Inadequate re-setting of on-load release gear

Photographs of Deficiencies identified during Port State Control Life Saving Inadequate re-setting of on-load release gear Poor condition of embarkation ladder Wasted support bracket Wasted boat fall block

Fire Fighting Leaked fire line Wasted fire damper Disconnected CO2 bottle MARPOL Oily inside of discharge pipe Oily corelessor

Machinery Space Oily and dirty E/R floor Oily main engine Patched sea water pipe Load Line Corroded packing channel Wasted gooseneck air vent.

Missing butterfly nut Others Wasted hatch way Cracked hatch coaming Cracked bulwark stay Broken fair lead

Foreword This annual Port State Control (PSC) report summarizes deficiencies identified by PSC inspections carried out in various countries around the world. This report is prepared with the objective of building awareness of the present state of PSC as well as to improve future maintenance and inspections, and also Safety Management System is compiled into the following Chapters. Chapter 1 : Status of Implementation and Recent Developments in PSC Worldwide Chapter 2 : Statistical Analysis of Detained Ships registered to ClassNK in 2011 Chapter 3 : Statistical Analysis of NK SMC ship recorded ISM deficiency at PSC Chapter 4 : Statistical Data from the Tokyo MOU, Paris MOU, and USCG Port State Control has been found to be a very effective tool in reducing the number of substandard ships as well as improving maritime safety and pollution prevention. There has been a significant increase in PSC activity worldwide in concert with a number of amendments to relevant international conventions. In order to carry out the effective implementation of PSC provisions, many countries have already signed and accepted a Memorandum of Understanding (MOU) for regional cooperation in PSC for many regions, and have established a centralized computerized database system and/or a harmonized approach. PSC inspection procedures have been improved to cover not only a ships hardware or documents, but also the operational requirements of the relevant conventions or shipboard maintenance under the ISM Code. Also, because several new conventions or amendments such as the ISPS Code, the Bulk Carrier Safety initiative, and air pollution prevention, etc. have come into force, the extent of PSC inspections has been further increased. In light of this background, ClassNK is working hard to increase the transparency of information related to PSC issues and to make it even more difficult for substandard ships to survive in the market place. August 2012 Note: Every effort has been made to ensure the accuracy of the information presented in this report. However, as information is collected from a variety of sources, ClassNK cannot be held responsible for any erroneous data, judgements or conclusions that may appear in this report, in cases were the information available should prove to have been incomplete or incorrect in any respect.

TABLE OF CONTENTS Chapter 1 Status of Implementation and Recent Developments in PSC Worldwide 1.1 Amendments to the relevant conventions 1.1.1 IMSBC Code 1 1.1.2 Bridge Navigation Watch System 1 1.1.3 Electronic Chart Display and Information System 1 1.1.4 Control for SOx and particulate matter (PM) within North American Emission Control Area 2 1.2 Recent global developments 1.2.1 MOUs around the world (1) European and North Atlantic region (Paris MOU) 3 (2) Asia-Pacific region (Tokyo MOU) 4 (3) Latin-American region (Viña del Mar or Latin-America Agreement) 5 (4) Caribbean region (Caribbean MOU) 5 (5) Mediterranean region (Mediterranean MOU) 5 (6) Indian Ocean region (Indian Ocean MOU) 5 (7) Black Sea region (Black Sea MOU) 6 (8) West and Central Africa region (Abuja MOU) 6 (9) Arab States of the Gulf (Riyadh MOU) 6 1.2.2 Port State Control in the United States (U.S.Coast Guard) 6 1.2.3 Equasis 7 1.3 Measures adopted by ClassNK 1.3.1 Treatment of the Deficiencies Identified by Port State Control Inspections (1) Cooperative assistance with Port States and treatment of the deficiencies 8 (2) Treatment of inspection reports by PSC officers 8 1.3.2 Minimizing the number of detained ships in order to reduce substandard ships (1) Special training at several in-house meetings 8 (2) Meetings and informal gatherings with ship owners 9 1.3.3 Visits to Port States 9 Chapter 2 Statistical Analysis of Detained Ships Registered to ClassNK 2.1 General 10 2.2 Data on Detentions 2.2.1 Detentions by Flag State 10 2.2.2 Detentions by ship type 12 2.2.3 Detentions by ship s age 13 2.2.4 Detentions by ship size (Tonnage) 14 2.2.5 Detentions by Port State 15 2.3 Analysis of Detainable Deficiencies 2.3.1 Detainable Deficiencies per Category 16 2.3.2 Frequently Reported Deficiencies 17 2.4 Analysis of Detainable Deficiencies by Port State 2.4.1 China 23 2.4.2 Australia 24 2.4.3 Japan 24

2.4.4 India 25 2.4.5 Indonesia 25 2.4.6 U.S.A 26 2.4.7 Russian Federation 26 2.4.8 Spain 26 2.4.9 Vietnam 27 2.4.8 Netherlands 27 Chapter 3 Statistical Analysis of NK SMC ship recorded ISM deficiency at PSC 3.1 ISM deficiency cases 3.1.1 Total number and average rate 28 3.1.2 Comparison 29 3.1.2.1 Per factors related to ship 29 3.1.2.2 Per factors related to Company 33 3.1.2.3 Per port state who carried out PSC inspection 36 3. 2 ISM deficiencies and PSC actions 3.2.1 Comparison of deficiencies per ISM Code requirement 37 3.2.2 Comparison of deficiencies and detentions per port state 38 3.2.3 Analysis of deficiencies recorded along with PSC actions applied 39 Appendix: Extract from PSC inspection reports 43 Chapter 4 Statistical Data from Tokyo MOU, Paris MOU and the USCG 4.1 Tokyo MOU 4.1.1 Port State Inspections carried out by Authorities 51 4.1.2 Black List of Flag States 52 4.1.3 Detentions by Recognized Organization 53 4.1.4 Deficiencies by Category 54 4.2 Paris MOU 4.2.1 Port State Inspections carried out by Authorities 55 4.2.2 Black List of Flag States 56 4.2.3 Deficiencies by Category 57 4.2.4 Recognized Organization Performance Table 58 4.3 USCG 4.3.1 USCG Statistics 59 4.3.2 Targeted Flag States (Safety) 59 4.3.3 Recognized Organization Performance Table (Safety) 60

