02 Class Survey Issues & PSC Updates - June'15

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    Most Frequent Detainable Deficiencies (Tokyo MOU Reports)

    2013 2014

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    PSC Deficiencies Load Line

    Recent PSC Reports on an ABS Classed Double Hull Oil Carrier and Double Hull Bulk Carrier.

    Q: Which LL Reg identifies guardrail; requirements & what are they??

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    PSC Deficiencies Load Line (Annex I, Chp II, Reg 25) Regulation 25(2): Guard rails or bulwarks shall be fitted around all exposed decks. Regulation 25(3): Guardrails fitted on superstructure and freeboard decks shall have at least three courses. Regulation 25(3b): At least every 3rd stanchion shall be supported by a bracket or stay.

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    PSC Deficiencies Load Line Marks

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    PSC Deficiencies Load Line Marks At Annual LL Surveyor Surveyor to confirm: The freeboard marks are to be sighted, found plainly visible, and recut and/or painted in accordance with the LL Certificate as required. The LL Certificate is to be examined for accuracy.

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    PSC Deficiencies Navigation

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    PSC Deficiencies Navigation

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    ISM related Maintenance of the ship and equipment Development of plans for shipboard operations Emergency preparedness Masters responsibility and authority Safety and environment policy Reports and analysis of nonconformities,

    accidents and hazardous occurrences Documentation STCW MLC

    Port State Control Trending

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    CIC STCW Recording of rest hours

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    Port State Control Trending Main & Auxiliary Machinery Propulsion main engine Auxiliary engine Cleanliness of engine room Insulation soaked (oil) Bilge pumping arrangements Guards around machinery

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    Port State Self-Closing Sounding Pipe Head Without test cock

    2006 built Bulk at Xiamen, P.R. China, Sept14. PSC Inspector raised raised this deficiency as a Code 17.

    ABS Surveyor attended the vessel and reported: Fuel tank sounding pipes are fitted with self-closing weighted devices &

    with a screwed plug instead of a small-diameter self-closing test cock.

    Rectification (Temporary) All of screw plugs were drilled with a through (axial and radial) hole which

    would allow a check on overflow level of the tank.(See below pictures)

    Attending PSCO agree with delete the code 17 (Rectify deficiency before departure) with OSR issued by ABS with a due day of three months for permanent repair.

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    Screwed plug with a through hole and sounding pipe head.

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    SOLAS & ABS Rule requirement

    SOLAS: Chapter II-2/Part B/ Reg.4 /2.2.3.5.3 The termination of sounding pipes are fitted with self-closing blanking devices and with a small-diameter self-closing control cock located below the blanking device for the purpose of ascertaining before the blanking device is opened that oil fuel is not present. ABS Rule SVR 4-6-4/11.3.7(a) ii) The termination of sounding pipes is fitted with a quick-acting self-closing valve and with a small diameter self-closing test cock or equivalent located below the self-closing valve for the purpose of ascertaining that fuel oil is not present before the valve is opened. Provisions are to be made to prevent spillage of fuel oil through the test cock from creating an ignition hazard.

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    Serious Violations

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    Serious Violations

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    MARPOL items Annex I Oil Record Book Oil filtering equipment Shipboard oil pollution emergency plan

    (SOPEP) Oil discharge monitoring and control

    system (ODMC) Control of discharge of oil 15 ppm alarm arrangements Retention of oil on board Suspected discharge violations

    Port State Control Trending

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    Oil Record Book (O.R.B.) Mandatory Entries

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    Oil Record Book (O.R.B) - Deficiencies

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    Oil Filtering Equipment

    Examination. ABS action Rule requirement Test of OWS at each Annual Machinery Survey (AMS)

    At each Special Periodic Survey of Machinery OWS opened up for examination system tested

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    Port State Control Trending

    Stability, structure and related equipment Steering Gear Electrical Equipment general Emergency lighting, batteries and switches Gangway, Accommodation Ladder Closing devices / Watertight doors Stability / Strength / Loading information and

    Instrument. Means of escape Signs/Indications (WT doors, Fire detectors, fire

    dampers, ventilation) Deck/Hull corrosion, Damages impairing

    seaworthiness.

