion The value for t he out st anding deficiencies is applied only in respect of t he lat est inspect ion - for each list ed act ion t aken" rect ify deficiency at next port " or " m ast er inst ruct ed t o rect ify deficiency befor e depart ure" and for every t w o list ed act ion t aken " rect ify deficiency wit hin 14 days" and/ or " ot her ( specify in clear t ext ) add 1 point - I n case "all deficiencies rect ified" is not ed on t he report deduct 2 point s Point s Ta r ge t Fa ct or Vessels are targeted for priority inspections by PSC authorities on basis of the following scale: • • • • • 0-17 points: Low priority 18-24 points: Lower priority 25-34 points: Medium priority 35-50 points: High priority 51+ points: Very high priority Masters are encouraged to calculate the targeting factor of their vessels frequently and make sure this information is passed on to the relieving master during handover. Four types of vessels are subject to yearly mandatory expanded inspections. These are : • • • • Oil tankers above 3,000 GT and over 15 years of age Bulk carriers above 12 years of age Passenger vessels not subject to Directive 1999/35 and over 15 years of age, and Gas and Chemicals carriers over 10 years of age 13. Refusal of access to EU ports (Banning ) Since July 2003 all EU member states are under obligation to ban from their ports vessels which have failed to satisfy one or more of the following requirements: • • • • • Vessels without ISM certification Vessels that have sailed without port authority’s permission Vessels that have not complied with conditions imposed before sailing Vessels flying flags included in the black list which have been detained more than twice in the last 24 months, or Vessels with flags appearing in the “very high risk”, or “high risk” categories which have been detained more than once during the last 36 months. Thirty days are allowed for the rectification of deficiencies at the next port. Banning takes effect immediately after the last critical detention and the banned ships list is renewed every six months. 14. Cancellation of refusal of access Before refusal of access is lifted the vessel must be reinspected to ensure that it complies with all applicable requirements of the Conventions. During the period that the vessel is banned from calling at EU ports, it may still be allowed access in the events of: • Force majeure, or • Overriding safety considerations, or • To reduce or minimize the risk of pollution, or • To have deficiencies rectified, On provision that adequate measures have been taken –to the satisfaction of the competent authority of such state – by the owners/operator/master to ensure safe entry. Before refusal of access is lifted, the vessel will need to be re inspected jointly by the two authorities ( the one that has imposed the banning and the one seeking to lift it) and adequate notice is required. All costs will need to be covered by the vessel. There is no limitation to the above procedure. 15. Naftotrade and Port State Control inspections’ record Naftotrade records and follows up all deficiencies found during PSC inspections of its vessels. While all departments take an interest in the findings of such inspections, including the Managing Director, the three principal departments are those of Marine and Operations, Technical and ISM. The performance of individual vessels during PSC inspections are regularly reviewed during Safety Meetings and the performance of individual officers in this regard is assessed during staff performance evaluations. Shore staff is under constant pressure from the Managing Director to ensure good shows in PSC inspections and the overall performance of the company regarding Port State Control becomes object of assessment once a year. Finally, Naftotrade, its management team and its agents are committed to providing every possible assistance to masters and vessels to achieve good inspection results and are open to all suggestions from masters and officers to the same end.