Port State

Annual Report on Port State Control regarding the ISM Code

2005

Aug. 2006

CONTENTS Introduction

Chapter 1 ISM Non-compliant Ships 1.1 General 1 1.2 ISM non-compliant ships sorted by Flag State 2 1.3 ISM non-compliant ships sorted by Type of Ship 5 1.4 ISM non-compliant ships sorted by Age of Ship 6 1.5 ISM non-compliant ships sorted by Gross Tonnage 7 1.6

Port State of non-compliant ships 8

Chapter 2 Analysis of deficiencies related to ISM Code 2.1 ISM deficiencies sorted by dominant causes 11 2.2 Number of ISM deficiencies sorted by section of the ISM Code for the past four

years 12

2.3 Number of ISM deficiencies sorted by PSC State 13 2.4 Particulars of ISM deficiencies sorted by PSC State 15

2.4.1 Australia 16 2.4.2 Italy 16 2.4.3 U.K. 17 2.4.4 Germany 17 2.4.5 Belgium 18 2.4.6 India 19

Chapter 3 ISM deficiencies and Action Code

3.1 ISM deficiencies and Action Codes 20 3.2 Action Code sorted by section of the ISM Code 21

Chapter 4 Companies managing the ISM non-compliant ships

4.1 Management companies and number of ships 24 4.2 Management companies and years of ISM system operation 25 4.3 Nationalities of companies managing ISM non-compliant ships 26

Chapter 5 Analysis of ISM Non-compliant Ships based on Open Information

5.1 General 27 5.2 ISM non-compliant ships sorted by Flag State 27 5.3 ISM non-compliant ships sorted by Type of Ship 28 5.4 5.5 5.6 5.7

ISM non-compliant ships sorted by Age of Ship ISM non-compliant ships sorted by Gross Tonnage ISM non-compliant ships sorted by Port State Nationalities of companies managing ISM non-compliant ships

28 29 29 30

Conclusions 32

Introduction This Annual Report summarizes reports collected by the Head Office of ClassNK from its Branch and Overseas Offices, Flag States and various ship management companies on current activities relating to PSC all over the world, during the year 2005, from January to December. Also included is information revealed on web sites by the PSC authorities about the ships against which actions had been taken by them, especially regarding ISM Code related deficiencies. ClassNK has compiled this Annual Report in the hope that such information be helpful to all personnel concerned, in order to better their understanding of PSCs attitude to the ISM Code and for the further improvement of their safety management systems. Chapter 1 presents various tables and figures that show the number of ships against which action had been taken by PSC for ISM Code related deficiencies (hereunder referred to as ISM non-compliant ship) among those ships classed with NK or ships for which the SMC was issued by NK (hereunder referred to as NKSMC ship). Analyses were made for five types of breakdown, namely by Flag State, Type of Ship, Age of Ship, Gross Tonnage and Port State. Chapter 2 presents the results of analyses of ISM deficiencies pointed out by PSC. The breakdowns of deficiencies have been analyzed by number of ISM deficiencies per ship, by the requirements referring to each section of the ISM Code, and by those examples that resulted in the detention of ships. Chapter 3 presents the results of analyses of the actions taken by PSC for ISM deficiencies and their relation to each section of the ISM Code. Chapter 4 presents the actual situation of companies that are managing ships identified with ISM deficiencies, including the size of company and the relationship between years of system operation experience and number of ISM non-compliant ships. Chapter 5 presents the results of various analyses of ISM non-compliant ships (NKSMC ships) based on information obtained from the web sites of the Tokyo MOU, Paris MOU and USCG (the same as last year), the data of which shows more than 6.3 times the number of ISM non-compliant ships compared with ClassNK data.

Note: Definitions of key words used in this Report: PSCO: Port State Control Officer ISM deficiency: a deficiency related to the requirements of the ISM Code ISM non-compliant ship: a ship where action is taken by PSC due to ISM Code related

deficiencies, i.e. due to non-compliance with the ISM Code. Action taken by PSC: directives given by PSCO to a ship to take corrective action to rectify an ISM deficiency(non-compliance with the ISM Code) pointed out by a PSCO NKSMC: a ship holding a Safety Management Certificate issued by NK NKDOC: a company holding a Document of Compliance issued by NK RO: (Recognized Organization) an organization recognized by a Flag State to conduct audits and issue certificates on its behalf

1

Chapter 1 ISM Non-compliant Ships 1.1 General During the one year period from January to December 2005, NK Head Office received reports from its Branch and Overseas Offices, ship management companies, Flag States and other parties, on a total of 96 ISM non-compliant ships, which was 0.64 times the 150 ships of 2004. Of the total of 96 ISM non-compliant ships, 81 ships were NKSMC ships; of which 67 ships were classed with NK and 14 ships were classed with other societies. The total number includes 15 ships classed with NK but in possession of SMCs issued by other ROs. The number of ISM non-compliant ships during the past five years sorted by SMC issuing organizations is shown on Table 1.1.1 and Fig. 1.1.1.

Tab.1.1.1 ISM non-compliant ships sorted by SMC issuing organization ISM non-compliant ships 2001 2002 2003 2004 2005

NK classed ships with SMC issued by other RO 11 53 77 13 15

NKSMC ships classed with other society 5 16 17 15 14

NKSMC ships classed with NK 70 135 155 122 67

Total 86 204 249 150 96

Fig.1.1.1 ISM non-compliant ships sorted by SMC issuing organization The total number of ISM deficiencies for all 96 ISM non-compliant ships was 158 items, which was a steep decrease to 0.32 times that of 2003 and 0.63 times that of 2004.

Fig.1.1.2 Total number of ISM deficiencies for the past four years

0 50 100 150 200 250 300 350 400 450 500

2005

2004

2003

2002

Number of ISM deficiencies

158

350

250 491

46 4545

0

2 0

4 0

6 0

8 0

1 0 0

1 2 0

1 4 0

1 6 0

2 0 0 1 2 0 0 2 2 0 0 3 2 0 0 4 2 0 0 5

N K c la s s e d s h ip s w it h S M C is s u e d b y o t h e r R O

N K S M C s h ip s c la s s e d w it h o t h e r s o c ie t y

N K S M C s h ip s c la s s e d w it h N K

135

155

Number of ISM non-compliant ships 70 67

122

2

1.2 ISM non-compliant ships sorted by Flag State

1.2.1 ISM non-compliant ships sorted by Flag State in 2005 Flag states of ISM non-compliant NKSMC ships (81 ships) and the percentage of non-compliance are listed in Table 1.2.1 and Fig. 1.2.1. (Percentage of noncompliance = Number of ISM non-compliant ships/ Number of NKSMC ships x 100)

Tab.1.2.1 ISM non-compliant ships sorted by Flag State in 2005

Flag State No. of ISM

non-compliant ships(A)

No. of NKSMC ships(B)

Percentage(A/B)

Thailand 7 84 8.3 Marshall Islands 2 40 5.0

Malaysia 3 70 4.3 Hong Kong 10 244 4.1

Cyprus 3 85 3.5 Turkey 2 57 3.5

Philippine 2 89 2.2 Panama 40 2053 1.9

Singapore 7 405 1.7 Malta 2 133 1.5

Bahamas 1 68 1.5 Liberia 1 184 0.5 Others 1 262 0.4 Total 81 3774 2.1

Fig.1.2.1 Percentage of non-compliant ships sorted by Flag State2005(%) This data includes only those Flag States which have 30 or more NKSMC ships.