Chapter 1 Status of Implementation and Recent Developments in PSC Worldwide 1.1 Amendments to the relevant conventions Major amendments to international conventions and to the relevant regulations that came into effect in 2010 or will do so in 2011 are summarized below. 1.1.1 IMSBC Code (SOLAS VI, VII) Date: 1 January 2011 [Refer to ClassNK Technical Information TEC-0772, 786] The IMSBC Code has become applicable to all ships as mandatory requirements since 1 January 2011. 1.1.2 Bridge Navigation Watch System (SOLAS V/19) Date: 1 July 2011 [Refer to ClassNK Technical Information TEC-0838] Paragraphs 2.2.3 and 2.2.4 relating to the Bridge Navigation Watch System (BNWAS) were added to SOLAS Chapter V/19. A Bridge Navigation Watch System (BNWAS) is required to be installed on all affected ships by the following due dates: (1) Ships constructed on or after 1 July 2011: not later than the initial Safety Equipment Survey (SE survey). (2) Passenger ships constructed before 1 July 2011: not later than the first SE survey after 1 July 2012. (3) Cargo ships of 3,000 GT and upwards constructed before 1 July 2011: not later than the first SE survey after 1 July 2012. (4) Cargo ships of 500 GT and upwards constructed before 1 July 2011: not later than the first SE survey after 1 July 2013. (5) Cargo ships of 150 GT and upwards constructed before 1 July 2011: not later than the first SE survey after 1 July 2014. (6) Ships constructed before 1 July 2011 but delivered after the due dates of (2) to (5) above: not later than the initial SE survey. 1.1.3 Electronic Chart Display and Information System (SOLAS V/19) Date: 1 July 2012 [Refer to ClassNK Technical Information TEC-0907] Paragraphs 2.1.4 and 2.10, 2.11 relating to the Electronic Chart Display and Information System (ECDIS) were revised and newly added to SOLAS Chapter V/19. A Electronic Chart Display and Information System (ECDIS) and back-up arrangement will be phased in from 1 July 2012. (1) Passenger ship (i) Passenger ship constructed on or after 1 July 2012, not later than the initial safety equipment survey. (ii) Passenger ship constructed before 1 July 2012, not later than the first safety equipment survey on or after 1 July 2014. (2) Tanker (i) Tanker constructed on or after 1 July 2012, not later than the initial safety equipment survey. (ii) Tanker constructed before 1 July 2012, not later than the first safety equipment survey on or after 1 July 2015. 1

(3) Cargo ship other than tanker (i) Cargo ship, of 10,000GT and upwards constructed on or after 1 July 2013, not later than the initial safety equipment survey. (ii) Cargo ship, of 3,000GT and upward but less than 10,000GT constructed on or after 1 July 2014, not later than the initial safety equipment survey. (iii) Cargo ship, of 50,000GT and upward constructed before 1 July 2013, not later than the first safety equipment survey on or after 1 July 2016 (iv) Cargo ship, of 20,000GT and upward but less than 50,000GT constructed on or after 1 July 2013, not later than the first safety equipment survey on or after 1 July 2017. (v) Cargo ship, of 10,000GT and upward but less than 20,000GT constructed before 1 July 2013, not later than the first safety equipment survey on or after 1 July 2018. (4) Ship constructed under the conditions of above (1)(ii), (2)(ii), (3)(iii), (iv) and (v), but delivered after the applicable due date, not later than initial safety equipment survey. 1.1.4 Control for SOx and particulate matter (PM) within North American Emission Control Area (MAROOL ANNEX VI) Date: 1 August 2012 [Refer to ClassNK Technical Information TEC-0916] The control of the sulphur content in fuel oil for ships operating within the designated North American Emission Control Area (MARPOL ANNEX VI, Regulation 14) will commence on 1 August 2012. New amendments to conventions are also introduced on the ClassNK Website in the section, IMO International Convention Calendar. (http://www.classnk.or.jp) 2

1.2 Recent global developments 1.2.1 MOUs around the world In order to carry out PSC effectively, a recommendation concerning regional co-operation in the control of ships and discharges was adopted as a resolution by the IMO. In July 1982, fourteen European countries signed the Paris Memorandum of Understanding on Port State Control (Paris MOU), and today many countries have signed and accepted similar MOUs around the world. Currently, nine MOUs exist around the world and their respective activities in terms of implementing PSC are described below. European and North Atlantic region :Paris MOU (http://www.parismou.org/) Asia-Pacific region :Tokyo MOU (http://www.tokyo-mou.org/) Latin American region :Viña del Mar (http://www.acuerdolatino.int.ar/) Caribbean region :Caribbean MOU (http://www.caribbeanmou.org/) Mediterranean region :Mediterranean MOU (http://www.medmou.org/) Indian Ocean region :Indian Ocean MOU (http://www.iomou.org/) Black Sea region :Black Sea MOU (http://www.bsmou.org/) West and Central Africa region :Abuja MOU (http://www.abujamou.org/) Arab States of the Gulf :Riyadh MOU (http://www.riyadhmou.org/) (1) European and North Atlantic region (Paris MOU) 1) Activity Established: 1 July 1982 Members: Belgium, Bulgaria, Canada, Croatia, Cyprus, Denmark, Estonia, Finland, France, Germany, Greece, Iceland, Ireland, Italy, Latvia, Lithuania, Malta, Netherlands, Norway, Poland, Portugal, Romania, Russian Federation, Slovenia, Spain, Sweden, and the United Kingdom -1 The Paris MOU consists of 27 participating maritime Administrations and covers the waters of the European coastal States and the North Atlantic basin from North America to Europe. The Paris MOU states that their aim is to eliminate the operation of sub-standard ships through a harmonized system of port State control. -2 Press releases have announced the recent activities of the Paris MOU as follows. Press release dated 14 February 2012 The Paris MOU announced the results of the Concentrated Inspection Campaign (CIC) on Structural Safety and load lines, which was conducted from 1 September to 30 November 2011. - In total, 4,250 ships were inspected and 42 ships (1%) were detained for CIC-related deficiencies. - The CIC questionnaire was completed during 4,386 inspections. Of them, general cargo/multi-purpose ships with 1,563 (36%) inspections, bulk carriers with 795 (18%) inspections, container ships with 495 (11%) inspections, chemical tankers with 433 (10%) inspections and oil tankers with 296 (7%) inspections included. Press release dated 1 June 2012 A Concentrated Inspection Campaign (CIC) on Fire Safety Systems is scheduled to be carried out from 1 September to 30 November 2012 simultaneously with Paris MOU/ Tokyo MOU, Black Sea MOU and Indian Ocean MOU. 3

