Port State Control Inspections. Athens, Greece, 2 nd February 2018 Capt. Simon Rapley

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1 Port State Control Inspections Athens, Greece, 2 nd February 2018 Capt. Simon Rapley

2 Introduction Capt. Simon Rapley Loss Prevention Manager, West of England P&I, London Master Mariner, former Captain What we will be covering: Port State Control Brief Overview Paris MOU Inspection Regime Concentrated Inspection Campaigns Facts and Figures

3 Port State Control IMO William O Neill It is the duty of Governments to make sure that ships which fly their flags comply with the standards laid down in the IMO treaties which they have ratified. If they fail to do so, then IMO - which has the stewardship of these standards - has not only the right but the obligation to take further action

4 Port State Control IMO Inspection Rationale...to provide assistance to flag state administrations in securing compliance with convention provisions...

5 Port State Control IMO Procedures for Port State Control Substandard Ship A ship whose hull, machinery, equipment or operational safety is substantially below the standards required by the relevant convention or whose crew is not in conformance with the safe manning document

6 Port State Control IMO Procedures for Port State Control First Impressions A PSCO may. before boarding gain, from its appearance in the water, an impression of (the ship s) standard of maintenance from such items as the condition of its paintwork, corrosion or pitting or unrepaired damage

7 Port State Control IMO Procedures for Port State Control On boarding. the PSCO should examine the vessel s relevant certificates and documents

8 Port State Control IMO Procedures for Port State Control If the certificates are valid and the PSCO s general impression and visual observations on board confirm a good standard of maintenance, the PSCO should generally confine the inspection to reported or observed deficiencies, if any

9 Port State Control IMO Procedures for Port State Control If the PSCO from general impressions or observations on board has clear grounds for believing that the ship, its equipment or its crew do not substantially meet the requirements, the PSCO should proceed to a more detailed inspection

10 Port State Control Clear Grounds Statutory certificates missing or invalid Absence of principal convention equipment Logs and other documentation not properly maintained Defective safety, anti-pollution or navigational equipment Serious hull or structural deterioration Crew unfamiliar with essential shipboard operations Crew unable to communicate with each other effectively Muster list or fire control plan not up to date False distress alert not properly cancelled Report or complaint that ship is substandard

11 Port State Control IMO s Inspection Guidelines (If the) inspection is initiated based on a report or a complaint, especially if it is from a crew member, the source of information should not be disclosed

12 Port State Control IMO Procedures for Port State Control Detention It should be borne in mind that the main purpose of Port State Control is to prevent a ship proceeding to sea if it is unsafe or presents an unreasonable threat of harm to the marine environment

13 Port State Control IMO Procedures for Port State Control Significant areas of damage or corrosion Failure of essential machinery and equipment Stability considered to be inadequate Insufficient cleanliness of engine room Deficient emergency alarm systems Charts & publications uncorrected for intended voyage Draft marks impossible to read Those designated for first sea watch insufficiently rested Unlikely to perform forthcoming voyage safely

14 Detainable Deficiencies Examples

15 Detainable Deficiencies Examples

16 Paris MOU New Inspection Regime

17 Paris MOU Port State Control Inspections governed by Paris MOU 1982 Countries were required to check 25% of visiting ships Non-discriminatory Inspections subsequently prioritised Efforts by Paris MOU to name & shame

18 Paris MOU Port State Control Inspections governed by Paris MOU 1982 Countries were required to check 25% of visiting ships Non-discriminatory Inspections subsequently prioritised Efforts by Paris MOU to name & shame Further action by EU after Erika & Prestige

19 Paris MOU Port State Control Inspections governed by Paris MOU 1982 Countries were required to check 25% of visiting ships Non-discriminatory Inspections subsequently prioritised Efforts by Paris MOU to name & shame Further action by EU after Erika & Prestige New Inspection Regime since 1 January 2011