0

1

2

3

4

5

6

7

8

9

Thail

and

Marsh

all Is

lands

Malay

sia

Hong

Kon

g

Cypu

rus

Turke

y

Philip

pines

Pana

ma

Singa

pore

Malta

Baha

ma

Liberi

a

Othe

rs

Percentage of ISM non-compliant ships

3

1.2.2 ISM non-compliant ships sorted by Flag State for over four years. The total numbers and percentages of ISM non-compliant NKSMC ships sorted by Flag State over four years are shown in the following Tables (1.2.2 & 1.2.3) and Figures (1.2.2 & 1.2.3). As for the number of ISM non-compliant ships, Panama decreased by about 38% over the previous year, Singapore, Cyprus, Malta and Liberia were largely reduced in comparison with the previous year, and Hong Kong shows a tendency to decrease, while Thailand is increasing. (There were no ISM non-compliant ships under Japanese Flag.) Tab. 1.2.2 Number of ISM non-compliant NKSMC ships

Flag State 2002 2003 2004 2005 Panama 79 87 64 40

Hong Kong 5 9 13 10 Singapore 9 15 14 7 Thailand 1 4 2 7 Cyprus 13 14 6 3 Malaysia 5 2 2 3

Malta 6 9 8 2 Turkey 7 3 4 2

Philippines 1 6 4 2 Marshal Islands - - - 2

Liberia 10 6 9 1 Bahamas - 2 1 1

Other 12 17 14 1 Total 151 172 137 81

Fig.1.2.2 Number of ISM non-compliant NKSMC ships

0

10

20

30

40

50

60

70

80

90

Pana

ma

Hong

Kon

g

Sing

apor

e

Thail

and

Cypr

us

Mala

ysia

Malt

a

Turk

ey

Philip

pine

sM

arsh

all Is

lands

Libe

ria

Baha

mas

2002200320042005

Number of ISM non-compliant ships

4

Percentages of ISM non-compliant ships are shown in Table 1.2.3. and Fig.1.2.3. No ISM non-compliant ship for Saint Vincent Flag which was projected in percentage of ISM non-compliant ships of last year has been observed. Thailand became worse again although had improved in 2004, and also Malaysia showed a tendency to increase. Hong Kong, Cyprus and Turkey were still above the average although largely improving, and Singapore, Panama and Malta were improving and below the average. Also Liberia was largely improved to 0.5% of ISM non-compliant ships from 5.3% in 2004. (It seems that the Flag States are seriously tackling PSC problems which may have contributed to an improvement in the percentages of ISM non-compliant ships.)

Tab.1.2.3 Percentage of ISM non-compliant ships() Flag State 2002 2003 2004 2005 Thailand 1.2 5.8 2.3 8.3

Marshall Islands - - - 5.0 Malaysia 7.8 2.7 2.7 4.3

Hong Kong 4.3 6.3 5.9 4.1 Cyprus 11.3 12.8 6.5 3.5 Turkey 9.3 4.8 6.3 3.5

Philippines 4.0 4.0 0 2.2 Panama 4.0 4.6 3.3 1.9

Singapore 2.4 4.0 3.6 1.7 Malta 6.7 7.4 5.6 1.5

Bahamas - 3.8 1.6 1.5 Liberia 6.7 3.9 5.3 0.5 Total 4.4 5.0 3.8 2.1

Fig.1.2.3 Percentage of ISM non-compliant NKSMC ships (%) This data includes only those Flag States which have 30 or more NKSMC ships.

0

2

4

6

8

10

12

14

Thail

and

Mar

shall

Islan

ds

Mala

ysia

Hong

Kon

g

Cypu

rus

Turk

eyPh

ilippi

nes

Pana

ma

Sing

apor

e

Malt

a

Baha

mas

Libe

ria

2002

2003

2004

2005

Number of ISM non-compliant ships

5

1.3 ISM non-compliant ships sorted by Type of Ship. The total number of NKSMC ships (3774 ships) can be sorted into various types of ships as shown in Table 1.3.1. Reflecting the ongoing good shipping market, the total number of registered ships with NKSMC increased 3.6% compared with the previous year, of which the increased ratios for bulk carriers and oil tankers were relatively high at 5.7% and 7.6% respectively. The percentage of ISM non-compliant ships for all NKSMC ships improved to 2.1%. The breakdown of this percentage for each type of ship was: bulk carriers 3.4%, other cargo ships 2.2%, oil tankers 0.7%, chemical tankers and gas carriers 0%. The decreasing of percentages for oil tankers was notable, and both chemical tankers and gas carriers were nil. As for other cargo ship, it showed a tendency towards decreasing, but was still above the average. As for bulk carriers, it was still high above the average. Tab.1.3.1 ISM non-compliant ships sorted by Type of Ship

Percentage (%) A/B

Type of Ship

No. of ISM

non-compliant

NKSMC ships

(A)

No. of NKSMC

All Ships

(B) 2002 2003 2004 2005

Percentage of

each Ships

Type (B/C)

Bulk Carrier 43 1265 4.5 4.9 4.4 3.4 34

Other Cargo 33 1523 5.1 6.8 4.2 2.2 40

Oil Tanker 5 763 3.0 1.5 2.5 0.7 20

Chemical Tanker 0 39 6.7 5.0 2.4 0 1

Gas Carrier 0 178 2.0 5.1 0.6 0 5

Passenger & HSC 0 6 0 0 0 0 0(0.2)

Total 81 3774(C) 4.4 5.0 3.8 2.1 100

Fig.1.3.1 Percentage of NKSMC Ships sorted by Type of Ship(2005)

Gas Carrier 5% Oil Tanker 20%Chemical Tanker 1%

0

1

2

3

4

5

6

7

B u l kC a r r i e r

O t h e rc a r g o

O i l T a n k e r C h e m i c a lT a n k e r

G a sC a r r i e r

P a s s e n g e r& H S C

2 0 0 32 0 0 42 0 0 5

Fig.1.3.2 Percentage of ISM non-compliant ships sorted by Type of Ship

Gas Carrier 5% Oil Tanker 19%Chemical Tanker 1%

B u lk C a r r ie rG a s C a r r ie rO i l T a n k e rC h e m ic a l T a n k e rO t h e r C a r g oP a s s a n g e r & H S C

Passenger & HSC 0.2%Other Cargo 40% Bulk Carrier 34%

Percentage of ISM non-compliant ships (%)

Chemical Tanker 1% Oil Tanker 20%Gas Carrier 5%

6

1.4 ISM non-compliant ships sorted by Age of Ship The number of ISM non-compliant ships and their percentage of the total NKSMC ships, sorted by Age of Ships over the past four years are shown in Table 1.4.1 and Fig. 1.4.1. Tab.1.4.1. ISM non-compliant ships of NKSMC ships sorted by Age of Ship

ISM non-compliant ships(A) NKSMC Ships(B) Ship's Age 2002 2003 2004 2005 2002 2003 2004 2005

0 to 4 27 16 17 6 959 866 898 991

5 to 9 29 39 21 14 952 1039 1087 1039

10 to 14 15 25 22 14 471 452 522 599

15 to 19 49 39 21 10 510 467 392 365

20 to 24 21 40 46 30 369 424 529 543

25 and more 10 13 10 7 186 186 212 237

Fig.1.4.1. Percentage of ISM non-compliant ships of NKSMC ships sorted by Age of Ship (%)

Percentage = A/B x 100(%) In general, the higher the age of ship, the higher the percentage of ISM non-compliance, as we have seen in every year. In 2005, the percentage for ships of 10 years and above exceeded the average of the total, and for ships of the age 20 to 24 years was particularly high(5.5%). Fig.1.4.2 shows the percentage of ISM non-compliant ships sorted by Age of Ship for three different types of ships. The percentage for bulk carrier increases rapidly if the age is over 10 years, and as for other cargo ship and oil tanker, these also increase from over 15 years and show a high percentage for ships of the age 20 to 24 years. These figures may depend on company maintenance policies for ships and equipment by respective type or age of ship.