2) New Inspection Regime (NIR) -1 Classification of the Ship Risk Profile A Ship Risk Profile is based on the flag, Recognized Organization and company performance, the number of deficiencies and detentions recorded for the ship, past inspection records of the ship, as well as the ship s age and ship type. The Ship Risk Profile classifies ships into Low Risk Ships (LRS), Standard Risk Ships (SRS), and High Risk Ships (HRS). The time window is set according to the Ship Risk Profile as follows: - HRS: between 5-6 months after the last inspection - SRS: between 10-12 months after the last inspection - LRS: between 24-36 months after the last inspection -2 Banned Ships The banning criteria for the first and second ban have been amended as follows: - If the ship flies a black listed flag, it will be banned after more than 3 detentions in the last 36 months - If the ship flies a grey listed flag, it will be banned after more than 3 detentions in the last 24 months Any subsequent detention after the 2 nd banning will lead to a ban, regardless of the flag of the ship. -3 Reporting obligations The ETA72 (a 72 hour pre-arrival) notification requirement has been widened to include all ships with a HRS profile as well as all bulk carriers, chemical tankers, gas carriers, oil tankers, and passenger ships 12 years of age or older subject to an expanded inspection. Further, all ships are required to notify their ETA24 (a 24 hour pre-arrival), ATA (the actual time of arrival), and ATD (the actual time of departure). (2) Asia-Pacific region (Tokyo MOU) 1) Activity Established: 1 December 1993 Members: Australia, Canada, Chile, China, Fiji, Hong Kong, Indonesia, Japan, Korea, Malaysia, New Zealand, Papua New Guinea, Philippines, Russian Federation, Singapore, Solomon Islands, Thailand, Vanuatu, and Vietnam -1 The main objectives of the Memorandum have been announced as follows: 1. to establish an effective Port State control regime in the Asia-Pacific region through the co-operation of its members and the harmonization of their activities, 2. to eliminate substandard shipping so as to promote maritime safety, 3. to protect the marine environment, and 4. to safeguard working and living conditions onboard ships. -2 Press releases announced the activities of the Tokyo MOU as follows. Press release dated 9 February 2012 The Tokyo MOU announced the results of its Concentrated Inspection Campaign (CIC) on Structural Safety and the International Convention on load lines which was conducted from 1 September to 30 November 2011. - In total, 5,901 inspections were carried out. Of them, bulk carriers were the ship type with the highest number of CIC inspections which accounted for 1,898 (32.16%), followed by general cargo vessels 1,565 (26.52%) and container vessels 983 (16.66%). 4

- The most significant deficiencies found during the campaign were related to the protection of opening (ventilators, air pipes, casings) 554 instances. Press release dated 23 April 2012 The 22nd meeting of the PSC Committee of the Tokyo MOU was held in Vina del Mar, Chile from 18 to 21 April 2011. - The Committee agreed to accept Peru as a Co-operating Member of the Tokyo MOU. - The Committee decided to put the measures for permanent implementation against under-performing ships that have been detained three or more times by the Tokyo MOU during the last 12 months. - The Committee approved the arrangements for the CIC on Fire Safety System that will be carried out from 1 September to 30 November 2012 jointly with the Paris MOU. 2) Targeting system To facilitate the selection of ships to be inspected throughout the Tokyo MOU region, a central computer database, known as APCIS, is consulted by PSC officers for data on ship particulars and for reports of previous inspections carried out within the region. The Tokyo MOU Authorities select ships for PSC inspection in accordance with a target factor that is calculated based on information stored in the database. (3) Latin-American region (Viña del Mar or Latin-America Agreement) Established: 5 November 1992 Members: Argentina, Bolivia, Brazil, Chile, Colombia, Cuba, Ecuador, Honduras, Mexico, Panama, Peru, Uruguay, and Venezuela -1 The 18th meeting of the PSC Committee of the Latin American Agreement was held in Montevideo, Uruguay from 3 to 6 October 2011. -2 In 2012, the 19th meeting of the PSC Committee is scheduled to be held in Brazil. (4) Caribbean region (Caribbean MOU) Established: 9 February 1996 Members: Antigua and Barbuda, Aruba, Bahamas, Barbados, Belize, Cayman Islands, Cuba, Grenada, Guyana, Jamaica, Netherlands Antilles, Suriname, and Trinidad & Tobago (5) Mediterranean region (Mediterranean MOU) Established: 11 July 1997 Members: Algeria, Cyprus, Egypt, Israel, Jordan, Lebanon, Malta, Morocco, Tunisia, and Turkey (6) Indian Ocean region (Indian Ocean MOU) Established: 5 June 1998 Members: Australia, Bangladesh, Comoros, Eritrea, France (La Reunion Island), India, Iran, Kenya, Maldives, Mauritius, Oman, South Africa, Sri Lanka, Sudan, Tanzania, and Yemen -1 The 14th meeting of the PSC Committee of the Indian Ocean MOU was held at Goa, India from 12 to 15 September 2011. 5

-2 The Indian Ocean MOU will carry out a Concentrated Inspection Campaign (CIC) on fire safety system arrangements from 1 September to 30 November 2011. -3. According to Annual Report 2012 of the Indian Ocean MOU, a total of 5,550 inspections were carried out and 600 vessels were detained in 2011. (7) Black Sea region (Black Sea MOU) Established: 7 April 2000 Members: Bulgaria, Georgia, Romania, Russian Federation, Turkey, and Ukraine -1 The Black Sea MOU announced the results of its Concentrated Inspection Campaign (CIC) on structural safety and international convention on load lines, which was conducted from 1 September to 30 November 2011. - In total, 1,199 vessels were inspected for the CIC and 21 (1.75%) were detained due to the CIC related deficiencies. - Largest group of the ship inspected for the CIC were general cargo/multi-purpose ships with 541 (45.1%) inspections, bulk carrier 330 (27.5%) and oil tanker 123 (10.3%) were also inspected. -2 The 13th meeting of the PSC Committee of the Black Sea MOU was held in Odessa, Ukraine from 5 to 7 June 2012. -3 CIC on fire safety systems arrangements is scheduled to be carried out from 1 September to 30 November 2012. (8) West and Central Africa region (Abuja MOU) Established: 22 October 1999 Members: Benin, Congo, Cote d Ivoire, Gabon, Ghana, Guinea Conakry, Nigeria, Senegal, Sierra Leone, The Gambia, and Togo (9) Arab States of the Gulf (Riyadh MOU) Established: 30 June 2004 Members: The Kingdom of Bahrain, Kuwait, Qatar, The Kingdom of Saudi Arabia, The Sultanate of Oman, and United Arab Emirates 1.2.2 Port State Control in the United States (USCG) 1) Activity Although the United States Coast Guard (USCG) is not a member of any MOU, it is an observer at a number of MOUs, and undertakes effective PSC in cooperation with other MOUs. In the 1970's, the U.S. Coast Guard increased its emphasis on the examination of foreign vessels. Although this emphasis was primarily driven by requirements to ensure compliance with the then new U.S. pollution prevention and navigation safety regulations, boarding officers also exercised Port State authority when instances of non-compliance with SOLAS and MARPOL were noted. In 1994, the U.S. introduced risk-management methodologies into the Port State Control program in order to allocate limited inspection resources to where they could do the most good, by identifying those ships, ship owners, classification societies and Flag Administrations that were most often found lacking in meeting their international Convention responsibilities. On 1 January 2001, the USCG implemented an initiative to identify high-quality 6