20 Paris MOU New Inspection Regime (NIR) 25% inspection scheme scrapped NIR aims to: - reward responsible operators - monitor ships in poor condition more closely NIR is a risk-based targeting system: - high risk ships to be inspected more often - low risk ships to be inspected less frequently New reporting requirements introduced

21 EU Reporting Requirements As from 1 January 2011 ETA to port authority at least 24 hrs before arrival Prescribed by Directive 2009/16/EC: - actual time of arrival (ATA) - actual time of departure (ATD) - 72 hrs notification to be given by: (a) ships subject to an expanded inspection (b) passenger ships, tankers and bulkers over 12 yrs old (c) ships with a high risk profile

22 EU Reporting Requirements As from 1 January hrs notification to include: - ship identification (eg name, call sign, IMO number) - planned duration of call (ETA/ETD) - additional information for tankers: (a) hull type (eg, single, double, single with SBTs) (b) cargo/ballast tanks condition (eg full, empty, inerted) (c) volume/type of cargo - planned ops at destination (eg loading, unloading, other) - planned statutory surveys, maintenance and repairs - date of last expanded inspection in Paris MOU region

23 New Inspection Regime (NIR) Ship Risk Profile Generic Factors: - type of ship - age of ship - flag - recognised organisation - company + Historical Factors: - deficiencies - detentions High Risk Ship (HRS) Standard Risk Ship (SRS) Low Risk Ship (LRS)

24 New Inspection Regime (NIR) High Risk Ship Score of 5 points or more Oil, Gas & Chemical Tankers, Bulk Carriers, Passenger Ships Ships older than 12 years Black Flag (Very High Risk, High Risk, Medium to High Risk) Black Flag (Medium Risk) 2 points 1 point 2 points 1 point

25 Paris MOU List of Black Flags

26 New Inspection Regime (NIR) High Risk Ship Score of 5 points or more Oil, Gas & Chemical Tankers, Bulk Carriers, Passenger Ships Ships older than 12 years Black Flag (Very High Risk, High Risk, Medium to High Risk) Black List (Medium Risk) Recognised Organisation with Low or Very Low performance 2 points 1 point 2 points 1 point 1 point

27 Paris MOU ROs with Very Low or Low Performance

28 New Inspection Regime (NIR) High Risk Ship Score of 5 points or more Oil, Gas & Chemical Tankers, Bulk Carriers, Passenger Ships Ships older than 12 years Black Flag (Very High Risk, High Risk, Medium to High Risk) Black List (Medium Risk) Recognised Organisation with Low or Very Low performance Two or more detentions within the previous 36 months 2 points 1 point 2 points 1 point 1 point 1 point

29 Paris MOU Equasis

30 New Inspection Regime (NIR) High Risk Ship Score of 5 points or more Oil, Gas & Chemical Tankers, Bulk Carriers, Passenger Ships Ships older than 12 years Black Flag (Very High Risk, High Risk, Medium to High Risk) Black List (Medium Risk) Recognised Organisation with Low or Very Low performance Two or more detentions within the previous 36 months Company with Low or Very Low performance 2 points 1 point 2 points 1 point 1 point 1 point 2 points

31 New Inspection Regime (NIR) Low Risk Ship Flag on the White List

32 Paris MOU List of White Flags

33 New Inspection Regime (NIR) Low Risk Ship Flag on the White List Flag is IMO audited

34 Flags Meeting Criteria for a Low Risk Ship Antigua & Barbuda Greece Bahamas Hong Kong, China Belgium Ireland Bermuda (UK) Isle of Man (UK) Cayman Islands (UK) Italy China (PRC) Japan Croatia Korea, Republic of Cyprus Latvia Denmark Liberia Estonia Luxembourg Faroe Islands Malta Finland Marshall Islands France Netherlands Germany Norway Gibraltar (UK) Panama Portugal Russian Federation Singapore Spain Sweden Turkey United Kingdom United States of America