Fig. 1.4.2 Percentage of ISM non-compliant ships sorted by Age of Ship for three types of NKSMC ships

0

2

4

6

8

0 t o 4 5 t o 9 1 0 t o 1 4 1 5 t o 1 9 2 0 t o 2 4 2 5 a n d m o r e

O t h e r C a r g o

B u l k C a r r i e r

O i l T a n k e rPercentage of ISM non-compliant ships ()


0

1

2

3

4

5

6

7

8

9

1 0


2 0 0 22 0 0 32 0 0 42 0 0 5

7

1.5 ISM non-compliant ships sorted by Gross Tonnage The number of ISM non-compliant ships and their percentage of NKSMC ships sorted by Gross Tonnage is shown in Table 1.5.1 and Fig. 1.5.1. Tab.1.5.1 Number of ISM non-compliant ships sorted by Gross Tonnage

ISM Non-compliant ships(A) NKSMC ships(B) G/T (x 1000) 2002 2003 2004 2005 2002 2003 2004 2005

0 to 10 70 83 54 22 1239 1228 1264 1249

10 to 20 26 42 36 22 763 716 731 745

20 to 30 31 13 15 11 396 426 474 490

30 to 40 8 15 11 11 383 366 402 445

40 to 50 5 6 8 6 221 235 251 258

50 to 60 3 0 5 0 108 119 140 153

60 to 80 1 4 6 5 107 102 115 127

80 and more 7 9 2 4 235 242 263 307

Fig.1.5.1 Percentage of ISM non-compliant NKSMC ships sorted by Gross Tonnage for over past four years (%) Percentage = A/B x 100 (%) In 2005, the percentage of ISM non-compliant ships for 60,000 to 80,000 G/T was particularly high (5 ships, 3.9%), and for 10,000 to 50,000 exceeded the average percentage, of which 68% were bulk carriers. Non-compliant ships for 60,000 to 80,000 G/T were bulk carrier, which might be Panamax type without cargo handling gear, three of which were pointed out as a non-conformity of maintenance (ISM code 10). On the other hand, as for ISM non-compliant ships for 10,000 to 20,000 (22 ships, 3.0%), 59% of them were bulk carriers, 64% of them were over 20 years and also 64% of them were pointed out as a non-conformity of maintenance (ISM code 10). Therefore, the companies managing old-aged bulk carriers are requested to enhance their monitoring for shipboard maintenance.

G/T ( x 1000)0

1

2

3

4

5

6

7

8

0 to 10 10 to 20 20 to 30 30 to 40 40 to 50 50 to 60 60 to 80 80 and more

2002200320042005


8

1.6 Port States of ISM non-compliant ships The numbers of ISM non-compliant ships sorted by six regional areas of the world and Port State are shown in Tab.1.6.1 and 1.6.2, and Fig.1.6.1 and 1.6.2. In comparison with the previous year, the numbers in Asia and North America have been decreasing, but in Oceania have been increasing. The percentage of ships for respective areas in 2005 were varied at 58% in Asia, 146% in Europe and 183% in Oceania, compared to the previous year, and may have been affected by several campaigns implemented by the respective MOUs. Tab.1.6.1 Number of ISM non-compliant ships sorted into six regional areas and their percentage.

Percentage

(AB) (%) Area

No. of ISM

non-compliant

ships (A) 2003 2004 2005

Asia 24 54 43 25

Europe 33 26 24 35

Oceania 32 9 18 33

North America 6 8 12 6

South America 1 2 2 1

Russia 0 1 1 0

Total 96B 100 (%) 100 (%) 100(%)

Fig.1.6.1 Percentage of ships sorted by area

Asia 43 Europe 24%

0 5 10 15 20 25 30

G ermany

Hong Kong

New Zea land

France

India

C hina

Be lgium

Ne the rland

U.S .A.

Ita ly

U.K .

Japan

Aus tra lia

Country No. of non-compliant Ships

Australia 29 Japan 14 U.K. 9 Italy 7 U.S.A 5

Netherlands 4 Belgium 4 China 3 India 3

France 3 New Zealand 3 Hong Kong 2 Germany 2

Tab.1.6.2 Number of ISM non-compliant ships sorted by Port State (2005)

Fig.1.6.2 Number of ISM non-compliant ships sorted by Port State(2005)

Number of non-compliant ships

Asia 25

Europe 35

Oceania 33

North America 6 South America 1

9

The numbers of ISM non-compliant ships sorted by Port State over four years are shown in Tab.1.6.3 and Fig.1.6.3. Total numbers of ISM non-compliant ships were drastically decreasing in comparison with the previous year (64% of the previous year), and among those Port States, it was remarkably decreased in Japan, U.S.A., Korea and Hong Kong. However, Australia still remained high compared with other States. Tab.1.6.3 Number of ISM non-compliant ships sorted by Port State

Number of ISM non-compliant ships Port State 2002 2003 2004 2005

Australia 31 23 27 29 Japan 38 63 30 14 U.K. 5 17 8 9 Italy 5 6 6 7 U.S.A 15 11 12 5

Netherlands 21 11 9 4 Belgium 3 11 1 4 China 10 13 8 3 India 4 3 5 3

France 3 3 3 3 New Zealand 0 0 1 3 Hong Kong 23 39 9 2 Germany 7 7 4 2

Korea 7 11 8 1 Canada 6 10 6 1 Brazil 0 3 0 1 Poland 0 2 0 1

Singapore 5 3 3 0 Portugal 8 2 2 0

Chile 2 0 2 0 Spain 2 1 1 0 Russia 3 1 1 0 Greece 1 1 1 0 Others 5 8 3 4 Total 204 249 150 96

10

0 10 20 30 40 50 60 70

Greece

Russia

Spain

Chile

Portugal

Singapore

Poland

Brazil

Canada

Korea

Germany

Hong Kong

New Zealand

France

India

China

Belgium

Netherland

U.S.A.

Italy

U.K.

Japan

Australia

2002

2003

2004

2005

Fig.1.6.3 Number of ISM non-compliant ships sorted by Port State

11

Chapter 2 Analysis of deficiencies related to the ISM Code

2.1 ISM deficiencies classified by dominant cause During 2005, the total number of ISM deficiencies reported for all 96 ISM non-compliant ships was 158 items as shown in Table 2.1.1. The average number of deficiencies per ship was 1.65/ship, which was almost the same as 2004 as shown in Fig. 2.1.1. Tab.2.1.1 Number of ISM deficiencies of ISM non-compliant ships

Numbers of ISM deficiencies in 2005 sorted by ISM Code sections are shown in Table 2.1.2 and Figure 2.1.2

1 . 4

1 . 5

1 . 6

1 . 7

1 . 8

1 . 9

2

2 0 0 2 2 0 0 3 2 0 0 4 2 0 0 5

Year

No. of

deficiencies

(A)

Ships

(B)

Rate

(A/B)

2002 350 204 1.71

2003 491 249 1.97

2004 250 150 1.67

2005 158 96 1.65

Fig. 2.1.1 Number of ISM deficiencies per ship

0 10 20 30 40 50 60 70 80

Others 99.

Certification13.

Company Review12.

Documentation11.

Maintenance10.

Non-conformity9.

EmergencyPreparedness8.

Shipboard Operation7.

Resources andPersonnel6.

Master'sResponsibility 5.

Designated Person 4.

CompanyResponsibilities 3.

Safety Policy 2.

General 1.