ships, called Qualship 21, quality shipping for the 21 st century. This program has since proven to be very effective in recognizing well operated and maintained ships of good quality and continues in use today. 2) USCG Boarding Priority Matrix The USCG uses a Boarding Priority Matrix which enables it to rationally and systematically determine the probable risk posed by non-u.s. ships calling at U.S. ports. The Matrix is used to decide which ships Port State Control Officers should board on any given day, in any given port. Points are assessed in each of five columns for Safety matters and four columns for Security matters, and then added up for a total point score. This numerical score, along with other performancebased factors, determines a ship s boarding priority (http://homeport.uscg.mil/). 3) Banning of foreign vessels All foreign flagged vessels operating in U.S. waters are required to be maintained in compliance with U.S. regulations, international conventions and other required standards. However, when a vessel has been repeatedly detained by the USCG (totaling three detentions within a twelve month period) and it is determined that failure to effectively implement the SMS onboard may be a contributing factor for the substandard conditions that led to the detentions, the USCG Headquarters (USCG-HQ) will issue a Letter of Denial prohibiting the ship from further entering any U.S. port until such time as certain actions have been taken to rectify the situation. However, even if a vessel has less than three detentions in twelve months, a Letter of Denial may be issued to any vessel which, in the option of the USCG; 1. may pose a significant risk to the safety of the vessel, crew or the marine environment; or 2. has a history of accidents, pollution incidents, or serious repair problems which creates reason to believe that such a vessel may be unsafe or create a threat to the marine environment; or 3. has discharged oil or other hazardous material in violation of any law of the United States or in a manner or quantities inconsistent with the provisions of any treaty to which the United States is a party. 1.2.3 Equasis Equasis is a unique database that collects safety-related information on the world s merchant fleet from both public and private sources and makes it easily accessible on the Internet (http://www.equasis.org/). It displays information from public authorities (Port State inspection and detention information from the three participating PSC regions, i.e. the Paris MOU, Tokyo MOU, and USCG) and industry players (such as information on class, insurance, participation in industry inspection schemes, and quality organizations), all free of charge. 7

1.3 Measures adopted by ClassNK 1.3.1 Handling of the Deficiencies Identified by Port State Control Inspections (1) Cooperative assistance with Port States and treatment of deficiencies When surveyors of the Society are notified of the detention of a ship classed with ClassNK, the Society actively co-operates with the reporting PCS Authority in a number of ways. The more direct of these steps include the following. - Surveyors liaise with port state control authorities to ensure that they are called in as soon as appropriate when deficiencies related to class and/or statutory matters are identified. - Surveyors liaise with PSC officers to ensure uniformity of interpretation of class and statutory requirements. - Surveyors provide PSC officers with background information, extracts from reports pertinent to the inspection, and details of outstanding recommendations of class and statutory items whenever so requested by the port state. - Attending surveyors examine not only the condition of the deficiencies identified by the PSC officers but also the general condition of the hull, machinery and equipment of the subject ship to the extent of an annual survey, carefully considering the seriousness of any deficiencies when they attend ships that have been subject to an intervention action by the port state. (2) Treatment of inspection reports by PSC officers When a surveyor receives an inspection report from a port state authority, the report is sent to the ClassNK Head Office. The report is immediately examined for the causes of the deficiencies by experienced staff. This examination is carried out for all ships for which such reports are received, and the results are circulated to all sections concerned, including all members of the board of directors, as necessary. The results are also reflected a ClassNK PSC database that has been developed for the purpose of providing surveyors with PSC related information electronically. The results of this examination are also submitted to the Flag State Administration of the ship, as required. A letter is also sent to owner(s) of the ship to remind them of their ultimate responsibility regarding the safety of their ships and protection of the marine environment. Visits may also be made to the ship owner or manager, when deemed appropriate, to advise them of the relevant deficiencies noted and to encourage them to more proactively improve the routine maintenance of their ships and take other measures as necessary to ensure the highest levels of safe and environmentally friendly operation. In cases where the intervention is determined to be related to previous surveys conducted by surveyors of the Society, those surveys are treated as a non-conforming service, and appropriate corrective and preventive actions are taken in accordance with the ClassNK quality system. 1.3.2 Minimizing the number of detained ships in order to reduce substandard ships (1) Special training at several in-house meetings Special training on PSC related issues is conducted at several meetings held regularly for general managers and managers, to ensure that surveyors carry out full and effective surveys with an uncompromising attitude towards ensuring the quality and safety of the ships classed with the Society. Special re-training is also carried out under the supervision of the Head Office and regional managers, as needed, for those surveyors who have conducted any surveys 8

determined to be a non-conforming service under the quality system of the Society. (2) Meetings and informal gatherings with ship owners (a) Visiting Management Companies When a ship classed with ClassNK is detained by PSC, a senior surveyor or manager of the Society visits the owner or the company managing the ship to discuss what steps can be taken to improve the routine maintenance of the ships in their fleet, so as to prevent both a recurrence of the deficiencies noted and the occurrence of similar problems in the future. (b) Meetings and seminars PSC related issues are regularly discussed at informal gatherings and technical committee meetings held with ship owners. At such times, explanations are given and documents presented, with emphasis placed on the importance of proactively ensuring the proper maintenance of ships and education of crew in order to prevent the detention of ships. (c) Publications The ClassNK Annual Report on Port State Control is distributed to all registered shipowners and operators in the ClassNK fleet. A checklist entitled Good Maintenance on board Ships has also been prepared in electronic format, which can be used by the ship s crew for quick and easy inspection of a ship before entering port. 1.3.3 Visits to Port States Personnel from the ClassNK Head Office as well as local survey offices are assigned to visit the headquarters or offices of various Port States with the aim of introducing ClassNK and exchanging views on matters of mutual concern. Major port States and relevant organizations visited by executives of the Society during 2011 are listed below. U.S.A United States Coast Guard (USCG) Canada Transport Canada China Marine Safety Administration (MSA) Australia Australian Maritime Safety Authority (AMSA) 9

