port state inspection bimco web

8/2/2019 Port State Inspection BIMCO Web

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YOUR BimcO gUide tO pRepaRe fOR

www.bimco.org

pORt statecOntROl

inspectiOns

in the Usa


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This guide has been prepared to protectYOU the

crew rom unnecessary problems during Port State

Control inspections when calling at US ports.

This guide is not meant to help the bad guys avoidgetting caught, but rather to help you perorm your

duties in a way that complies with regulations.

When rules are broken you may ace nes and

possibly jail time.

This guide will provide general advice. Detailed

guidelines and instructions are available in the

Saety Management System (SMS) and Ship Security

Plan (SSP).

Introduction2

REMEMBER, ONE MISTAKE CAN JEOPARDIZETHE FUTURE FOR YOU AND YOUR COMPANY


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Port State Control (PSC) is part o an international

eort to identiy and eliminate sub-standard ships.

It is a process by which a country enorces

international rules relating to saety, security andthe environment over oreign ships in its waters.

In addition a country may have its own laws and

regulations or any ship trading in its waters.

Countries have the right to veriy that ships

operating in their waters comply with SOLAS and

MARPOL, and to take action to bring these ships

into compliance i they do not.

The US Coast Guard will take action against shipsthat do not in comply with laws or regulations.

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THE GOAL IS TO IDENTIFY AND ELIMINATESUB-STANDARD SHIPS FROM US WATERS

What is PortState Control?


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In 2007, 8,281 ships rom 84 dierent countries made

82,937 calls at US ports.

USCG conducted 10,423 PSC saety examinations.

152 ships were detained as a result o problems

ound.

In other words, 98.5% o inspections ound ships to

be saely operated!

Problems oundThe reasons that ships get into trouble vary over the

years as the USCG ocuses on current problems.

The Top-Three reasons or 2007 detentions were:

1. Saety

2. Security

3. Pollution

The Facts4

THE POLLUTION OFFENCES MAY GETCREW IN PRISON


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I serious deects are ound during an inspection an

expanded examination will be carried out.

For crew such inspections may result in investigations

o violations o US laws, some o which carry criminalsanctions or the crew.

Lying to ocials, or instance by presenting log

books, Oil Record Books or records with alse or

incorrect entries, carries severe criminal penaltiesin the USA.

The penalties or saety, security or environmental

violations can be less severe.

Consequences5

LYING TO OFFICIALS IS A CRIME IN USA


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A typical PSC Inspection sequence could include:

1. Inspecting the ships certifcates.

2. Looking at the ships condition, equipment andthe crew at work.

3. Looking at any target areas that the PSC Ofcers

prioritise, such as security or pollution.

What are theylooking for?

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IF SOMETHING LOOKS WRONG EXPECT TO BE INVESTIGATED!


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Imagine a PSC Ocer being met at the ship by:

a dirty or oily gangway

a daydreaming watchman

sloppy ISPS procedures

a messy deck and accommodation

crew in doubt o their assigned duties

an unnecessary bad start on what could otherwise

have been a trouble ree PSC!

Good work wasted!7

FIRST IMPRESSIONS HAVE AN IMPACT!


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Once on board, PSC Ocers start by checking the

ships certicates.

They will want to make sure that the ship has the

required certicates, and that they are valid.

Some certicates, such as the IOPP attachments will

tell the PSC Ocer what equipment is on board, and

what related procedures are required.

The inspector will ocus on such equipment and

procedures during his inspections.

SMS procedures may also be checked.

Have all documents ready beore the PSC Ocerarrives!

In the Masters Office8

MAKE SURE THAT PROCEDURESARE BEING FOLLOWED!


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The inormation on the supplement to the IOPP

certicate relates to;

SOPEP,

the Saety Management System, and

machinery spaces.

I there are dierences between the inormation on

these documents and what is ound on board you

should inorm the PSC Ocer and not wait or himto nd out himsel!

Prepare documentation to show that procedures are

being ollowed. Unocial logs and records, such as

sounding books, are treated as ocial documents.

records o drills and exercises

Oil Record Book (ORB), including

waste delivery receipts

Evidence of Compliance9

REMEMBER - CONSISTENCY COUNTS!


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Bridge inspections usually ocus on:

Operational equipment

Nautical publications, charts and postedinormation

English speaking operator o the

radio equipment

Ofcers amiliar with the equipment and

publications, procedures and requirements

in respect o log and record keeping

Equipment can break down or need servicing.

Tell the PSC Ocer!

Ensure that the logs do not contain incorrect entries.

On the Bridge10

IT IS A CRIME TO PRESENTA FALSIFIED LOG IN THE USA!


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In 2007, 17% o deciencies involved problems with

Fire Fighting equipment and Lie Saving Appliances.

Other problems related to security arrangements

improper access controls was a requent issue.

What is the PSC Ofcer looking or?

The presence o required equipment.

The condition o the required equipment.

The knowledge o the crew in respect o the

maintenance and operation o saety equipment

and their own duties.