ISM Code section No of ISM

deficiencies

1.General 3

2.Safety Policy 2

3.Company Responsibilities 4

4.Designated Person 0

5.Master's Responsibility 4

6.Resources and Personnel 11

7.Shipboard Operation 16

8.Emergency Preparedness 21

9.Non-conformity 21

10.Maintenance 68

11.Documentation 2

12.Company Review 3

13.Certification 0

99. Others 3

Total 158

Tab.2.1.2 Number of ISM deficiencies sorted by ISM Code section2005

Fig. 2.1.2 Number of ISM deficiencies sorted by ISM Code section


(%)

12

2.2 Number of ISM deficiencies sorted by section of the ISM Code for the past four years

The number of ISM deficiencies sorted by ISM Code section for the past four years is shown in the following Tables 2.2.1 and Figures 2.2.1. Tab.2.2.1 Number of ISM deficiencies sorted by ISM Code section for the past four years

ISM Code section Year

1 2 3 4 5 6 7 8 9 10 11 12 13 99 Total2002 6 9 1 3 20 53 37 46 18 101 31 10 15 - 350

2003 1 8 12 1 24 60 45 96 23 159 43 13 6 - 491

2004 2 18 8 0 8 29 24 37 9 88 16 9 2 - 250

2005 3 2 4 0 4 11 16 21 21 68 2 3 0 3 158

In general, despite the drastic decrease in the total number of ISM deficiencies from the previous year, Section 10 Maintenance still occupied 43% of the total number of deficiencies, and Section 8 Emergency Preparedness and Section 9 Non-conformity occupied 13% respectively, and also Section 7 Shipboard Operation occupied 10%. As for Section 10 and Section 9 in particular, the percentages of these Sections increased compared with the previous year. In this respect, it may be that during PSC inspection, the matters relating to maintenance of the ship and equipment are addressed with greatest care, and PSCO points out ISM-related deficiency as objective evidence of deficiency for Maintenance, and also as for Section 9, PSCO may take a proactive approach to the investigation and corrective actions taken by the company against the deficiencies pointed out at previous PSC inspections, in addition to the rectification of hardware deficiencies at the scene. Therefore, companies are requested to enhance monitoring of the appropriate ships maintenance plan and its proper implementation onboard, and also to maintain good communication with the ship for immediate rectification and corrective actions taken against the deficiencies and non-conformities raised at PSC.

0 20 40 60 80 100 120 140 160Others 99 .

Cert ification 13 .

Company Rev iew 12 .

Docum entation 11 .

Maintenance 10 .

Non-conform ity 9 .

Em ergency Preparedness 8 .

Sh ipboard Operation 7 .

Resources and Personne l 6 .

Master's Responsib il ity 5 .

Designated Person 4 .

Company Responsib il it ies 3 .

Safety Policy 2 .

Genera l .

2002200320042005


Fig.2.2.1 Number of ISM deficiencies sorted by ISM Code section for the past four years

13

2.3 Number of ISM deficiencies sorted by the States of PSC The number of ISM deficiencies pointed out by respective Port States is shown in Table 2.3.1 and Figure 2.3.1. A feature of 2005 is a decrease by 0.63 over the previous year. Particularly in the Tokyo MOU, remarkable decreases in the number from the previous year were noted in Japan (54 to 25), Hong Kong (16 to 2), China (8 to 3) and Korea (11 to 1). Also in the Paris MOU, they decreased about 16% over the previous year, although some of domestic fluctuations exist. In the meantime, in the U.S.A. they also decreased from the previous year (13 to 5). These results can be viewed as stable management being implemented and executed effectively in accordance with the ISM Code which has been effective in the seven years since Phase I and in the three years since Phase II. Tab.2.3.1 Number of ISM deficiencies sorted by the State of PSC (2002-2005)

Port State 2002 2003 2004 2005 Australia 37 31 38 46 Japan 77 107 54 25 U.K. 9 38 12 14 Italy 9 14 15 11 Germany 10 11 11 10 Belgium 5 38 4 8 Netherlands 31 20 16 7 India 5 5 6 7 U.S.A. 25 24 13 5 New Zealand - - 1 5 France 6 9 4 4 China 15 26 8 3 Canada 8 20 20 2 Hong Kong 59 93 16 2 Poland 0 5 0 2 Korea 7 22 11 1 Brazil 0 4 0 1 Singapore 6 5 5 0 Portugal 22 2 2 0 Chile 2 0 5 0 Spain 2 1 1 0 Russian 6 1 1 0 Greece 1 4 2 0 Other 8 12 5 5 Total 350 491 250 158

14

0 20 40 60 80 100 120

Other

Greece

Russian

Spain

Chile

Portugal

Singapore

Brazil

Korea

Poland

Hong Kong

Canada

China

France

New Zealand

U.S.A

India

Netherland

Belgium

Germany

Italy

U.K.

Japan

Australia

2002

2003

2004

2005

Fig. 2.3.1 Number of ISM deficiencies sorted by the State of PSC(2002-2005)


15

2.4 Particulars of deficiencies sorted by PSC The number of ISM deficiencies sorted by their ISM Code sections, and the number identified that caused the detention of ship (Action Code 30) sorted also by the ISM Code sections in eight Port States are shown in Table 2.4. These eight States are Australia, Japan, Italy, U.K., Germany, Belgium, Netherlands and India, which identified a greater number of ISM deficiencies than other States. Actual examples of statements of PSC pointing out the deficiencies that caused the detention of ships are also shown under each State. (No detention case in Japan and Netherlands.) Tab. 2.4. No. of ISM deficiencies sorted by the ISM Code section for each PSC

ISM Code section PSC 1 2 3 4 5 6 7 8 9 10 11 12 99 Total

ISM Deficiencies

2 1 2 2 10 4 6 18 1 46Australia Ships detained 1 3 4 ISM Deficiencies

2 1 4 6 12 25Japan Ships detained 0 ISM Deficiencies

1 1 4 4 1 11Italy Ships detained 1 2 1 1 5 ISM Deficiencies

1 1 2 10 14U.K. Ships detained 2 2 ISM Deficiencies

1 1 1 1 1 3 2 10Germany Ships detained 1 1 1 2 1 6 ISM Deficiencies

2 4 2 8 Belgium Ships detained 1 2 2 5 ISM Deficiencies

1 1 5 7 Netherlands Ships detained 0 ISM Deficiencies

1 1 2 1 1 1 7 India Ships detained 1 2 1 1 1 6 ISM Deficiencies

1 1 3 1 3 5 12 1 1 2 30Other Ships detained 1 2 1 4 8 ISM Deficiencies

3 2 4 0 4 11 16 21 21 68 2 3 3 158Total Ships detained 1 1 0 0 1 5 3 4 4 14 1 2 0 36

ISM Deficiencies: Total number of ISM deficiencies pointed out by the PSC officer Ship detained : Total number of ISM deficiencies pointed out by the PSC officer with Action Code 30

16

2.4.1 Australia

ISM Code section

1 2 3 4 5 6 7 8 9 10 11 12 99 Total

Ships detained 0 0 0 0 0 0 0 0 1 3 0 0 0 4 ISM Deficiencies 2 1 2 0 0 2 10 4 6 18 0 0 1 46

Fig. 2.4.1 ISM Deficiencies that caused ships detention, sorted by ISM Code section ISM Code

section

Action

Code Deficiencies

9 30 The ISM system does not ensure effective analysis of reports and non-conformities, as evidenced by deficiencies No. 6, 7 (Fire damper,/OWS.MARPOL-Annex I related)

10 30 The ISM system does not ensure maintenance of the ship and equipment, as evidenced by deficiencies No.1,2,3,4,5,6 and 7 (Life saving appliance-1, Fire safety measures-3, Alarm signals-1, Safety of Navigation-1 and MARPOL Annex I-1)

10 30 Safety equipment not maintained or properly tested in accordance with ship's procedure.(Engine room fire dampers - not maintained, not close by remote operation)

10 30 Serious structural deficiencies identified are evidence of failure of the ship's Safety Management System. (No.4 TST(S) - Deep web transverse frames wasted and cracked, deck head longitudinal stiffener cracked. Fire main and branch line holed/leaked. Cargo hold No.1/3 - numerous toes and stiffeners cracked.)

2.4.2 Italy

ISM Code section

1 2 3 4 5 6 7 8 9 10 11 12 13 Tota

l Ships detained 0 0 0 0 0 1 0 2 0 1 1 0 0 5

ISM deficiencies 0 0 0 0 0 1 1 4 0 4 1 0 0 11

Fig. 2.4.2 ISM Deficiencies that caused a ships detention, sorted by ISM Code section

0

4

8

1 2

1 6

2 0

1 2 3 4 5 6 7 8 9 1 0 1 1 1 2 9 9

S h i p s d e t a i n e d

I S M d e f i c i e n c i e s

ISM Code section

ISM Code sections

0

1

2

3

4

5

1 2 3 4 5 6 7 8 9 1 0 1 1 1 2 1 3



17

ISM Code

section

Action

Code Deficiencies

6 30 Crew members are not familiar with their duties in an emergency (Crew members are not able to show familiarity with assigned duties during abandon ship drill.)