Chapter 2 Statistical Analysis of Detained Ships Registered to ClassNK 2.1 General The data in this chapter, on ships detained due to deficiencies identified during PSC inspections, is based on the following sources: (1) Notifications from Port States issued in accordance with IMO Resolution A.1052(27) Procedure for Port State Control, and (2) Publications related to detained ships issued by the USCG, the Paris MOU, and the Tokyo MOU. From January to December 2011, 431 PSC detentions were reported relating to 401 ships classed by NK. This included cases of detention for reasons not related to class or to NK itself. The total number of NK-registered ships (500 GT or over) was 6,914 at the end of December 2011. Therefore, the 401 ships detained represent about 5.8% of the total number of ships in the NK fleet. 2.2 Data on Detentions 2.2.1 Detentions by Flag State Flag State Table 2.2.1 Detentions by Flag State (NK) Number of Registered Ships (500GT or over) Number of Detentions Detention Ratio (%) (= Detentions / Registered Number in each year) 2009 2010 2011 2009 2010 2011 2009 2010 2011 Panama 2,985 2,988 3,048 199 193 246 6.7 6.5 8.1 Liberia 260 267 299 20 16 26 7.7 6.0 8.7 Singapore 539 560 610 19 17 21 3.5 3.0 3.4 Malta 192 194 181 27 23 18 14.1 11.9 9.9 Hong Kong 347 388 422 10 18 18 2.9 4.6 4.3 Marshall Islands 168 213 249 13 13 18 7.7 6.1 7.2 Vietnam 94 98 90 13 6 14 13.8 6.1 15.6 Bahamas 136 132 131 11 5 14 8.1 3.8 10.7 Thailand 66 66 72 2 8 8 3.0 12.1 11.1 St. Vincent * 32 31 27 6 7 8 18.8 22.6 29.6 Cyprus 76 78 86 13 8 7 17.1 10.3 8.1 Turkey 47 56 58 9 7 7 19.1 12.5 12.1 Indonesia 85 104 108 1 5 4 1.2 4.8 3.7 Malaysia 235 240 257 1 4 4 0.4 1.7 1.6 Others - - - 23 22 18 - - - Total 6,485 6,675 6,914 367 352 431 5.7 5.3 6.2 * Refers to St. Vincent and the Grenadines. The same applies in all subsequent tables. 10

300 Detentions 250 200 150 100 199 193 246 2009 2010 2011 50 0 Panama 26 27 20 16 19 17 21 23 18 18 18 18 10 13 13 13 14 11 14 13 6 5 8 8 6 7 8 8 7 9 7 7 5 2 4 1 4 1 4 Liberia Singapore Malta Hong Kong Marshall Islands Vietnam Bahamas Thailand Flag State St. Vincent * Cyprus Turkey Fig 2.2.1-1 Detention by Flag (NK) Indonesia Malaysia 23 22 18 Others 35.0 30.0 29.6 Detention Ratio (%) 25.0 20.0 15.0 10.0 5.0 0.0 8.1 6.76.5 8.7 7.7 6 3.5 3.4 3 14.1 11.9 9.9 4.64.3 2.9 15.6 13.8 7.7 7.2 6.1 6.1 10.7 8.1 3.8 12.1 11.1 3 22.6 18.8 17.1 10.3 8.1 19.1 12.5 12.1 2009 2010 2011 4.8 3.7 1.7 1.2 1.6 0.4 Panama Liberia Singapore Malta Hong Kong Marshall Islands Vietnam Bahamas Thailand Flag State St. Vincent * Cyprus Turkey Indonesia Malaysia Fig 2.2.1-2 Detention Ratio by Flag (NK) Of those Flag State Administrations with ten or more NK classed ships, the following Administrations were identified as having a detention ratio higher than 10% in 2011: Vietnam, Bahamas, Thailand, St. Vincent and the Grenadines, and Turkey. 11

2.2.2 Detentions by ship type Table 2.2.2 Detentions by Ship Type (NK) Ship Type Number of Registered Ships in 2011 (500GT or over) Number of Detentions Detention Ratio (%) (= Detentions / Registered Number in each year) 2009 2010 2011 2009 2010 2011 Bulk Carrier 2,916 186 161 209 8.3 6.7 7.2 General Cargo 650 62 65 93 9.8 10.3 14.3 Container Carrier 585 19 28 31 3.4 4.9 5.3 Chip Carrier 153 11 8 13 7.2 5.0 8.5 Cement Carrier 103 2 2 1 1.7 1.8 1.0 Ro-Ro Ship 92 3 2 9 3.0 2.0 9.8 Reefer Carrier 174 26 24 15 13.4 12.9 8.6 Vehicles Carrier 342 12 16 8 3.7 4.9 2.3 Oil Tanker 721 6 7 10 0.8 0.9 1.4 Oil/Chemical Tanker 625 29 32 31 4.6 5.0 5.0 Gas Carrier 353 7 4 9 2.1 1.2 2.5 Others 200 4 3 2 0.9 0.7 1.0 Total 6,914 367 352 431 Bulk carriers, General cargo ships, and Reefer carriers were identified as having a higher detention ratio than other ship types noted. ( Detention ratio was determined by dividing the number of detentions by the number of ships of each respective ship type in the NK fleet.) Detentions 250 200 150 100 50 0 Bulk Carrier 209 186 161 62 General Cargo 65 93 19 Container Carrier 28 31 11 Chip Carrier 8 13 Cement Carrier 2 2 1 3 2 Ro-Ro Ship 9 Fig. 2.2.2-1Detentions by Ship Type (NK) 26 Reefer Carrier 24 15 12 Vehicles Carrier 16 8 6 7 10 Oil Tanker 29 Oil/Chemical Tanker 32 31 Gas Carrier 2009 2010 2011 7 7 9 4 3 Others 2 Detention Ratio(%) 16.0 14.0 12.0 10.0 8.0 6.0 4.0 2.0 0.0 Bulk Carrier 8.3 7.2 6.7 10.3 9.8 General Cargo 14.3 Container Carrier 7.2 5.3 4.9 5 3.4 Chip Carrier 8.5 Cement Carrier 3 1.7 1.8 2 1 Ro-Ro Ship 9.8 13.4 12.9 Reefer Carrier 4.9 3.7 2.3 1.4 0.8 0.9 Fig. 2.2.2-2 Detention Ratio by Ship Type (%) 8.6 Vehicles Carrier Oil Tanker 5 5 4.6 Oil/Chemical Tanker Gas Carrier 2.5 2.1 1.2 2009 2010 2011 0.9 0.7 1 Others 12

2.2.3 Detentions by ship s age Ship s age Table 2.2.3 Detentions by Ship s Age (NK) Number of Detention Ratio (%) Registered Number of Detentions (= Detentions / Registered Ships in 2011 Number in each year) (500GT or over) 2009 2010 2011 2009 2010 2011 Up to 5 years old 2,769 41 47 71 1.8 2.0 2.6 Over 5 and up to 10 1,286 52 52 68 4.4 4.0 5.3 Over 10 and up to 15 1,216 95 79 94 7.3 6.4 7.7 Over 15 and up to 20 842 54 66 88 6.8 7.5 10.5 Over 20 and up to 25 382 52 34 41 10.9 8.1 10.7 Over 25 419 73 74 69 14.5 14.3 16.5 Total 6,914 367 352 431 Detentions 100 80 60 40 20 41 47 71 52 52 68 95 79 94 66 88 54 52 34 41 73 74 69 2009 2010 2011 0 Up to 5 Over 5 and up to 10 Over 10 and up to 15 Over 15 and up to 20 Over 20 and up to 25 Over 25 Fig. 2.2.3-1Detentions by Ship's Age (NK) Detention Ratio (%) 20.0 15.0 10.0 5.0 0.0 1.8 2 2.6 Up to 5 4.4 4 5.3 Over 5 and up to 10 7.3 7.7 6.4 6.8 7.5 Over 10 and up to 15 Over 15 and up to 20 10.5 10.9 10.7 8.1 Over 20 and up to 25 16.5 14.5 14.3 Over 25 2009 2010 2011 Fig. 2.2.3-2 Detention Ratio by Ship's Age (NK) 13

