Tuesday, 30th August 2011
Concentrated Inspection Campaign - Vina Del Mar
Correspondents Brazil P and I have advised in their latest circular that foreign vessels entering Brazilian ports between 01 September and 30 November 2012 will be subject to a Concentrated Inspection Campaign under the Vina Del Mar agreement.
As with the CIC being conducted in Paris and Tokyo MOUs the focus will be on structural safety and load lines in order to verify compliance with the International Convention on Loadlines, 1966.
New joint Concentrated Inspection Campaign (CIC)
During the 44th meeting of the Paris Memorandum of Understanding (Paris MOU), the committee agreed that a new concentrated inspection campaign (CIC) focusing on structural safety and the Load Line Convention will be carried out from 1 September to 30 November 2011. This CIC is to be run jointly with the Tokyo Memorandum of Understanding.
A further joint CIC between the Paris and Tokyo MOU's on Fire Safety Systems (FSS) has been scheduled to run from September to November 2012.
Click here for Paris MOU press release.
Click here for the Tokyo MOU press release.
15 February 2011: USCG - Vessel General Permit as part of PSC Inspection
From the 13 March 2011 the USCG will begin checking vessels to ensure compliance with the VGP programme as part of their routine vessel inspections and port state control inspections.
For further information please click here for an advisory from Patriot Maritime Compliance and here for the USCG policy letter concerning VGP Inspections. The latter may be particularly useful in preparing for an inspection.
SPANISH PSC
Correspondents, Hispania PandI, have produced a briefing note that outlines the current law and gives a brief overview of the procedure and practice in relation to Port State control inspections and fines in Spain.
Click here for the briefing note.
FUEL OIL QUICK-CLOSING VALVES
USCG port State control inspections are finding fuel oil quick-closing valves intentionally blocked, modified, and poorly maintained preventing them from operating as designed during an emergency.
Fuel oil quick-closing valves are positive shutoff valves on fuel oil systems to isolate fuel tanks in the event of an emergency. These valves are designed to be remotely operated so a situation where they are rendered inoperable is hazardous for the crew and the ship.
Proper routine maintenance and in some cases approved modifications and/or replacement of components may be necessary to ensure reliability of the remote operation and closure of the valve. Fittings for testing remote closure without cutting of fuel supply should only be used as intended.
USCG recommendations for port State control inspections include:
- Ships engineers should be able to explain maintenance requirements
- Operational test and maintenance records should be available
- Ships engineers should be able to describe how to test and reset the valves
All crew should be aware of the need for fuel oil quick-closing valves and how to operate these valves remotely if instructed to do so.
Click here for the full USCG Safety Alert 01-11 Inspection of fuel oil quick-closing valves.
Paris MOU - New Inspection Regime - 2 Weeks Away
With the implementation of the NIR now just two weeks away Paris MOU have issued a press release that outlines the workings of the system.
NIR press release 14 December.
Paris MOU - New Inspection Regime - 2 Months Away
Members are reminded that the existing Paris Memorandum of Understanding on Port State Control (Paris MOU) inspection regime will be replaced by the New Inspection Regime (NIR) on 1 January 2011.
The system introduces several new features and moves the Paris MOU away from the current quota based system (25% of foreign flagged vessels to be inspected) towards a more refined targeting system based on ship and company risk profiles.
To enable the targeting system to function from the 01 January 2011 Paris MOU have been collating port state control inspection data from June 2009. This data will be ‘live' from the 01 January.
Ship Risk Profile
Paris MOU has developed a ship-risk profile calculator that will categorise ships as either high risk ships (HRS), standard risk ships (SRS) or low risk ships (LRS). Vessels will then be inspected at intervals associated with their risk category
HRS - inspection interval 6 months
SRS - inspection interval 10-12 months
LRS - inspection interval 24-36 months.
There is a clear benefit to Members for having ships in the LRS category. The NIR awards points to vessels based on ship type, age, flag state and flag state auditing, performance of flag state recognised organisations (RO), whether or not the RO is EU recognised and the company's ISM Code performance. The vessel port state history in the last 36 months is also taken into account.
Company Risk Profile
The company risk profile is calculated by averaging the number of deficiencies and detentions per Paris MOU inspection and benchmarking this across all Paris MOU inspections within the period.
Banning
Banning may occur where ships are detained. The rules surrounding banning are: -
Grey list flags - 2 detentions in 24 months period tolerated - any subsequent detention will lead to a ban.
Black list flags - 2 detentions in 36 months period tolerated - any subsequent detention will lead to a ban.
White List flags - the above banning rules do not apply.
It should be remembered that detentions since June 2009 will count. So for example, if a black list vessel has suffered two detentions since June 2009 these detentions will count towards a ban should the vessel be detained again within 36 months of the first detention.
Obviously any ban is likely to have adverse commercial implications for the vessel owners.
Of particular note to Members who may be considering the purchase of vessels is the fact that a vessel's record follows it to a new owner. As such a vessel's Paris MOU record should be closely scrutinised before purchase to ensure that it is not already subject to a ban, or has an otherwise poor record that may lead to a ban should it be detained again.
The first ban will be for a minimum period of three months. If a second ban is imposed this will be for a minimum period of 12 months and any subsequent ban will permanently expel a vessel from the Paris MOU. The banning rules are also applicable to any vessel that jumps a detention or fails to call at an agreed repair yard.
The New Inspection Regime seems to be designed both to reward vessels with good PSC records, white list flags and high scoring ROs and to encourage shipowners trading to Europe to consider switching to such flags and ROs.
Members can get an early indication of how their vessels may be categorised by the NIR by visiting the Paris MOU website and calculating both their individual vessel risk category and their company performance:
www.parismou.org/ParisMOU/New+Inspection+Regime/default.aspx
Click here for more information on the NIR.
Click here for a European Maritime Safety Agency presentation on the NIR.
USCG - Banning of Foreign Vessels
The USCG has introduced a new policy that seeks to ban vessels they consider to be substandard from entering ports under US jurisdiction.
Where a vessel has been detained by USCG three times within a twelve month period, any subsequent inspection is likely to give rise to an ISM expanded inspection should the PSCO have clear grounds to believe the SMS has not been properly implemented.
Click here for more information....
1 October - Riyadh MOU Concentrated Inspection Campaign (CIC) on Safety of Navigation - SOLAS Ch.V
The 6 Maritime Authorities of the Riyadh-Memorandum of Understanding (RMoU) on Port State Control will start a concentrated inspection campaign focusing on compliance with SOALS Chapter V - Safety of Navigation. The inspection campaign will last 3 months, ending on 31 December 2010.
Click here for more information...
UK Gets Tough on Hours of Rest
The contribution of seafarer fatigue to many incidents has been highlighted by the MAIB in recent investigation reports. It appears that the MCA have taken note and will be inspecting vessels visiting UK ports to ensure that hours of work requirements are being complied with.
The inspections will primarily be targeted at vessels with busy schedules and small crews. The inspections will compare the hours of rest records to vessel operating patterns in order to verify their accuracy. Evidence of company audits of the records will also be sought.
Significant breaches of the regulations may result in prosecution by the MCA enforcement unit.
Click here for the MCA press release.
Useful Resources
USCG - Marpol Annex VI Inspection Guidelines
Blanking of Bilge Discharge Piping Systems in Port
Australia - vessel criteria for port sate control
IMO - "Code of good practice for port State control officers"
US - Examination, Investigation or Boarding? USCG
Guidance on the management of Port State Control inspections
BIMCO Guide to prepare for Port State Control inspections in the USA