8 30 Emergency preparedness - Lack of training during abandon ship drill. An additional survey has to be carried out before departure.

8 30 Emergency Fire Pump found inoperative. 10 30 Lifeboat hook found not working - The lack of maintenance

(Lifeboat not ready to use release hooks buckle during drill. Launching arrangement of survival craft not properly maintained.)

11 30 Internal Audit Record not available on board the ship.

2.4.3 U.K.

ISM Code section

1 2 3 4 5 6 7 8 9 10 11 12 13 Total


Fig. 2.4.3 ISM Deficiencies that caused a ships detention, sorted by ISM Code section ISM Code

section

Action

Code Deficiencies

10 30 Maintenance of lifeboat davit not according to safety maintenance system (Lifeboat davits are corroded and perforated.)

10 30 Maintenance of the ship and equipment - Lifeboat, life raft not maintained as required. (Port life boat fibre glass fractured. Winch/lifting gear inoperative.)

2.4.4 Germany

ISM Code section

1 2 3 4 5 6 7 8 9 10 11 12 13 Total

Ships detained 1 1 0 0 0 1 0 0 2 1 0 0 0 6 ISM deficiencies 1 1 0 0 1 1 1 0 3 2 0 0 0 10

0

3

6

9

1 2

1 2 3 4 5 6 7 8 9 1 0 1 1 1 2 1 3

S h ip s d e ta in e dIS M d e f ic ie n c ie s

ISM Code section

18

Fig. 2.4.4 ISM Deficiencies that caused a ships detention, sorted by ISM Code section ISM Code

section

Action

Code Deficiencies

1 30 Situation of detainable deficiencies indicates non conformity of requirements of ISM code. (Total 44 items of deficiencies including 13 items of detainable deficiencies were pointed out.)

2 30 Company has not ensured that policy is implemented and maintained. (Evidence: Numbers of deficiencies arising out of two days inspection.)

6 30 2nd officer showed lack of familiarization with his duties. (Charts and nautical pub.s not up to date. Several nautical instruments inoperative.)

9 30 Company has not established procedures for implementation of corrective actions. (Evidence: Closing out dates of masters NC-report unclear)

9 30 Company has not established procedures for implementation of corrective actions.(Evidence: Former NC from internal audit on17.06.05 not available onboard.)

10 30 Company has not established procedures to ensure that the ship is maintained in conformity with relevant rules and regulations. (Evidence: Bad condition of launching appliances for survival craft.)

2.4.5 Belgium

ISM Code section

1 2 3 4 5 6 7 8 9 10 11 12 13 Total

Ships detained 0 0 0 0 0 0 0 1 0 2 0 2 0 5 ISM deficiencies 0 0 0 0 0 0 0 2 0 4 0 2 0 8

Fig. 2.4.5. ISM Deficiencies that caused a ships detention, sorted by ISM Code section

0

1

2

3

4

5

1 2 3 4 5 6 7 8 9 1 0 1 1 1 2 1 3

S h ip s d e t a in e dIS M d e f ic ie n c ie s

ISM Code section

0

1

2

3

4

5

1 2 3 4 5 6 7 8 9 1 0 1 1 1 2 1 3



ISM Code section

19

ISM Code

section

Action

Code Deficiencies

8 30 Emergency preparedness - not according to SMS Lack of onboard training for emergency

10 30 Maintenance of the ship and equipment - not according to SMS (Launching arrangements for survival craft - not properly maintained.)

10 30 Maintenance of the ship and equipment - not according SMS / Record of maintenance do not reflect the condition of the ship

12 30 Company verification, review and evaluation - not according to SMS 12 30 Company verification, review and evaluation - not according SMS / Corrective action

and necessary shore based support not given by company

2.4.6 India

ISM Code section

1 2 3 4 5 6 7 8 9 10 11 12 13 Total


Fig. 2.4.6 ISM Deficiencies that caused a ships detention, sorted by ISM Code section

ISM Code

section

Action

Code Deficiencies

6 30 Following ISM procedure as per vessel's Quality Manual not complied with - Training plans.

7 30 Implementation of ISM on board - to be more effective. (1.Non familiar with manual 2.Lack of maintenance of safety equipment. 3.Check lists not used prior to departure.

7 30 Following ISM procedure as per vessel's Quality Manual not complied with. -Navigation Passage Plan -Procedure for entering harbor -Navigation in rough sea -Main engine check prior port entry -Aux engine check prior port entry

8 30 Following ISM procedure as per vessel's Quality Manual not complied with. -Master's evaluation subsequent to contingency drill.

9 30 ISM internal audit - Two items of NCNs given on 04-12-2004 to close by 04-02-2005,these items not yet closed by auditors.

10 30 Following ISM procedure as per vessel's Quality Manual not complied with. -Maintenance of Radio equipment -Boiler pressure gauge calibration

0

1

2

3

4

5

1 2 3 4 5 6 7 8 9 1 0 1 1 1 2 1 3

S h ip s d e ta in e dIS M d e f ic ie n c ie s

ISM Code section

20

Chapter 3. ISM deficiencies and Action Codes 3.1 ISM deficiencies and Action Codes For all 158 ISM deficiency items, analyses were undertaken to sort them by their ISM Code sections in the vertical column, and by the Action Code on the horizontal line, as shown in Table 3.1.1. 36 items (23% of all deficiency items) were related to detention of the ship (Action Code 30). This number was 0.65 times the number of 2004 where it was 55 detentions. 6 items (4%) required correction of the defect before departure of the ship (Action Code 17), 9 items (6%) required correction of the major non-conformity before departure (Action Code 19), 92 items (58%) required correction within 3 months (Action Code 18) and 3 items (2%) required correction within 14 days (Action Code 16). The aggregate percentage of the above was 92% of the all deficiency items. Many items relating to Action Code 18 were pointed out regarding Maintenance, Non-conformity report, Shipboard operation and Emergency preparedness as functional deficiencies of key elements of the SMS, and the companies were required to carry out the investigation and analysis of the root cause, and establish measures to prevent recurrence including proper education and training. (Respective Action Code is correspondent to that of Paris and Tokyo MOU except for 70a which corresponds to the USCG.) Tab.3.1.1 ISM deficiencies arranged by matrix of Action Code and ISM Code section

0 10 15 16 17 18 19 30 50 55 70a 99ISM Code

section No. of ISM deficiencies

No action

Rectified Next port 14 days Before

departure3

monthRectifyMNC

DetainedFlag

informed Flag

consulted By next US port

Other

1.General 3 2 1

2. Policy 2 1 1

3.Company 4 4

4. DP 0

5. Master 4 2 1 1

6. Resources 11 4 1 5 1

7. Operation 16 12 3 1

8.Emergency 21 3 10 4 4

9. NC Report 21 14 4 1 2

10. Maintenance 68 3 1 41 4 14 5

11.Documentation 2 1 1

12. Review 3 1 2

99. Others 3 1 1 1

Total(2005) 158 0 0 0 3 6 92 9 36 0 0 1 11

Total(2004) 250 0 1 3 16 28 104 27 55 1 2 0 13

Fig. 3.1.1 Number of ISM deficiencies sorted by Action Code (2004,2005)

0

2 0

4 0

6 0

8 0

1 0 0

1 2 0

0 1 0 1 5 1 6 1 7 1 8 1 9 3 0 5 0 5 5 7 0 9 9

2 0 0 42 0 0 5Number of

ISM deficiencies

Action Code

21

3.2 Action Codes sorted by section of the ISM Code The patterns of Action Codes have been analyzed by the respective section of the ISM Code. Section numbers selected from the ISM Code are 10 "Maintenance of the Ship and Equipment, 8 "Emergency Preparedness, 9 Report and Analysis of Non-conformity, 7 "Development of Plans for Shipboard Operations and 6 "Resources and Personnel. 3.2.1 ISM Code section 10Maintenance of the ship and equipment

