Port State MOUs to bring yachts under greater scrutiny this Autumn
Inspections focused on MARPOL Annex I and SOLAS' chapter on safety of machinery launch from September. Capturing the fleet in European as well as Caribbean waters, yachts could be caught out if oil log book keeping and safety procedures are not up to scratch.…
Several Memorandum of Understanding bodies (MOUs) on Port State Control are launching concentrated campaigns that could catch out yachts either exiting the Med this summer, or arriving in the Caribbean for the start of the winter season.
First is the joint Concentrated Inspection Campaign (CIC) comprising Paris, Tokyo, Indian Ocean and Black Sea MOUs on Port State Control, which will target compliance with SOLAS Chapter II-1. This regulation, which deals with the safety of machinery maintenance and operation will be the focus of checks from 1 September, ending on 30 November. The timing coincides with the Caribbean’s own CIC, this one dealing with MARPOL Annex I, the legislation corresponding to matters including oil record book keeping and maintenance of oily water separators.
Yacht managers and registries say there is no need for undue worry as yachts should already be compliant under their auspices. Nevertheless, there are areas where yachts have been caught out in the past, and are therefore advised to double-check for compliance now.
“The oil record book is a regular deficiency for yachts. Engineers must be especially careful to log all movements of oil to account for every single drop,” said Jake DesVergers at International Yacht Bureau (IYB). “If the entries in the oil record book do not correspond to bunker delivery receipts, Port State Control will think that something is wrong. That's when the real fun starts. People have gone to jail for false oil record book entries.”
The MARPOL Annex I CIC by the Caribbean Memorandum of Understanding (CMOU) will investigate yachts for operability of oil filtering equipment systems and the arrangements for handling sludge. Inspectors will measure, for example, whether sludge has been discharged into port reception facilities, mixed with fuel or handled using other alternative arrangements. Port State Control officers will be issuing a 12-point questionnaire to assess these mechanisms.
“Any yacht that is equipped with an oil and water separator, for example, needs to be correctly locked off, certified and maintained. We’ve seen some yachts in the past that aren’t as rigorous in this as they ought to be,” commented Daniel Taylor at Andrew Weir Yacht Management.
The SOLAS Chapter II-1 CIC pertaining to the fleet in European waters focuses on safety of propulsion and auxiliary machinery. This will assess the working order and maintenance of the main engines, auxiliary engines, auxiliary equipment and their related alarm systems. “Special attention will be given to crew familiarity with safety and emergency procedures,” states the Lloyd's Register notification on the CIC.
In a separate article on the CIC, Lloyd's goes on to specify that Port State inspectors could well examine the “cleanliness of machinery spaces and [whether] spare part inventories are up to date – a requirement under the international ship management code.”
Whilst inspections are nothing for yachts with good management to be concerned about – as Taylor and DesVergeres both attested - and is perhaps of more concern for yachts without shore based management. But it does give increasingly confrontational European authorities another reason to look for fault, should they wish to find it:
“Authorities are itching for ways to [stop] vessels at the moment. Italians are particularly [pedantically] attentive with the application of the rules. I’m sure the French and Spanish are just as bad if they go on board,” said Taylor.
Port State Control was the focus of the Superyacht Management Meeting in Barcelona this Spring. Industry discussed which Ports were most likely to detain superyachts and other key issues. Download the transcript here from SuperyachtEvents.com
First is the joint Concentrated Inspection Campaign (CIC) comprising Paris, Tokyo, Indian Ocean and Black Sea MOUs on Port State Control, which will target compliance with SOLAS Chapter II-1. This regulation, which deals with the safety of machinery maintenance and operation will be the focus of checks from 1 September, ending on 30 November. The timing coincides with the Caribbean’s own CIC, this one dealing with MARPOL Annex I, the legislation corresponding to matters including oil record book keeping and maintenance of oily water separators.
Yacht managers and registries say there is no need for undue worry as yachts should already be compliant under their auspices. Nevertheless, there are areas where yachts have been caught out in the past, and are therefore advised to double-check for compliance now.
“The oil record book is a regular deficiency for yachts. Engineers must be especially careful to log all movements of oil to account for every single drop,” said Jake DesVergers at International Yacht Bureau (IYB). “If the entries in the oil record book do not correspond to bunker delivery receipts, Port State Control will think that something is wrong. That's when the real fun starts. People have gone to jail for false oil record book entries.”
Oil record book keeping will be a focus of the MARPOL Annex I inspection campaign
The MARPOL Annex I CIC by the Caribbean Memorandum of Understanding (CMOU) will investigate yachts for operability of oil filtering equipment systems and the arrangements for handling sludge. Inspectors will measure, for example, whether sludge has been discharged into port reception facilities, mixed with fuel or handled using other alternative arrangements. Port State Control officers will be issuing a 12-point questionnaire to assess these mechanisms.
“Any yacht that is equipped with an oil and water separator, for example, needs to be correctly locked off, certified and maintained. We’ve seen some yachts in the past that aren’t as rigorous in this as they ought to be,” commented Daniel Taylor at Andrew Weir Yacht Management.
Engines will be inspected for compliance with SOLAS II-1 under the Europe wide CIC
The SOLAS Chapter II-1 CIC pertaining to the fleet in European waters focuses on safety of propulsion and auxiliary machinery. This will assess the working order and maintenance of the main engines, auxiliary engines, auxiliary equipment and their related alarm systems. “Special attention will be given to crew familiarity with safety and emergency procedures,” states the Lloyd's Register notification on the CIC.
In a separate article on the CIC, Lloyd's goes on to specify that Port State inspectors could well examine the “cleanliness of machinery spaces and [whether] spare part inventories are up to date – a requirement under the international ship management code.”
Whilst inspections are nothing for yachts with good management to be concerned about – as Taylor and DesVergeres both attested - and is perhaps of more concern for yachts without shore based management. But it does give increasingly confrontational European authorities another reason to look for fault, should they wish to find it:
“Authorities are itching for ways to [stop] vessels at the moment. Italians are particularly [pedantically] attentive with the application of the rules. I’m sure the French and Spanish are just as bad if they go on board,” said Taylor.
Port State Control was the focus of the Superyacht Management Meeting in Barcelona this Spring. Industry discussed which Ports were most likely to detain superyachts and other key issues. Download the transcript here from SuperyachtEvents.com
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