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    Commonly Repeated China MSA Deficiencies

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    Port State Control Trending

    Lifesaving appliances Lifeboats / stowage Lifebuoys Rescue boats Inflatable life rafts / stowage Lifeboat inventory Launching arrangements for survival craft Operational readiness and maintenance Embarkation arrangements survival craft Immersion suits and lifejackets Onboard training and instructions

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    Lifeboats & equipment are a major issue with Class & PSC

    Lifeboats & Launching Appliances

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    Open or Locked??

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    Hook indicator position external

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    Hook indicator position external

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    Lifeboats & Launching Appliances

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    Lifeboat - freefall

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    Lifeboat - freefall

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    Lifeboat - freefall

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    Lifeboat Seatbelts

    LSA code (from MSC 48(66))

    4.6.3 Capsizing and re-righting

    4.6.3.1. Except in free-fall lifeboats, a safety belt shall be found at each indicated seating position. The safety belt shall be designed to hold a person with a mass of 100 kg securely in place when the lifeboat is in a capsized position. Each set of safety belts for a seat shall be of a colour which contrasts with the belts for seats immediately adjacent. free-fall lifeboats shall be fitted with a safety harness at each seat in contrasting colour designed to hold a person with a mass of 100 kg securely in place during a free-fall launch as well as with the lifeboat in capsized position.

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    Embarkation Ladder Damage

    2008 built chemical carrier

    2002 built container carrier

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    Embarkation Ladder Damage

    2007 built oil carrier

    2007 built oil carrier

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    Port State Control Trending

    Fire safety measures Emergency Fire Pump Fire-dampers Fire prevention Firefighting eqpt & appliances Fire detection Fixed firefighting installation Fire pumps Ready availability of ff eqpt International shore connection Jacketed piping for HP fuel line EEBD

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    Port State Control Trending

    Safety of Navigation Nautical publications Charts Lights, shapes and sounds Magnetic compass and Gyro compass Voyage data recorder (VDR or S-VDR) Voyage or passage plan Echo sounding device Radar AIS Rudder angle indicator Emergency steering position communication and compass

    reading LRIT Signaling lamp

    PresenterPresentation NotesOnboard routine maintenance check sheet.

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    ECDIS, Charts and Passage Planning/Monitoring what is being looked at.

    Lack of appropriate, updated, large scale charts/publications for:

    Upcoming voyage Arrival voyage

    Voyage planning / monitoring Berth to berth Infrequent position fixing Position fixing using only one means (eg.

    GPS)

    Lack of position fixing during pilotage

    Safety of Navigation

    PresenterPresentation NotesPhotocopied chartsNo appropriate charts available, including no large scale chartsPassage plan is not carried out Berth to Berth,The passage plan is not updated as result of the changes to the plan. Last minute diversions expect to make EVERY effort to get charts ECDIS will become compulsory for the following vessels on International voyages Tankers greater than 3000Grt and Passenger ships constructed after July 1st 2012Cargo ships other than tankers constructed after July 1st 2013. All Passenger ships will need to be fitted with ECDIS by 01/07/2014 All Tankers will need to be fitted with ECDIS by 01/07/2015 All Cargo ships will need to be fitted with ECDIS not later than the 1st Survey on or after 01/07/2018. Require backups (duplications should have independent source of power);Required to be approved type issued by hydrographic officeApproved ENC charts to be used Australia is now almost fully covered by ENCs, so raster charts are not acceptable for ECDIS useSoftware available for updates and correctionsOfficers to be trained (Generic, Familiarisation and from 2017 Type specific training)Procedures and instructions (ISM)If ECDIS is the primary then we expect the vessel to comply with the requirements.

