In control

In a recent interview with The Crew Report, one captain expressed his concern about the unpredictability of Port State Control (PSC) inspections. “I think one of the scariest things the crew can go through is a Port State Control inspection,” Captain Gary Morton told us. Of one particular occasion, he recounts, “We worked very hard prior to getting the boat there to make sure the paperwork was right and digging back into the history of the vessel. But the problem is that there’s various sides of what they are looking for, whether it’s certification in terms of safety equipment or whether it’s where the boat has been chartering; [whether it's] where we have picked up fuel [or] if we have a charter contract."

Port State Control inspections are those of foreign vessels in national ports to verify that the condition of the vessel and its equipment comply with the requirements of international regulations (SOLAS, MARPOL, STCW and the Maritime Labour Convention, 2006) and that the vessel is manned and operated in compliance with these rules.



Port State Control on yachts is becoming a norm rather than an exception, and as a result Network Marine Consultants has been issuing advice to yachts about how best to prepare and explaining that there is nothing to worry about. “Port State Control in Spain have been intensified this season to include most yachts over 24m and locally, in Palma, quite a few yachts over 24m have been inspected with only one yacht having a problem due to out-of-date certificates,” explains Pat Bullock, managing director. “The inspections are random and unannounced but not aggressive in any way. Most of the captains welcome the inspections as they know they have to be done and are glad to get them out of the way.

“As Port State Control is complementary to Flag State Control, it generally means that when the yacht is in class, it almost automatically complies with the Port State Control requirements,” Bullock adds. “Malta flagged vessels may be scrutinised more closely, as their classification requirements differ from other port states.”

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“Port State inspectors need not announce their arrival, and in many cases, for obvious reasons, they just descend upon the vessel,” Bullock explains, while Captain Morton adds that not knowing the dress of the inspectors makes it harder to identify them. “All Port State inspectors are former active mariners - mainly captains and chief engineers from the commercial shipping world. They are required to examine the vessel to ensure compliance with all four of the conventions, and each takes a slightly different approach.” Network Marine Consultants has provided some examples below of what items are commonly inspected, the duration of the inspection, and attitude of the inspectors, based upon actual experiences of, and including comments from, superyacht captains and officers:

• Crew contracts; "inspectors read them all the way through and commented on repatriation to point of embarkation during a trial period, which I explained. 
• Crew certificates; "inspectors checked certificates for the captain, first officer, second officer, chief engineer and chief stew. They asked for Security Awareness cerftificates and were shown Ship Security Officer [SSO] certificates for two crew. They accepted these but said that they should be in STCW format. I found and showed them MIN 309 (M) which states that holders of SSO certificates may apply for replacements in STCW format. However, they then asked other crew for their Security Awareness certificates; we explained that we have only just started the process of putting crew through this course since it only came into force on 1 January, 2014. They said; ‘No, it came into force [in] 2013 so we should have them by now.’"
• "Inspectors asked for our last passage plan."
• "We had to do a test of water-tight doors, galley fixed fire-extinguishing system alarms and shut-offs."
• "Inspectors made visual inspections of the emergency generator, life rafts and securing methods."
• "Inspectors looked at emergency escapes in [the] master cabin, guest cabin, deck, crew deck and pump room."
• "Inspectors asked to see the guest safety booklet."
• "Inspectors looked into three random crew cabins."
• "Inspectors seemed happy with everything and just noted the lack of Security Awareness training for some crew."
• "Inspectors checked all certification in great detail; our Lloyd’s tonnage certificate had a digital signature, which he wasn't happy with even though, apparently, it's the latest policy from Lloyd's to issue certificates in this way."
• "We had to go dead-ship to test the emergency batteries worked; they wanted us to send a test Digital Service Calling [DSC] and test VHF under emergency power; inspectors wanted to see the radio license; they wanted to see evidence of our shore-based maintenance contract for the coomuncations installation; they wanted us to test the fire pump and hydrants; they wanted us to activate the emergency ventilation shut-off and dampers to the engine room; they checked the position of all safety equipment relative to the fire and safety plan; they checked the Oil Record Book; they wanted us to close the watertight doors; they checked Safe Manning document; they checked all crew certification - make sure you have original copies of STCW certificates and CoCs and they checked charts and publications are up to date."
• "The inspector was on board for approximately four hours and although we had some minor deficiencies, we managed to avoid getting detained."
  

As can be seen from the above, the inspectors are focusing on every aspect of the vessel, and each point can be traced back to ensuring compliance with one of the four conventions. “Port State Control, like MCA [Maritime and Coastguard Agency] inspections and Classification Society Surveys, are high-pressure situations and there will always be something which the inspector notes as a deficiency,” concludes Bullock. “However, the vast majority [of inspectors] have no interest in detaining vessels without very good reason and you will be given a reasonable amount of time to resolve deficiencies. Many yachts are now requesting voluntary Port State Control, and this can be advantageous in that you can have a certain amount of control and can be prepared ahead of time. It is unlikely that Port State Control are able to meet the demands of the entire fleet, however, so the message should be: be prepared.”

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