Evidence that eective saety management systemsand security procedures are in place on board.

Checklists can be ound in the ships Saety Manage-

ment System USE THEM, and remember that it is

a crime to present a alsied checklist to an ocial.

On Deck11

IT IS THE CHECKS NOT THE TICKS THAT COUNT


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The accommodation, including the galley, may

not be important rom a saety and environmental

protection point o view, but the appearance o

the accommodation and galley is important, as it

is oten considered representative or the conditiono the ship and the quality o the management

on board.

Make sure that re doors are not orced open by

unauthorized means not even temporarily.

12Accommodation

HOUSEKEEPING COUNTS!MAKE A GOOD IMPRESSION!


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The inspection o machinery spaces concentrates

on identiying re, personal injury, electrical and

environmental hazards.

The PSC Ocer will ocus on the awareness o andcompliance with the SMS procedures, and the ami-

liarity o the crew with the operation o equipment

such as Oily Water Separator (OWS), emergency re

pump and emergency steering.

Emergency exits must be unobstructed and well

marked and lit and they must not be locked, e.g.

or security purposes, i that prevents their use.

Machinery spaces13

ENSURE THE ENGINE ROOM IS A SAFE AREA


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Inspections are ocused on identiying the intentional

discharges o oil, and on checking i the crew try to

hide violations. When inspecting ships or environ-

mental compliance the PSC Ocer oten looks or:

Genuine entries in the logs and Oil Record Book.

Entries in the ORB in line with statements rom the

crew regarding actual procedures ollowed.

Records o operations, maintenance works and

malunctions o the pollution prevention equipment.

The crew are amiliar with their duties in respect o

operation o pollution prevention equipment under

the SMS.

Signs o tampering with the piping or the electrical

controls on the OWS.

PSC Focus onEnvironmental compliance

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YOU MUST PROVE THAT YOU COMPLY!


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PSC Ocer may ask or an operational test o the

Oily Water Separator. The tests will seek to conrm

the perormance o both the OWS and the engineers

operating the OWS. All engineers assigned with

operation o the OWS should be prepared to conductsuch tests.

Close inspection o Oil Content Monitors should be

expected. NEVER tamper with this equipment as the

PSC Ocer will be looking or signs o tampering.Equipment perormance may also be tested.

Tank levels may be checked to conrm that they are

in accordance with ORB entries.

PSC Ocers may also check incinerators and thestandard discharge connection to veriy regular use.

Any connections, hoses and ttings that can be used to

discharge directly overboard will give rise to suspicion.

Environmentalequipment tests

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PROVE THAT YOU USE THE EQUIPMENT THE RIGHT WAY!


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Ensure that all are amiliar with their environmental

SMS duties.

Make sure repairs, adjustments and maintenance

cannot be read as tampering - and record it inthe ORB immediately.

I dismantling o equipment is required to carry

out tests, then label it accordingly. That will reduce

the risk o being suspected o tampering.

I ships equipment such as a hose is used or

discharge to reception acilities then record it

do not hide it.

Keep the spare parts inventory up-to-date. Donot cause unnecessary suspicion by being unable

to locate the spare parts.

Preparing forinspections:

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CO-OPERATE WITH THE PSC OFFICER DO NOT HIDE FACTS


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There are 3 types o ship inspections or law enorcement

(LE) boardings o particular relevance to seaarers:

Port State Control (PSC) Saety

and environmental inspections

PSC ISPS compliance inspections

LE boardings

Ships may be subjected to more than one inspection

type at a time, and oten ISPS compliance and enorce-ment inspections will be combined with PSC saety

and environmental inspections. The purpose o these

inspections is to ascertain ships compliance with

applicable regulations, as described elsewhere in this

guide. The scope o the inspections may be expanded,

depending on the inspectors ndings, and the shipscrew will usually be acquainted with the cause and

scope o such inspections, including any possible

criminal activity investigation.

LE boardings are dierent. Such boardings are under-taken in cases o an actual security threat or suspicion

o a security threat on board a particular ship.

Any such suspicion may originate rom a wide range

o intelligence inormation. A LE boarding will thereore

usually be unexpected, and depending on circumstances,

the Boarding Ocers conduct may dier substantiallyrom that displayed by Port State Control Ocers during

normal PSC inspections. LE boardings are carried out

to protect the port state, as well as the ship and crew

rom a suspected or actual security threat, or or law

enorcement purposes.

The boarding team will take appropriate precautions

during these inspections and ships crews should ollow

instructions and co-operate with the boarding team.

Inspections in the US:17


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YES NNoYes

Selection based on

classified criteria

LEBoarding? Inspection?

LawEnforcement(LE)

ISPScompliance

Selection based on ISPSCompliance matrix

PSC Safetyenvironment

Selection based on safetyand environmentalcompliance matrix

USCG receivesVessels Notice of

Arrival

The PSC programme is aimed at ensuring compliance

with saety, environmental and security regulations.