2.2.4 Detentions by ship size (Tonnage) Table 2.2.4 Detention by Size (Tonnage) (NK) Number of Detention Ratio (%) Gross Ton (x 1,000) Registered Number of Detentions (= Detentions / Registered Ships in 2011 Number in each year) (500GT or over) 2009 2010 2011 2009 2010 2011 Up to 10 2,478 122 132 164 4.7 5.3 6.6 Over 10 and up to 20 1,204 92 76 89 8.1 6.5 7.4 Over 20 and up to 30 781 47 49 63 6.7 6.6 8.1 Over 30 and up to 40 906 56 41 61 7.2 4.8 6.7 Over 40 and up to 50 509 23 17 28 5.3 3.6 5.5 Over 50 and up to 60 273 3 9 7 1.3 3.6 2.6 Over 60 and up to 80 200 15 12 7 8.2 6.0 3.5 Over 80 563 9 16 12 2.0 3.2 2.1 Total 6,914 367 352 431 Detentions 180 160 140 120 100 80 60 40 20 0 164 132 122 Up to 10 92 76 89 Over 10 and up to 20 47 63 61 56 49 41 Over 20 and up to 30 Over 30 and up to 40 Fig.2.2.4-1 Detention by Gross Tonnage (NK) 23 17 28 Over 40 and up to 50 3 15 9 12 16 7 7 9 12 Over 50 and up to 60 Over 60 and up to 80 Over 80 x 1,000 GT 2009 2010 2011 Detention Ratio (%) 9.0 8.0 7.0 6.0 5.0 4.0 3.0 2.0 4.7 5.3 6.6 8.1 7.4 6.7 6.5 6.6 8.1 7.2 4.8 6.7 5.3 5.5 3.6 3.6 1.3 2.6 8.2 6 3.5 2 3.2 2009 2010 2011 2.1 1.0 0.0 Up to 10 Over 10 and up to 20 Over 20 and up to 30 Over 30 and up to 40 Over 40 and up to 50 Over 50 and up to 60 Fig. 2.2.4-2 Detention Ratio by Gross Tonnage (NK) Over 60 and up to 80 Over 80 x 1,000 GT 14

2.2.5 Detentions by Port State Table 2.2.5 Detentions by Port State (NK) Port State 2009 2010 2011 China 59 88 117 Australia 89 76 83 Japan 21 27 40 India 10 8 26 Indonesia 3 6 23 U.S.A.(*1) 31 24 21 Russian Federation 9 6 12 Spain 14 5 10 Vietnam 6 13 9 Netherlands 6 0 9 Republic of Korea 20 18 6 United Kingdom 5 7 6 Iran 4 6 5 Italy 1 2 5 France 3 6 4 Belgium 11 4 4 Chile 2 2 4 Ukraine 6 4 3 Israel 1 2 3 Singapore 3 1 3 Canada 5 1 3 Germany 3 0 3 Ireland 3 2 2 Papua New Guinea 0 1 2 Portugal 2 0 2 Slovenia 1 0 2 Greece 1 0 2 Poland 0 0 2 Others 48 43 20 Total 367 352 431 (*1) Including Puerto Rico Detentions by members of the Tokyo MOU made up more than 70% of the total number of ships detained in 2011. China Australia Japan India Indonesia U.S.A.(*1) Russian Federation Spain Vietnam Netherlands Republic of Korea United Kingdom Iran Italy France Belgium Chile Ukraine Israel Singapore Canada Germany Ireland Papua New Guinea Portugal Slovenia Greece Porland 6 3 9 0 6 5 2 1 4 6 3 4 2 2 3 4 6 3 2 1 3 1 3 3 1 5 3 0 3 2 2 3 2 1 0 2 0 2 2 0 1 2 0 1 2 0 0 12 6 9 6 7 5 5 6 4 4 4 8 10 10 5 14 9 13 6 6 11 27 21 23 21 24 31 18 20 26 40 59 88 83 76 89 117 2011 2010 2009 Fig. 2.2.5 Detentions by Port State (NK) 15

2.3 Analysis of Detainable Deficiencies 2.3.1 Detainable Deficiencies per Category In 2011, a total of 1,137 detainable deficiencies were reported relating to 431 detentions, i.e., deficiencies which were serious enough to jeopardise the ship s seaworthiness, safety of the crew onboard, or to present an unreasonable threat of harm to the environment and therefore warranted the detention of the ship. The deficiencies are categorized as shown in Figure 2.3.1. Deficiencies related to fire-fighting and life-saving appliances combined accounted for more than one-third of the total in 2011. FIRE SAFETY MEASURES LIFESAVING APPLIANCES ISM RELATED DEFICIENCIES MARPOL - ANNEX I LOAD LINES SAFETY OF NAVIGATION RADIOCOMMUNICATIONS SOLAS RELATED OPERATIONAL DEFICIENCIES PROPULSION AND AUXILIARY MACHINERY STABILITY, STRUCTURE AND RELATED EQUIPMENT CERTIFICATE AND WATCHKEEPING FOR SEAFARERS MARPOL - ANNEX IV BULK CARRIERS - ADDITIONAL SAFETY MEASURES SHIP'S CERTIFICATES AND DOCUMENTS MARPOL - ANNEX VI ALARM SIGNALS MARPOL RELATED OPERATIONAL DEFICIENCIES CREW AND ACCOMMODATION (ILO 147) CARRIAGE OF CARGO AND DANGEROUS GOODS MOORING ARRANGEMENTS (ILO 147) FOOD AND CATERING (ILO 147) OIL, CHEMICAL TANKERS AND GAS CARRIERS ALL OTHER DEFICIENCIES WORKING SPACES (ILO 147) MARPOL - ANNEX V ACCIDENT PREVENTION (ILO 147) MARPOL - ANNEX II ADDITIONAL MEASURES TO ENHANCE MARITIME SAFETY AFS CONVENTION MARPOL - ANNEX II 97 94 85 59 53 66 47 61 66 45 51 57 35 46 57 41 43 52 81 64 51 42 76 25 17 27 24 11 8 6 0 3 12 18 16 10 6 4 8 3 2 8 2 0 5 1 4 6 3 4 2 4 0 3 3 5 2 3 2 0 2 0 2 0 2 0 4 1 0 2 0 2 20 16 19 31 33 15 112 134 153 143 238 205 217 2011 2010 2009 0 50 100 150 200 250 Fig. 2.3.1 Deficiencies per Category (NK) Deficiencies 16

