Pocket checklist to help cut risk of PSC detentions - 2 November 2010
The most common deficiencies noted by Port State Control during 2007-2009 on ships classed by Lloyd’s Register, related to maintenance of ship and equipment. Inspectors found three and a half times as many shortcomings in this category as in any other.
Other unsatisfactory findings related to emergency preparedness, reports and record keeping, documentation, security related deficiencies, shipboard operations plans, resources and personnel, appreciation of company and master responsibility and authority, and safety and environmental policy.
Lloyd’s Register has analysed this data, particularly in the context of the International Safety Management and International Ship and Port Facility codes which provide a key focus for Port State Control. It has also drawn substantially on the experience of the UK P&I Club’s ship inspectors.
The ISM Code aims to ensure safety at sea, preventing human injury and loss of life, and avoiding damage to property and to the marine and other environments. The ISPS Code is designed to ensure security of ships and port facilities. Ship owners and operators must implement an effective safety and security management system to ensure these purposes are met, minimising risk to fleets and avoiding fines and port state detention.
To highlight the shortcomings and provide advice, Lloyd’s Register and the UK P&I Club have produced the convenient and reusable ISM and ISPS Pocket Checklist.
Both codes place an emphasis on clearly designated responsibilities and procedures, adherence to and development of standards, training, drills and exercises, communications, record keeping and continual improvement. This means personnel must be numerically sufficient, listed, competent, qualified, medically fit, well rested and familiar with their duties and responsibilities.
Safety management emphasises risk assessments, internal and external audit, reporting irregularities, accidents, incidents and near misses, and follow up actions to promote safety improvement. Inspection and preventive maintenance of all equipment, machinery and structures, particularly life saving appliances and fire fighting equipment must be carried out within the safety management system. There is a particular focus on pre-empting sudden operational failure of equipment and technical systems which may result in hazardous situations.
The operational shipboard context for using the checklist includes cargo and ballast operations, voyage planning and navigation, pre-arrival and departure checks, watchkeeping, bunkering operations, garbage handling, management of oily residues, sludge and oily water, and safe working procedures relating to enclosed space entry and working aloft, over the side and hot work.
The checklist sets out the ISPS ship security controls which should be established and implemented at all times.
Masters must consider Port State Control while still at sea. If equipment is broken or missing or the ship suffers damage, the master must notify the port authorities prior to entry----and tell them of any permanent or temporary remedies agreed with the Flag State. Otherwise, the Port State has clear grounds for inspection, possibly leading to detention. If the ship is detained or looks like it is going to be, the owner or operator should contact the nearest Lloyd’s Register Group office immediately.
PSC officers always start in the master’s office so certification must be up to date, original and valid. All classification, statutory and other trading certificates must be readily available. They include the company’s document of compliance with annual endorsements, Safety Management Certificate, International Ships Security Certificate, Continuous Synopsis Records, ISM manuals, procedures, instructions and records, the Ship Security Plan and the company’s Safety and Environmental policy.
First impressions are very important with PSC authorities. Gangway and moorings should be in good condition, rigged as required with careful attention paid to wires, steps, gangway net, bottom stanchions and man ropes. There should be no grease from fall wires on steps, handrails or man ropes.
Access should be controlled, with photo ID required for identification. A visitors’ log should be maintained and restricted areas controlled. The gangway watch should be in neat working clothes and wearing appropriate personal protective equipment.
Accommodation and outside decks should be clean, tidy and well illuminated with non-slip walkways on outside decks. PSC officers should be accompanied by a senior officer with keys to secured areas and lockers.
Karl Lumbers, the UK Club’s Loss Prevention Director, explained: “Our inspectors generally find that UK Club-entered ships exhibit and observe high standards in terms of structure, equipment, safety and maintenance and demonstrate a high level of seafarer skills across the operational spectrum.
“However, they are finding that Port State Control is focusing ever more closely on compliance with procedures. It is frustrating and expensive for owners of quality ships to fall foul of PSC for slight deviations from what is laid down in the manuals and compliance guides. This pocket checklist will help masters and operators to avoid fines and detentions for both technical and significant procedural and compliance shortcomings.”
Captain Jim Barclay, Manager of Lloyd’s Register’s Port State Control section, explained: “The objectives of an effective onboard safety management system are to ensure safety at sea, prevent injury and loss of life and avoid damage to the environment and property, as required by the ISM code. Yet PSC inspections increasingly identify ISM failures, often based on a combination of other deficiencies, which result in the costly detention of a ship. This guide will help a ship’s personnel to ensure that all requirements of the ISM and ISPS codes are addressed.”
The ISM and ISPS Pocket Checklist is the fifth in a series of pocket checklists produced by Lloyd’s Register in conjunction with the UK P&I Club to help compliance with international conventions. The others cover Port State Inspections, Life Saving Appliances, Marine Fire Safety and Marine Pollution Prevention. All are available from www.webstore.lr.org or www.ukpandi.com
For further information:
Nick Whitear/Karl Lumbers
Thomas Miller P&I Ltd
Tel: +44 (0) 20 7283 4646
Email: firstname.lastname@example.org OR email@example.com
Lloyd’s Register contact:
Tel: +44 (0) 20 7423 1706
Dunelm Public Relations
Tel: +44 (0) 20 7345 5232
Fax: +44 (0) 20 7345 5234