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    China MSA Navigation Deficiencies

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    COLREG: Navigation Lights 1998 built container carrier was detained due to:

    Horizontal arc of visibility of stern light found not as per COLREG

    This is the 2nd time that a vessel has been detained for this deficiency

    Existing Stern Light New Stern Light

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    Items of Concern Most frequent deficiencies

    Ventilators, Funnel Flaps, Air

    Pipes

    Port State Deficiencies

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    Common deficiencies associated with Ventilators & Air Pipes

    Deficiencies categorized under Fire & Safety 1. Ventilators holed. 2. Ventilators repaired with soft patch/tape. 3. Ventilator cover securing nut broken. 4. Fire flap handle not easily assessed. 5. Fire flaps not closing fully. 6. Funnel dampers not operating properly. 7. Dampers wasted and holed. 8. E/R ventilator fire dampers not operational/not closing fully. 9. Air pipe closing device corrosion, pipe wasted. 10. E/R vent closing lever seized.

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    Louvre Fire Dampers Engine Room Intakes & Exhaust, including Funnel Flaps PSC have detained several vessels in China in 2013,2014 &

    and now in 2015, due to the operation of engine room & funnel dampers. Typical deficiency reported has been:

    i) Fire damper has gap.

    ii) Fire damper cannot close tightly.

    iii) Fire damper cannot close from outside.

    Following slides show 4 similar PSC deficiencies, of which 3 are Code 30 (detained) and one is a code 99 (rectify before departure). In referencing fire dampers we are referring solely to engine room intakes/exhausts and funnel flaps and not fire dampers located in ventilation ducts in fire control boundaries.

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    China PSC Reports on fire dampers.

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    Typical funnel louvre dampers/flaps

  • Highlighting PSC Reports (Case Studies)

    1. a) Accommodation Corridors b) Fuel Oil Tank Valves

    c) CO2 Room A-60 2. Emergency Escape Trunks 3. Engine Room Funnel Flaps

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    Quick Closing Valve of E/G Oil Tank (SOLAS & SVRs)

    SOLAS Chapter II-2/Reg.4.2.2.3.4 Oil fuel pipes, which, if damaged, would allow oil to escape

    from a storage, settling or daily service tank having a capacity of 500ltr and above situated above the double bottom, shall be fitted with a cock or valve directly on the tank capable

    SVRs 4-6-4/13.5.3(a) Required valves (2003). Every fuel oil pipe emanating from any fuel oil tank, which, if

    damaged, would allow fuel oil to escape from the tank, is to be provided with a positive closing valve directly on the tank.

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    SVRs 4-6-4/13.5.3(a) (2013) Valves on Fuel Oil Tanks.

    Required valves (2013). Every fuel oil pipe emanating from any fuel oil tank, which, if damaged, would allow fuel oil to escape from the tank, is to be provided with a positive closing valve. The valve is to be secured directly on the tank. A short length of pipe, with wall thickness in accordance to Column D of 4-6-2/Table 4, connecting the valve to the tank is also acceptable.

    Approved drawing

    Quick closing valve: PSC Interpretation not supported by Busan Eng as the attachment of the valve to the tank by a short length of pipe is permitted per the 2013 SVRs. However, based on the contract date for the vessel and delivery in 2012, the valve should have been fitted directly onto the tank per the rules at that time. PSC Inspector was actually correct.

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    c) CO2 Pilot Pipe In CO2 Room.

    SOLAS Chapter II-2/Reg.9.3.4 & MSC/Circ.1120 PSC Interpretation is not supported by ABS Engineering who have given their interpretation. And contend that SOLAS Chapter II-2 Regulation 13.4.2.1.1 which clearly states; the ladder shall be fixed in such a way that heat is not transferred into the enclosure through non-insulated fixing points does not extend to the brackets as identified in the PSC Report.