35 New Inspection Regime (NIR) Low Risk Ship Flag on the White List Flag undergone Voluntary IMO Member State Audit (VIMSA) Recognised Organisation with High Performance and EU recognition

36 New Inspection Regime (NIR) Low Risk Ship Flag on the White List Flag undergone Voluntary IMO Member State Audit (VIMSA) Recognised Organisation with High Performance and EU recognition No detentions within previous 36 months Not more than 5 deficiencies (and at least 1 inspection) in last 36 months

37 New Inspection Regime (NIR) Low Risk Ship Flag on the White List Flag undergone Voluntary IMO Member State Audit (VIMSA) Recognised Organisation with High Performance and EU recognition No detentions within previous 36 months Not more than 5 deficiencies (and at least 1 inspection) in last 36 months Company with High Performance

38 New Inspection Regime (NIR) Standard Risk Ship A ship which is neither High Risk nor Low Risk

39 New Inspection Regime (NIR) Company Performance Deficiency Ratio Company s Fleet: Total number of deficiencies* in last 36 months Company s Fleet: Total number of inspections in last 36 months (* 5 points for each ISM deficiency, 1 point for each non-ism deficiency)

40 New Inspection Regime (NIR) Non-ISM Deficiency A non-ism deficiency is any deficiency not directly related to the provisions of the ISM Code. Such deficiencies could be related, but are not limited to: technical, operational or environmental requirements; certification and documentation; or working and living conditions on board. The convention reference for such deficiency does not refer to the ISM Code

41 New Inspection Regime (NIR) Company Performance Deficiency Ratio Company s Fleet: Total number of deficiencies* in last 36 months Company s Fleet: Total number of inspections in last 36 months (* 5 points for each ISM deficiency, 1 point for each non-ism deficiency) Detention Ratio Company s Fleet: Total number of detentions in last 36 months Company s Fleet: Total number of inspections in last 36 months

42 New Inspection Regime (NIR) Company Performance Vessel months ago 1 Inspection Def: 1 ISM, 2 Non ISM months ago Not inspected 0-12 months ago Not inspected Points 7 Det 0 Vessel 2 1 Inspection Def: 0 ISM, 1 Non ISM 1 Inspection Def: 1 ISM, 3 Non ISM DETAINED Vessel 3 Not inspected Not inspected Not inspected 1 Inspection Def: 0 ISM, 0 Non ISM Vessel 4 Not inspected 1 Inspection Def: 1 ISM, 1 Non ISM Not inspected 6 0 Deficiency Ratio: 22 points/5 inspections Detention Ratio : 1 detention/5 inspections = 20% = 4.4 points per inspection 22 1

43 New Inspection Regime (NIR) Company Performance Below Average Deficiency Index Paris MOU Average Above Average 0.94 (-2) 2.94 (+2) 4.94 Deficiency Ratio: 22 points/5 inspections = 4.4 points per inspection Below Average Detention Index Paris MOU Average Above Average 1.45% (-2%) (+2%) 3.45% 5.45% Detention Ratio : 1 detention/5 inspections = 20%

44 New Inspection Regime (NIR) Company Performance Matrix Detention Index Deficiency Index Company Performance Above Average Above Average Above Average Average Below Average Average Average Below Average Below Average Above Average Average Below Average Above Average Above Average Average Below Average Average Below Average Very Low Low Low Low Low Medium Medium Medium High

45 New Inspection Regime (NIR) High Risk Ship Score of 5 points or more Chemical tankers, gas carriers, oil tankers, bulk carriers, passenger ships Ships older than 12 years Flag on the Black List (Very High Risk, High Risk, Medium to High Risk) Flag on the Black List (Medium Risk) Recognised Organisation with Low or Very Low performance Two or more detentions within the previous 36 months 2 points 1 point 2 points 1 point 1 point 1 point Company with Low or Very Low performance 2 points