2.3.2 Frequently Reported Deficiencies Figure 2.3.2 shows those items of detainable deficiencies that were reported frequently, in conjunction with the actual detention of ships in the NK fleet. Lifeboats, emergency fire pumps, and fire-dampers continue to be the major items where most detainable deficiencies were found. Maintenance of the ship and equipment also comprise major items noted in 2011. The items reported from 2009 to 2011 are explained in detail in paragraphs (1) to (15) below. Lifeboats 43 70 75 Emergency Fire Pump 53 64 64 Fire-dampers 41 48 60 Maintenance of the ship and equipment 39 39 42 Oil filtering equipment 22 33 41 Ventilators, air pipes, casings 24 34 34 Development of plans for shipboard operations 6 22 26 Operational readiness of lifesaving appliances 17 23 22 Reserve source of energy 4 9 22 Charts 12 15 19 Emergency lighting, batteries and switches 13 14 19 Sewage treatment plant 4 9 17 Fire prevention 17 16 19 Resources and personnel Quick Closing Devices, Remote Control Fixed fire extinguishing installation 2 7 6 9 10 15 15 17 15 2011 2010 2009 Water level indicator 6 8 14 Fire drills 5 11 14 MF/HF radio installation 14 16 21 Auxiliary engine 14 16 12 Jacketed piping system for high pressure fuel lines 14 18 17 Fire detection 11 14 14 Certificates for master and officers 10 14 22 Cleanliness of engine room 13 16 25 0 10 20 30 40 50 60 70 Deficiencies Fig. 2.3.2 Deficiencies reported Frequentry (NK) 17

(1) Fire Fighting Appliances Major types and details of deficiencies noted under the category of Fire Safety Measures (Fire Fighting Appliances) are shown in Table 2.3.2-(1) below. Table 2.3.2-(1) Fire Safety Measures (Fire Fighting Appliances) Item 09 10 11 Noted Deficiencies Fire pumps Inoperable or low pressure emergency fire 53 64 64 pumps Fire-dampers, Mechanical Ventilations 60 41 48 Wasted and holed fire-dampers Prevention (fire protection) Wasted and holed air vents 19 16 17 Wasted fire doors and fire insulation Fire fighting equipment Wasted and holed fire main system and hoses 17 20 16 Seized isolating valve of fire main Fixed fire extinguishing system Inadequate maintenance and validity expired 6 2 15 Wasted/holed fire main system Quick closing valves, Remote Wooden blocked quick closing valves 17 9 15 control devices Seized closing devices Leakage of fuel oil Jacketed piping system for high 17 18 14 Disconnected jacketed piping system pressure fuel lines Inoperable jacketed piping system Fire detection Other (fire safety related) Doors within main vertical zone 11 14 14 Inoperable fire detection units 5 10 12 E/R bilge full of oily water etc. 6 4 12 Malfunction of self-closing device Un-gastight due to worn packing (2) ISM Related Defects Major types and details of deficiencies noted under the category of ISM Related Defects are shown in Table 2.3.2-(2) below. Table 2.3.2-(2) ISM Related Defects Item 09 10 11 Noted Deficiencies Maintenance of the ship and Inadequate implementation of SMS by crew 39 39 42 equipment Inadequate maintenance of ship s equipment No record of hours of rest /work and incorrect Development of plans for 6 22 26 description shipboard operations Missing port arrival checklist Resources and personnel Masters responsibility and authority Other(ISM) Emergency preparedness Documentation 10 7 15 Not familiar with operation of equipments 2 6 12 Master failed to ensure proper implementation of requirements of the ISM Code 2 6 12 ISM system does not ensure etc. 14 15 10 Failure of abandon ship drill and fire drill Not familiar with fire fighting equipment 4 5 5 SMS documents not on board 18

(3) Life Saving Appliances Major types and details of deficiencies noted under the category of Life Saving Appliances are shown in Table 2.3.2-(3) below. Table 2.3.2-(3) Life Saving Appliances Item 09 10 11 Noted Deficiencies Inoperable lifeboat engine Damaged / Wasted lifeboats and inventories Lifeboats 70 43 78 Inoperable / Inadequate resetting of on-load release gear Inoperable lifeboat steering Operational readiness of lifesaving appliances Launching and recovery arrangements for survival craft Inflatable liferafts Inoperable / Inadequate resetting of on-load 22 17 23 release gear Wasted / Holed davit 22 19 11 Defective winch brake 4 2 5 Expired service period / hydrostatic release unit (4) Propulsion and Auxiliary Machinery Major types and details of deficiencies noted under the category of Propulsion and Auxiliary Machinery are shown in Table 2.3.2-(4) below. Table 2.3.2-(4) Propulsion and Auxiliary Machinery Item 09 10 11 Noted Deficiencies Inoperable Initial start arrangements Auxiliary engine 12 16 15 Leakage of oil, dirty blocks Cleanliness of engine room 16 25 13 Excessive oil and bilge in engine room Other (Machinery) 17 15 12 Inoperable incinerator, air compressor, emergency generator Leaking pump, cooling sea water line, mooring winch, steering gear Propulsion main engine 13 17 6 Leakage of oil, cooling water (5) MARPOL-ANNEX I Major types and details of deficiencies noted under the category of MARPOL-ANNEX I are shown in Table 2.3.2-(5) below. Oil filtering equipment (Oily-Water Separating Equipment) Table 2.3.2-(5) MARPOL-ANNEX I Item 09 10 11 Noted Deficiencies 22 33 41 15 ppm alarm arrangement 8 7 10 Failure of alarm Inoperable separator, bilge pump Oily water inside overboard discharging line By-pass line fitted for oil filtering equipment Not familiar with the operation of oil filtering equipment Oil record book 2 3 7 Defective entry in oil record book 19

Oil discharge monitoring and control system Other 4 4 5 Defective automatic stopping device 2 2 5 Inoperable waste oil incinerator (6) Load Lines Major types and details of deficiencies noted under the category of Load Lines are shown in Table 2.3.2-(6) below. Table 2.3.2-(6) Load Lines Item 09 10 11 Noted Deficiencies Wasted/Holed ventilator, air pipes Ventilators, air pipes, casings 34 24 34 Damaged float of air pipe head Damaged closing device Wasted / Holed hatch cover Hatch covers 9 8 9 Wasted hatch cover cleats Wasted rubber packing Doors Cargo and other hatchway 4 5 9 Not weather tight 4 3 8 Wasted / Holed hatch Cover Wasted / Holed hatch coaming (7) Safety of Navigation Major types and details of deficiencies noted under the category of Safety of Navigation are shown in Table 2.3.2-(7) below. Table 2.3.2-(7) Safety of Navigation Item 09 10 11 Noted Deficiencies Navigation charts not updated Charts 15 12 19 Navigation charts for intended voyage not available Voyage data recorder (VDR) Defective VDR / S-VDR 4 4 9 Alarm panel showing system error Nautical publications Nautical publications (tide table, list of lights, list 7 4 7 of radio signals, etc.) not updated Lights, shape, sound-signals Inoperable navigation lights 5 3 7 Navigation lights not supplied by battery (8) Stability, Structure and Related Equipment Major types and details of deficiencies noted under the category of Stability, Structure and Related Equipment are shown in Table 2.3.2-(8) below. Table 2.3.2-(8) Stability, Structure and Related Equipment Item 09 10 11 Noted Deficiencies Emergency lighting, batteries & Deficient batteries/emergency generator 14 13 14 switches Inoperable emergency lighting Inoperable emergency steering Steering Gear 9 5 7 Not familiar with operation of emergency steering Wasted / cracked structural members in WBT Ballast, fuel and other tanks 5 1 7 and FOT 20