Accordingly the track record o the classication so-

ciety, the fag, the ship, and its owners are actors in

the targeting process. In practice, ships are targetedor PSC on the basis o 2 systems:

1. the ISPS matrix and

2. the saety and environmental matrix.

These matrixes are published by the USCG. In ad-

dition, all ships can assess the likelihood o being

subjected to inspections at any time.

In respect o LE boardings, ships are targeted based

on classied inormation and evaluation processes.

Selection of shipsfor inspection:

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3 risk-based vessel selection tools


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The USCG enorces the applicable requirements o

SOLAS Chapter XI-2, the ISPS Code, and the maritime

security regulations authorized by MTSA.

The enorcement will apply to all oreign vesselsunder SOLAS and all oreign commercial vessels

greater than 100 GRT that enter US ports.

The security standards are seamlessly integrated into

the existing Port State Control programme, howeveran ISPS inspection ocuses on compliance with the

ISPS Code.

I the inspection reveals clear grounds or non-com-

pliance with the applicable security requirements,

the Captain O The Port (COTP) imposes more severecontrol and/or enorcement actions.

These actions may include a thorough investigation

with subsequent delay or detention o the ship;

possible restriction o ship operations; expulsiono the ship rom port; and/or lesser administrative

or corrective measures.

ISPS Inspections:19


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A LE boarding diers signicantly rom an ISPS/MTSA

Security Compliance Examination.

The LE boarding o a vessel will be perormed by

an armed boarding team searching the ship andexamining the cargo, relevant documentation, crew,

ocers and persons on board arriving or departing

a US port.

The objective is to deter acts o terrorism and/ortransportation security incidents. The boarding team

is instructed to examine all items that could cause

damage to the US, its people or its possessions.

With this in mind the conduct o the boarding teams

during such boardings may dier signicantly romthat experienced during saety and security inspec-

tions.

A crew exposed to a LE boarding may nd themselves

being subjected to a direct, interrogatory anduncompromising behaviour by the boarding team.

Although this may be a stressul experience, the only

recommendable action under such circumstances is

ull co-operation, patience and non-intererence

while the boarding team is conducting its boarding.

BIMCO enjoys a close and constructive dialogue with

the USCG and other US agencies, amongst others to

ensure that inspections are relevant, air and practi-

cal and that ships are inconvenienced the least.

For this purpose, BIMCO operates a ships report-ing programme that details actual experiences in

connection with inspections around the world. All

reports o experiences are important and welcome.

LE Boardings:20


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I the PSC Ocer nds a problem on your ship,

you should expect that he will take a closer look

at everything.

As a result, he may decide to:

Order that repairs are made to correct the problem

(sometimes beore the ship will be allowed to sail).

I the crew can repair or correct the problem quickly,then the risk o delays and possible nes may be

reduced.

For severe problems, i the PSC Ocer thinks that US

laws have been broken, a criminal investigation could

be started. A criminal investigation could aim at boththe Company and the crew on board.

When thingsgo wrong

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LYING TO INVESTIGATORS IN A CRIMINALINVESTIGATION RESULTS WITH PUNISHMENT FARWORSE THAN THE PUNISHMENT FOR VIOLATIONSOF SAFETY AND SECURITY REGULATIONS


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Important things to remember: ALWAYS!!!

Tell the truth

Tell others to tell the truth

Make sure all log entries are

complete and accurate

Know your saety, security and environmentalcompliance duties and do them!

Fix or report deects as soon as possible

Share relevant inormation with the authorities

More inormation is available on:

http://homeport.uscg.mil

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AVOID PROBLEMS RUN A SAFE ANDSECURE SHIP AND BE HONEST WITH PORTSTATE CONTROL OFFICERS


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Certicates

Emergency Generator and Lighting

Main and Emergency Fire Pump

Fixed Deck Foam FF System

Fire Detection System

Fire and Boat Drills

Steering Gear

Oily Water Separator and Bilge Monitor

Saety Management System

Navigation Saety Checks

Conduct a Deck Walk - Structureand Watertight Integrity

ILO Crew living Conditions

Security Compliance

The US PSCChecks include:

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BIMCO

161 Bagsvaerdvej

2880 Bagsvaerd

Denmark

Phone: +45 4436 6800

www.bimco.org

BIMCO is an independent international shipping associa-

tion comprised of ship owners, managers, brokers, agents

and many other stakeholders with vested interests in

the shipping industry. The association acts on behalf of

its global membership to promote higher standards and

greater harmony in regulatory matters. It is a catalyst forthe development and promotion of a fair and equitable

international shipping policy.

This guide provides practical and valuable informa-

tion for the mariner to avoid serious yet common

Port State Control problems that may lead to delaysand detentions in ports throughout the world.

In the spirit of PSC harmonisation and transparency,

I heartily endorse this guide.

Brian Salerno

Rear Admiral, U.S. Coast Guard

BIMCO Reflectingyour interests

port state inspection bimco web

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