46 New Inspection Regime (NIR) Inspection Frequency - Periodic Inspections High Risk Ship (HRS) Standard Risk Ship (SRS) Low Risk Ship (LRS) Window months months months Ships available within window Ships not inspected within window Priority II May be inspected Priority I Must be inspected

47 New Inspection Regime (NIR) Additional Inspection - Priority I - Other Triggers Overriding Factors - Examples Ships reported by another Member State Collision, grounding or stranding Discharge of harmful substances or effluents Erratic or unsafe manoeuvring Class suspended/withdrawn for safety reasons Ships not identified in EMSA s Thetis database

48 New Inspection Regime (NIR) Additional Inspection - Priority II - Other Triggers Unexpected Factors - Examples Outstanding deficiencies Previously detained (after 3 months) Complaint Cargo problems Entrance to Baltic pilotage scheme not followed* *IMO Resolution MSC.138(76) Recommendation on Navigation through Entrances to Baltic Sea

49 New Inspection Regime (NIR) Expanded Inspections - Application Inspection Category Periodic Additional Ship Risk Profile High Risk Ship Standard Risk Ship Low Risk Ship Overriding and/or Unexpected Factors Expanded Inspection? All Risk type ships (Oil/ Chem/Gas Tankers, Bulk Carriers, Pax) over 12 yrs According to judgement of PSCO if HRS, or SRS/LRS if risk type ship (Oil/Chem/ Gas Tankers, Bulk Carriers, Pax) over 12 yrs

50 New Inspection Regime (NIR) Expanded Inspections - Scope Documentation Structural condition Weathertight condition Emergency systems Radio communications Cargo operations Fire safety Alarms Living/working conditions Navigation equipment Life saving appliances Dangerous goods Prop/aux machinery Pollution prevention Specific ship-type items

51 New Inspection Regime (NIR) Revised Banning Procedures Extended to apply to all ship types Banned from EU ports if: - more than 2 detentions in 3 years if black flag - more than 2 detentions in 2 years if grey flag

52 New Inspection Regime (NIR) Revised Banning Procedures Extended to apply to all ship types Banned from EU ports if: - more than 2 detentions in 3 years if black flag - more than 2 detentions in 2 years if grey flag - jumped detention - failed to call at agreed repair yard

53 New Inspection Regime (NIR) Revised Banning Procedures Minimum Period of Ban First Ban Second Ban Third Ban Fourth Ban 03 months 12 months 24 months (conditional) Indefinite A ban affects a vessel s Port State Control record for life, regardless of ownership, class or flag

54 Paris MOU Current List of Banned Vessels

55 New Inspection Regime (NIR) Other Considerations EU to publish names of companies with: - very low performance - low performance

56 New Inspection Regime (NIR) Other Considerations

57 New Inspection Regime (NIR) Other Considerations EU to publish names of companies with: - very low performance - low performance Difficulties chartering out high risk vessels? Sanctions by oil majors if ship is not low risk? Commercial impact on fleet if ship banned from EU Resale value of: - currently or previously banned vessels? - high risk vessels?

58 Concentrated Inspection Campaigns - CIC Focuses on specific areas where a high level of deficiencies have been found or Focuses on new regulatory requirements which have recently entered into force Conducted annually Covers a three month period 1 st September to 30 th November May be in conjunction with another MOU

59 Concentrated Inspection Campaigns - CIC 2018 MARPOL Annex VI 2017 Safety of Navigation (ECDIS) 2016 Maritime Labour Convention 2015 Enclosed Space Entry 2014 STCW Hours of Rest 2013 Propulsion and Auxiliary Machinery 2012 Fire Safety Systems 2011 Structural Safety and Load Lines 2010 Tanker Damage Stability

60 Concentrated Inspection Campaigns - CIC 2016 Maritime Labour Convention 3674 Inspections carried out 42 Ships detained (1.1% of total inspected)

61 Thank You

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