Action Code

0 10 15 16 17 18 19 30 50 55 70a 99 Total

2004 3 6 42 9 20 1 7 88Number of ISM

deficiencies 2005 3 1 41 4 14 5 68

Although the number of deficiencies relating to ISM Code Section 10 was 0.77 times that of the previous year, the percentage of the total numbers increased. PSC usually require a correction within 3 months (Action code 18: 41), or detain the ship (Action code 30: 14). In most cases, poor maintenance of hardware such as fire fighting equipment, life saving appliances, bilge separator and closing appliances as required by the relevant Conventions are pointed out, and then improper systems for the maintenance plan and its implementation are pointed out as ISM related deficiencies. It is also noted that no entry or no correct entry to maintenance record compared with actual maintenance condition notes were made. Therefore, companies are requested to conduct proper education and training and also undertake closer monitoring of ships maintenance on board particularly for safety equipment, as this tendency still remains unaltered. Most ISM-related deficiencies resulting in detention ordered by PSC inspectors are derived from non-compliance with the relevant regulations of the International Conventions or Flag State, or observation of a large number of deficiency items for ships maintenance, particularly for inoperative fire dampers, poor maintenance of launching appliances or releasing hooks of survival crafts. In addition, No periodical test or checking for several alarm systems and emergency batteries, etc. and Frozen and stuck air vents of ballast water tanks were pointed out as Action code 18. 3.2.2 ISM Code section 8 Emergency preparedness

Action Code

0 10 15 16 17 18 19 30 50 70a 99 Total

2004 1 2 5 14 7 7 1 37 Number of ISM deficiencies 2005 3 10 4 4 21

0

10

20

30

40

50

0 10 15 16 17 18 19 30 55 70a 99

20042005Number of ISM

deficiencies

0

3

6

9

1 2

1 5

0 1 0 1 5 1 6 1 7 1 8 1 9 3 0 5 0 7 0 a 9 9

2 0 0 42 0 0 5Number of

ISM deficiencies

Action Code

Action Code

22

In 2005, ISM Code 8 deficiencies decreased to 0.57 times those of the previous year, and also the percentage among the total number of deficiencies decreased slightly. Although the percentages of Action code 30 (detention), Action code 19 (rectify MNC) and Action code 17 (rectify before departure) were almost same as the previous year, Action code 18 increased about 10%. Most ships detentions are due to lack of familiarization with fire fighting and life saving drills, and insufficient executions of drills including lifeboat waterborne test at the required interval. Deficiencies of insufficient delivery pressure of emergency fire pump, inoperative fire dampers, inoperative shut down valve for F.O. and also improper training records were also pointed out as a lack of emergency preparedness. Other deficiencies of ISM Code 8 such as poor familiarization for emergency steering gears drills, insufficient knowledge for operation of radio equipment including MF/HF, etc. were pointed out in relation to Code 10 and 6. In this respect, companies are requested to enhance monitoring and instructions (frequent attendance and proper reporting) to the ship to ensure more effective training and education (OJT) for ships crew to prepare for emergency situations including proper maintenance of the relevant equipment. Also companies should pay attention to shipboard drills in order to prevent the detention of the ship due to the above reasons. 3.2.3 ISM Code section 9Reports and Analysis of Non-conformities

Action Code

0 10 15 16 17 18 19 30 55 70a 99 Total

2004 3 4 1 1 9 Number of ISM

deficiencies 2005 14 4 1 2 21

In 2005, ISM Code 9 deficiencies increased 2.3 times over those of the previous year, and also the percentage among the total numbers of deficiencies increased drastically. Although the deficiencies of Action code 30 (detention) was almost same as the previous year, Action codes 18 increased to 14. In cases of any deficiency or defective problems have been reported to the company only by verbal dialogue without written formal reporting in accordance with companys SMS or no written evidences or records for reporting of deficiencies or non-conformities having been kept onboard, these were pointed out as ISM code 9 deficiency. In cases of any deficiencies or non-conformities pointed out by PSC/FSC, internal audit or external audit in the past have not been corrected or confirmed the completion of corrective actions, these were also ISM code 9 related deficiencies. Since these deficiencies have increased rapidly, it is thought that more expanded and detailed PSC inspections for pursuing the corrective actions against the deficiencies or non-conformities pointed out in the past PSC will be conducted. In this respect, companies are requested to establish and keep a good and close communication with respective ships to enhance the reporting of any deficiencies or non-conformities to be taken up immediately, and are also requested to ensure close monitoring and proper educations/instructions to the ship.

Number of ISM

deficiencies

Action Code

0

3

6

9

12

15

0 10 15 16 17 18 19 30 55 70a 99

20042005

23


3.2.4 ISM Code section 7Development of plans for shipboard operation Action Code

0 10 15 16 17 18 19 30 50 70a 99 Total

2004 1 1 4 13 1 1 3 24 Number of ISM

deficiencies 2005 12 3 1 16

In 2005, 4 deficiencies were pointed out for ISM code 7, as checking item for AIS was not included in SMS departure checklist, and others improper descriptions for oil record book and onboard training record book, no execution or wrong entry of several SMS checklists, insufficient voyage planning not complying with SOLAS requirements, No establishment or record of working language onboard were also pointed out. PSC inspectors pointed out safety awareness for cargo handling operation (overload) in addition to the safety of navigation for execution of shipboard operation. As for AIS, these might be pointed out during MOU concentrated campaigns in some areas, but, it is necessary for companies to pay attention to proper implementation and records of shipboard operations by close monitoring, checking and attending ships at a regular interval, and also reviewing and investigating ships reports. 3.2.5 ISM Code section 6Resources and Personnel

Action Code

0 10 15 16 17 18 19 30 50 70 99 Total

2004 1 1 1 7 9 2 8 29 Number of ISM

deficiencies 2005 4 1 5 1 11

In cases where the application for the endorsements of several certifications were not available on board, or unsatisfactory results or evaluations for shipboard drills conducted during PSC inspections due to insufficient familiarization and education on board (OJT), insufficient execution of shipboard operation, such as improper chart corrections or voyage planning by second officer, these were pointed out as ISM Code 6 related deficiencies. In the meantime, in some particular areas, it was ordered to detain the ships due to the expiry of crews medical certificates. Therefore, companies are requested to enhance the education and training on the SMS for the crew and undertake close monitoring for the control of licenses and certification for their crews.

Action Code


0

3

6

9

1 2

1 5

0 1 0 1 5 1 6 1 7 1 8 1 9 3 0 5 0 7 0 a 9 9

2 0 0 42 0 0 5

Action Code


0

3

6

9

1 2

1 5

0 1 0 1 5 1 6 1 7 1 8 1 9 3 0 7 0 a 9 9

2 0 0 42 0 0 5

24

Chapter 4 Companies managing the ISM Non-compliant ships With regard to those companies managing ships that have ISM non-compliant deficiencies, analysis was undertaken regarding the number of ships under their management and the duration of years of SMS operation (counting from the year when the company registered their ISM operation with ClassNK). 4.1 Management companies and number of ships Table 4.1.1 shows the relationship between the number of ISM non-compliant ships and number of ships under management sorted by eight different sizes of companies which have been grouped by the number of ships under their management. For those with 1 to 5 ships, a detailed breakdown is shown. For each group, the percentage of ISM non-compliant ships was calculated. As a result, we can see that percentage of non-compliant ships for the 1-5 group, the 16-20 group, the 21-30 group and the group over 51 exceed the average. The total number of 81 ISM non-compliant ships belonged to 62 companies of which 50 companies hold DOC issued by ClassNK. 11 companies had more than one ISM non-compliant ship, and the worst company had 6 ships. Tab.4.1.1 Number of ISM non-compliant ships and size of company