(9) SOLAS Related Operational Defects Major types and details of deficiencies noted under the category of SOLAS Related Operational Defects are shown in the Table 2.3.2-(9) below. Fire drills Table 2.3.2-(9) SOLAS Related Operational Defects Item 09 10 11 Noted Deficiencies 5 11 14 Fire drill failed Abandon ship drills Operation of GMDSS equipment 16 9 8 Abandon ship drill failed 7 1 4 Not familiar with the operation of GMDSS (10) Radio Communications Major types and details of deficiencies noted under the category of Radio Communications are shown in the Table 2.3.2-(10) below. Table 2.3.2-(10) Radio communications Item 09 10 11 Noted Deficiencies Reserve source of energy Inoperable radio equipments by DC power 9 4 22 Low voltage MF/HF Radio Installation Not operable 21 16 14 Not operable by DC power EPIRB Not operable 6 4 5 Annual test overdue INMARSAT Not operable 2 4 4 Not operable by DC power (11) Ship s Certificates and Documents Major types and details of deficiencies noted under the category of Ship s Certificates and Documents are shown in Table 2.3.2-(11) below. Table 2.3.2-(11) Ship s Certificates and Documents Item 09 10 11 Noted Deficiencies EIAPP 0 1 3 Certificate not onboard (12) Alarm Signals Major types and details of deficiencies noted under the category of Alarm Signals are shown in Table 2.3.2-(12) below. Table 2.3.2-(12) Alarm Signals Item 09 10 11 Noted Deficiencies Fire alarm 2 6 5 Not operable 21

(13) Certification and Watchkeeping Major types and details of deficiencies noted under the category of Certification and Watchkeeping are shown in Table 2.3.2-(13) below. Certification of master and officers Table 2.3.2-(13) Certification and Watchkeeping Item 09 10 11 Noted Deficiencies 22 10 14 Missing of endorsement on STCW certificates by flag state Valid certificates expired (14) MARPOL Annex IV Major types and details of deficiencies noted under the category of Alarm Signals are shown in Table 2.3.2-(14) below. Table 2.3.2-(14) Alarm Signals Item 09 10 11 Noted Deficiencies Sewage Treatment Plant 4 9 17 Not operable (15) Bulk Carrier Safety Major types and details of deficiencies noted under the category of Bulk Carrier Safety are shown in Table 2.3.2-(15) below. Table 2.3.2-(15) Bulk Carrier Safety Item 09 10 11 Noted Deficiencies Water level indicator 8 6 14 Water ingress alarm/sensor failure 22

2.4 Analysis of Detainable Deficiencies by Port State Tables 2.4.1 to 2.4.8 show the most common deficiencies that resulted in the detention of vessels classed with NK under PSC inspections conducted by the top 10 Port States, by number of detentions reported from 2009 through 2011. 2.4.1 China Table 2.4.1 China Category of Deficiency 2009 2010 2011 Fire Safety Measures 43 74 83 Lifesaving Appliances 28 21 47 MARPOL Annex I 11 22 25 Radio Communications 7 12 21 Load Lines 17 14 18 ISM Related Deficiencies 6 14 16 Stability, Structure and Related Equipment 5 8 13 Propulsion and Auxiliary Machinery 6 12 9 Bulk Carriers add. Safety Measures 6 1 9 MARPOL Annex IV 6 5 7 SOLAS Related Operational Deficiencies 10 3 7 Ships Certificates and Documents 14 5 6 Alarm Signals 12 8 5 Safety of Navigation 6 6 5 Type of Deficiency 2009 2010 2011 Lifeboats 21 15 32 Oil filtering equipment 10 15 19 Fire pumps (including emergency fire pumps) 9 29 18 Fire-dampers, mechanical ventilations 9 18 13 Ventilators, air pipes, casings 6 7 13 Maintenance of the ship and equipment 2 9 10 Fire Prevention 8 2 9 Reserve source of energy 3 1 9 Fixed fire extinguishing installation 0 0 8 Fire detection 5 7 8 Quick closing valves 5 4 8 Emergency lighting, batteries and switches 2 2 7 Water level indicator 4 1 7 Jacketed piping system for high pressure fuel lines 4 5 6 Fire safety 0 0 6 MF/HF radio installation 3 7 5 A total of 290 detainable deficiencies relating to 117 detentions were noted in 2011. (2.5 detainable deficiencies/detention) 23

2.4.2 Australia Table 2.4.2 Australia Category of Deficiency 2009 2010 2011 ISM Related Deficiencies 12 33 45 Lifesaving Appliances 38 25 28 Fire Safety Measures 41 16 23 Radio Communications 17 7 10 Load Lines 12 16 6 MARPOL Annex IV 0 4 6 Safety Navigation 2 2 6 SOLAS Related Operational Deficiencies 1 4 5 Type of Deficiency 2009 2010 2011 Operational readiness of lifesaving appliances 20 15 22 Development of plans for shipboard operations 0 19 20 Fire-dampers, mechanical ventilations 29 9 10 Maintenance of the ship and equipment 7 5 10 Masters responsibility and authority 0 3 10 Lifeboats 9 6 6 Sewage treatment plant 0 4 6 Fire pumps (including emergency fire pumps) 4 2 5 Charts 0 2 4 MF/HF radio installation 11 2 4 Reserve source of energy 3 2 4 A total of 141 detainable deficiencies relating to 83 detentions were noted in 2011. (1.7 detainable deficiencies/detention) 2.4.3 Japan Table 2.4.3 Japan Category of Deficiency 2009 2010 2011 Fire safety measures 12 14 21 SOLAS related operational deficiencies 2 9 13 MARPOL Annex I 1 5 11 ISM related deficiencies 2 9 9 Lifesaving appliances 7 4 7 Load lines 0 1 6 Type of Deficiency 2009 2010 2011 Oil filtering equipment 1 5 11 Fire-dampers, mechanical ventilations 5 0 9 Fire drills 1 6 8 Fire pumps (including emergency fire pumps) 4 3 7 Resources and personnel 0 4 6 A total of 78 detainable deficiencies relating to 40 detentions were noted in 2011. (3 detainable deficiencies/detention) 24