Mark Robinson Maritime Consultants’ (MRMC) pre season checklist addresses common issues that arise when inspected by Port State Control. With the season fast approaching, you can plan for a problem free year for the yachts you either manage, operate or command by following the tools or information provided, so that you don’t get ‘caught in the net’ (Paris MOU speak).
According to the Paris MOU website, 238 yachts were inspected in the latest yearly figures resulting in 381 deficiencies with 42 detainable deficiencies being noted by PSC Officers*. The results were much the same as last year with the top 5 deficiencies being:
Certificates & Documentation – Documents: 60 deficiencies
Certificates & Documentation – Ship Certificates: 59 deficiencies
Safety of Navigation: 51 deficiencies
Certificates & Documentation – Crew Certificates: 49 deficiencies
Fire Safety (various): 28 deficiencies
1. Certificates & Documentation – Documents:
Most deficiencies were issued on Garbage Record Books, Oil Record Books, SOPEPs and Records of Rest hours;
MEPC.1/Circ.736/Rev.2 can really help the Chief engineer and Captain get to grips of what is now expected as correct entries (and format) in the Oil Record Book – there are some really good examples and it goes into further detail than the coded page at the front of the book. Have a copy either stapled to the front cover or keep a copy with the ORB.
SOPEPS usually have an annex in the back recording oil pollution exercises; complete every time you undertake one, or make a statement that the records are held elsewhere; The National Contact Points, currently MSC-MEPC.6/Circ.15 is the extant version (31 December 2016).
There was a concentrated inspection campaign (MLC, 2006) running from September last year – make sure that you have a copy of the regulations, if you are running a simple spreadsheet, so that you do not fall foul of the rest requirements. Have a tool box talk with all crew so that they understand what needs to be entered.
Receipts are hard to come by when discharging garbage ashore – make up yacht specific receipts and get the official (or someone that has a level of management that will be willing) to sign one; they will be more amenable to do this than providing their own.
2. Certificates & Documents – Ships Certificates:
Continuous Synopsis Records, Cargo Ship Safety Radio Certificates, Tonnage Certificates, Minimum Safe Manning Certificates;
Check that the issue number/amendment is correct and that all details are up to date on the CSR. Speak with your Flag Administration if you believe the issue number is not correct. A 23/Res.959 gives excellent guidance for the maintenance of the Continuous Synopsis Record. It has been known that an incorrectly recorded CSR will possibly result in a detention.
3. Safety of Navigation:
Nautical Publication, Charts, Voyage Planning, AIS, Magnetic Compasses;
Passage planning is weak. If you don’t have it, buy the publication 'Bridge Procedures Guide' and refer to IMO Resolution A.893(21) – guidelines for voyage planning. Chart corrections is also a weak area; depending on your chart outfit and solution for the correction of charts and nautical publications, go through the whole outfit – assess any gaps, correct and be ready for the season. In most cases, Flag states/PSCOs will accept 3 weeks’ corrections in arrears. Check the AIS is correctly programmed and logged when switched off. The Standard Compass should have an in date deviation card associated with it – 2/3 years is acceptable. Remember that a spare Compass (that can be swapped out with the Standard Compass) must be readily available.
4. Certificates & Documentation – Crew Certificates:
Endorsements by Flag, Certificates for Master and Officers, SEAs, Application for Endorsements;
MLC, 2006 is still relatively new – some SEAs are left wanting for more information as dictated by the Convention. Make sure they are signed by the seafarer and that they have a copy.
Flag state CoC endorsements are important. Make sure that the CoC is recognised by a Flag state that you are sailing under but not necessarily the Flag state which your CoC originated from.
5. Fire Safety (various):
Means of Escape, firefighting equipment, fire detection systems, ready availability of firefighting equipment;
Perform a husbandry check and make sure the means of escape are not blocked by stores or furniture/carpet – check the signage is in place. Perhaps blindfold a few crew and see how they perform in finding the exits (and charter guests for that matter); adopt a 20% smoke/heat detector test every week. BA sets are usually still found in their bags without being suitable for the wearer in a hurry. Stow the sets so that the time to don the suits and BA sets is reduced, the kit fits the wearer and that the crew and BA controller knows how to perform a face seal check.
With these few ideas you could be drastically reducing the risk of being under additional scrutiny when the PSC officers come knocking.
*We have relied upon the statistics that are publically accessed on the Paris MOU website and this always provides food for thought as to what is being missed or not managed, checked correctly.
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