No. of ships

managed

No. of

Management

companies

No. of ISM

non-compliant

NKSMC ships

(A)

No. of NKSMC

ships

(B)

Percentage (%)

(A/B)

1 126 3 126 2.4

2 78 5 156 3.2

3 54 6 162 3.7

4 57 5 228 2.2

5 38 6 190 3.2

15 353 25 862 2.9

610 95 13 716 1.8

1115 37 8 471 1.7

1620 11 7 185 3.8

2130 19 11 468 2.4

3140 13 4 452 0.9

4150 4 0 180 0.0

50 over 7 13 440 3.0

Total 539 81 3774 2.1

Fig. 4.1.1 Percentage of ISM non-compliant ships sorted by size of companies (%)

0

0 .5

1

1 .5

2

2 .5

3

3 .5

4

1 2 3 4 5 1 5 6 1 0 1 1 1 5 1 6 2 0 2 1 3 0 3 1 4 0 4 1 5 0 O v e r 5 0

Percentage of ISM non-compliant ships ()

25

4.2 Management company and years of ISM system operation In Table 4.2.1 the calendar years are arranged vertically, and number of companies to which DOCs were issued by ClassNK (NKDOC companies) is listed corresponding to the year (when the company registered the ISM operation with ClassNK). For each year the number of ISM non-compliant ships and the number of ships managed by respective companies are listed, and percentage of ISM non-compliant ships was calculated. In general, it can be seen that generally in terms of the percentage of ISM non-compliant ships, the older the registration of the company, the lower the percentage, but, for 2005, the percentage of ISM non-compliant ships for companies registered to ClassNK in 1998 and from 2002 to 2004 exceeded the average Tab.4.2.1 Year of ISM Register of Companies and Non-compliant Ships

Year

No. of NKDOC

company

No. of ISM

non-compliant

ships(A)

No. of NKSMC

ships (B)

Percentage (%)

A/B

1994 4 1 52 1.9

1995 26 12 610 2.0

1996 55 8 660 1.2

1997 93 14 699 2.0

1998 71 14 406 3.4

1999 18 2 166 1.2

2000 13 0 72 0.0

2001 34 1 160 0.6

2002 49 9 272 3.3

2003 23 4 95 4.2

2004 18 2 58 3.4

2005 13 0 43 0.0

Total 417 67 3293 2.0

Fig. 4.2.1 Year of ISM Register of Companies and Percentage of ISM non-compliant ships

0

1

2

3

4

5

1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005

Percentage of ISM non-compliant ships ()

Year of ISM register

26

4.3 Nationalities of companies managing ISM non-compliant ships Table 4.3.1 shows the list of nationalities to which the companies that are managing the ISM non-compliant ships are registered. For each nationality, the percentage of ISM non-compliant ships was calculated against the total number of NKSMC ships. In 2005, the percentage of ISM non-compliant ships under companies in Thailand became drastically worse, and China largely improved, and Taiwan and Philippines improved up to the average, while Greece and Turkey still exceeded the average although showed the improvement. Hong Kong and Malaysia were almost same as the previous year, but still exceeded the average. Singapore and Japan improved greatly.

Tab.4.3.1 Nationality of companies managing ISM non-compliant ships

Nationality

No. of NKDOC

Company No. of NKDOC

non-compliant

ships (A)

No. of NKSMC ships

(B)

Percentage

(A/B)

()

Thailand 8 9 109 8.3

Greece 74 12 290 4.1

Malaysia 17 3 92 3.3

Hong Kong 21 8 253 3.2

Turkey 24 3 99 3.0

Taiwan 14 3 123 2.4

Philippines 16 3 137 2.2

China 28 1 58 1.7

Japan 222 27 1738 1.6

Singapore 47 8 554 1.4

Korea 11 0 62 0.0

Others 57 4 259 1.5

Fig. 4.3.1. Percentage of ISM non-compliant ships sorted by the Nationalities(%)

0

1

2

3

4

5

6

7

8

9

Thail

and

Gree

ce

Malay

sia

Hong

Kon

g

Turk

ey

Taiw

an

Philip

ines

China

Japa

n

Sing

apor

e

Kore

a

Percentage of ISM non-compliant ships(%)

27

Chapter 5 Analysis of ISM Non-compliant Ships based on Open Information 5.1 General This Chapter shows the results of analyses on actions taken by various PSCs for ISM non-compliance by NKSMC ships, based on the data collected from open information revealed on the web sites of the Tokyo MOU, Paris MOU and USCG. As in the previous year, we collected all ISM non-compliance data for respective NKSMC ships from the respective data bases of the MOUs through Equasis, and then investigated the ISM-related deficiencies pointed out by PSCs. Therefore, it was very different in numbers compared to the statistical results in Chapters 1 through 4. Also, open information in respective MOUs does not contain the details of deficiencies including applicable ISM Code and Action Code, etc., The number of ISM non-compliant ships pointed out in the above three areas during the year of 2005 amounted to 510 ships, which is 13.5% of all NKSMC ships (3774).

5.2 ISM non-compliant ships sorted by Flag States The number and percentage of ISM non-compliant ships sorted by Flag State are shown in Table 5.2 and Figure 5.2. Tab.5.2 ISM non-compliant ships sorted by Flag State

Flag State

No. of ISM non-compliant

NKSMC ships (A)

No. of NKSMC All Ships (B)

Percentage of ISM non-compliant ships (A/B %)

Turkey 10 57 17.5 Thailand 14 84 16.7 Panama 325 2053 15.8 Malta 21 133 15.8 Hong Kong 37 244 15.2 Philippines 13 89 14.6 St. Vincent 4 29 13.8 Cyprus 10 85 11.8 Marshall Islands 4 40 10.0 Bahamas 6 68 8.8 Singapore 34 405 8.4 Liberia 14 184 7.6 Malaysia 5 70 7.1 Japan 8 137 5.8 Others 5 96 5.2 Total 510 3774 13.5

28

Fig.5.2 Percentage of ISM non-compliant ships sorted by Flag State 5.3 ISM non-compliant ships sorted by Type of Ship The percentage of ISM non-compliant ships for NKSMC ships in 2005 sorted by various

type of ship are shown in Table 5.3. Chemical tanker was the highest in the percentage and Other cargo ship was the highest in the numbers of ships. The percentage for Phase I was 12% and for Phase II was 15.7% respectively. The percentages for Bulk carrier, Oil tanker and Gas carrier decreased. Tab.5.3 ISM non-compliant ships sorted by Type of Ship

Type of Ship


NKSMC ships (A)



Chemical Tanker 8 39 20.5 Bulk Carrier 207 1265 16.4 Other Cargo Ship 239 1523 15.7 Gas Carrier 12 178 6.7 Oil Tanker 44 763 5.8 Passenger & HSC 0 6 0.0

Total 510 3774 13.5 5.4 ISM non-compliant ships sorted by Age of Ship The percentage of ISM non-compliant ships for NKSMC ships in 2005 sorted by age of ship

are shown in Table 5.4. Percentage for ships not more than 4 years old and not less than 25 years old was relatively low and not exceeding the average, and for ships between 15 and 19 years a bit less than the average. Tab.5.4 ISM non-compliant ships sorted by Age of Ship

Ships Age


NKSMC ships (A)



0 to 4 105 991 10.6 5 to 9 164 1039 15.8

10 to 14 81 599 13.5 15 to 19 45 365 12.3 20 to 24 93 543 17.1

25 and more 22 237 9.3 Total 510 3774 13.5

0

2

4

6

8

1 0

1 2

1 4

1 6

1 8

Turk

ey

Thai

land

Pana

ma

Mal

ta

Hon

g Ko

ng

Phili

ppin

es

St.V

ince

nt

Cyp

urus

Mar

shal

l Isl

ands

Bah

ama

Sing

apor

e

Libe

ria

Mal

aysi

a

Japa

n

Oth

ers

Percentage of ISM non-compliant ships

(%)

29

The percentage of ISM non-compliant ships for bulk carrier, oil tanker and other cargo ship in 2005 sorted by type and age of ship are shown in Fig.5.4. The trends for oil tanker and other cargo ship after 5 years old were almost same.