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    There have been cases where PSC have correctly identified deficiencies related to funnel fire dampers of the louvre design as below. The deficiencies are usually as a result of the flaps being inoperative and unable to close. However there are cases where the PSC Inspector does not appear to fully understand the requirements and operation of funnel flaps.

    Highlighting PSC Reports (Case Studies)

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    Highlighting PSC Reports (Case Studies)

    2012 Built ABS Classed 34K DWT Bulk Carrier detained due to funnel flaps which cannot be closed tightly. ABS appealed locally this detention and although the RO was not blamed the detention remained.

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    Highlighting PSC Reports (Case Studies)

    SOLAS Reg. II-2/5.2.2.1 "means of control are to be provided for closure of openings in funnels which normally allow exhaust ventilation and closure of ventilation dampers".

    There are NO requirements for the dampers located in the engine room funnels to be of the gastight or watertight type (normally these dampers are located higher than 2.3 m above position 2 and accordingly they are not required to be watertight in accordance with Load Line requirements).

    The funnel flaps are not for forced ventilation they are a natural means of exhaust. Once they are closed and ER ventilation shutdown there is no air flow, no pressure differential across the dampers and if CO2 is released into the machinery space it flows to the lower levels being heavier than air. Construction tolerances do not present a problem.

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    2.14 Fire Dampers, Ref: 46 CFR 72.05-50, 116.610 The construction specifications in Subchapters H and K

    may be applied to fire dampers installed in A-class divisions on all domestic vessels. The regulations require fire dampers to have a casing and blade constructed of at least 3 mm (11 USSG) thick steel, with a maximum gap of 3 mm (1/8 inch) between the blade and the casing. The operating components of the damper such as springs and hinges must be stainless steel or equivalent corrosion resistant construction.

    Slide Number 1PSC Deficiencies Load LinePSC Deficiencies Load Line (Annex I, Chp II, Reg 25) PSC Deficiencies Load Line MarksPSC Deficiencies Load Line MarksPSC Deficiencies NavigationPSC Deficiencies NavigationSlide Number 8CIC STCW Recording of rest hours Port State Control TrendingPort State Self-Closing Sounding Pipe Head Without test cock Screwed plug with a through hole and sounding pipe head.SOLAS & ABS Rule requirementSerious ViolationsSerious ViolationsSlide Number 16Oil Record Book (O.R.B.) Mandatory EntriesOil Record Book (O.R.B) - Deficiencies Oil Filtering EquipmentPort State Control TrendingCommonly Repeated China MSA DeficienciesSlide Number 22Lifeboats & Launching AppliancesSlide Number 24Slide Number 25Slide Number 26Lifeboats & Launching AppliancesLifeboat - freefallLifeboat - freefallLifeboat - freefallLifeboat SeatbeltsEmbarkation Ladder DamageEmbarkation Ladder Damage Port State Control TrendingSlide Number 35ECDIS, Charts and Passage Planning/Monitoring what is being looked at.China MSA Navigation Deficiencies COLREG: Navigation LightsSlide Number 39Common deficiencies associated with Ventilators & Air PipesLouvre Fire Dampers Engine Room Intakes & Exhaust, including Funnel FlapsChina PSC Reports on fire dampers.Typical funnel louvre dampers/flapsSlide Number 44Quick Closing Valve of E/G Oil Tank (SOLAS & SVRs)SVRs 4-6-4/13.5.3(a) (2013) Valves on Fuel Oil Tanks. c) CO2 Pilot Pipe In CO2 Room.There have been cases where PSC have correctly identified deficiencies related to funnel fire dampers of the louvre design as below. The deficiencies are usually as a result of the flaps being inoperative and unable to close. However there are cases where the PSC Inspector does not appear to fully understand the requirements and operation of funnel flaps.Highlighting PSC Reports (Case Studies) Highlighting PSC Reports (Case Studies) Slide Number 51