Fig. 5.4 Percentage of ISM non-compliant ships sorted by Age of Ship for respective Type of Ship 5.5 ISM non-compliant ships sorted by Gross Tonnage

The percentage of ISM non-compliant ships for NKSMC ships in 2005 sorted by gross tonnage are shown in Table 5.5. The percentage for ships up to 50,000 G/T was relatively high and exceeded the average. Tab.5.5 ISM non-compliant ships sorted by Gross Tonnage

G/T (x 1,000)


NKSMC ships (A)



0 to 10 179 1249 14.3 10 to 20 111 745 14.9

20 to 30 72 490 14.7 30 to 40 69 445 15.5 40 to 50 38 258 14.7 50 to 60 3 153 2.0 60 to 80 15 127 11.8

80 and more 23 307 7.5 Total 510 3774 13.5

5.6 ISM Non-compliant Ships sorted by Port State

The number of ISM non-compliant ships acted against in five regional areas is shown in Table 5.6.1 and Figure 5.6.1.

Tab.5.6.1 ISM non-compliant Ships sorted by Port State Area

Regions ISM NC ships Percentage ()

Asia 264 52

Oceania 125 24

Europe 91 18

N/S America 19 4

Russia 11 2

Total 510 100

N/S America 6%

Fig.5.6.1 Percentage of ISM non-compliant ship sorted by PSC areas(%)

Percentage of ISM

non-compliant ships (%)

0

5

1 0

1 5

2 0

2 5

3 0

3 5

4 0


O t h e r C a r g o

B u l k C a r r i e r

O i l T a n k e r

AsiaOceaniaEuropNorth & South AmericaRussia

Europe 18%

Asia 52%

N/S America 4%

Oceania 24%

Russia 2%

30

In 2005, the percentage for PSC regional areas of ISM non-compliant ships was almost same as the previous year. Among such areas, Japan and Australia identified a large number of non-compliant ships compared with other Port States. (These two States accounted for 52% of all ISM non-compliant ships) New Zealand and Germany increased. Tab. 5.6.2 ISM non-compliant Ships sorted by Each PSC State

Country

No. of non-compliant

Ships

Country

No. of non-compliant

Ships Japan 162 Spain 8 Australia 103 Singapore 7 China 62 Chile 7 Korea 24 France 6 United Kingdom 22 Hong Kong 5 New Zealand 22 Belgium 4 Germany 17 Portugal 3 Netherlands 14 Poland 3 Canada 12 Malaysia 2 Russia 11 Vietnam 2 Italy 10 Ireland 1 5.7 Nationalities of Companies Managing ISM non-compliant Ships Table 5.7 and Fig. 5.7 shows the list of nationalities to which the companies that are managing the ISM non-compliant ships in 2005 have registered. The percentages of the companies managing ISM non-compliant ships in Taiwan, China and Korea are high exceeding 20%, and also the companies located in Philippines, Thailand, Japan and Turkey exceeded the average.. Tab.5.7 Nationality of Companies Managing ISM non-compliant Ships

Nationality

No. of NKDOC

Company

No. of NKDOC non-compliant

ships (A)

No. of NKSMC ships (B)

Percentage (A/B %)

Taiwan 14 31 123 25.2 China 28 14 58 24.1 Korea 11 13 62 21.0 Philippines 16 27 137 19.7 Thailand 8 20 109 18.3 Japan 222 276 1738 15.9 Turkey 24 15 99 15.2 Greece 74 34 290 11.7 Hong Kong 21 23 253 9.1 Singapore 47 36 554 6.5 Malaysia 17 5 92 5.4 Others 57 16 259 6.2 Total 539 510 3774 13.5

31

Fig.5.7 Percentage of ISM non-compliant ships sorted by their Management

Nationalities (%)

0

5

1 0

1 5

2 0

2 5

3 0

Taiw

an

Chin

a

Kore

a

Philip

ines

Thai

land

Japa

n

Turk

ey

Gree

ce

Hong

Kon

g

Sing

apor

e

Mal

aysia

Percentage of ISM

non-compliant ships (%)

32

Conclusions This report is the 7th Annual Report on Port State Control regarding the ISM Code issued by ClassNK, summing up the detained ships and deficiencies in relation to the ISM Code for all types of ships that have NK SMCs, through the year 2005. The number of ISM non-compliant ships (NKSMC) has further decreased compared with the previous year, and the average percentage of ISM non-compliant ships in 2005 was 2.1%. It may be that one of factors behind decreasing ISM-related deficiencies is that it has been 7 years since ISM Code Phase I entered into force and 3 years elapsed since Phase II, and the implementation of the ISM Code by the management companies has become comparatively stable and effective. As before, the deficiencies related to ISM Code section 10 Maintenance of the ship and equipment and section 8 Emergency Preparedness still remain too high, but in 2005, the deficiencies related to ISM Code 9: Reports and analysis of non-conformities were drastically increased, which may reflect a new direction for PSC to pursue to make sure of the corrective actions against any deficiencies or non-conformities in the past to ensure safe operations onboard. Therefore, companies are requested to maintain good communication with their ships, in addition to enhancing the monitoring of their ships maintenance condition and also offering further training and education for the said purpose. In general, the data shows that the longer management under SMS has been implemented, the lower the deficiencies of a ship pointed out by PSC, however, in 2005, there was a comparatively high percentage of ISM non-compliant ships managed by the companies registered for NKDOC around 1998, when ISM Code Phase I entered into force, and also the percentage for companies registered in 2002 through 2004 became worse.

As for tankers and gas carriers, the companies managing the said type of ships were requested to participate in a program of Tanker Management and Self Assessment (TMSA) which was developed by Oil Companies International Marine Forum (OCIMF), to incorporate a new scheme for continuous improvement of their SMS and re-develop their system up to a higher level taking TMSA requirements into consideration. The deficiencies of the said type of ships decreased drastically, which may have been a byproduct of the TMSA program.

As for age of ships, it can be said that the percentage of non-compliant ships of age

exceeding 10 years old was above the average in all types of ship, and for oil tanker and other cargo ship, it starts increasing when exceeding 15 years and shows a high percentage during 20-24 years old. For bulk carrier, it increased drastically when exceeding 10 years old, which may be considered due to the companys policies or plans for the maintenance of respective types of old-aged ships.

Looking at Gross Tonnage, relative small (1-20,000GT) bulk carriers or cargo ships, and

also Panamax type bulk carriers were mainly identified for their deficiencies regarding Maintenance, therefore, the companies managing the said type of ships are requested to enhance close monitoring of shipboard maintenance conditions.

In general, in cases where a ship is detained or has pointed out a major non-conformity due to ISM related deficiencies by PSC, an additional audit may be conducted at the scene, where major non-conformities (MNCs) may be raised by the attending auditor, (which are consequently downgraded to non-conformities), to which the company should set out corrective actions for releasing the ship from detention. Most detentions can be released for departure if the MNCs can be downgraded to NCNs by executing the relevant repairs, maintenance works or successful drills for emergency preparedness, etc., however, it still remains to investigate and analyze the root causes of the ISM related deficiencies, to review

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the system and the education and training of crew, which should be resolved by both the management companies and the ships. Companies should remind themselves that once detained, the companies must absorb the costs due to the detention including off-hire time. Therefore, it is important that the company and the ship should keep good communications between them for reporting any deficiencies from the ship and their corrective and preventive actions through a support from the company, and also proper monitoring of the performance of the shipboard operations and maintenance conditions onboard via the internal audits by the company or frequent attendances on the ships, etc. We hope this report will be helpful for the SMS review activities of your company and ships.

Key Contacts Head office Information Center Safety Management Systems Department Nippon Kaiji Kyokai 1-8-5 Ohnodai, Midori-ku, Chiba 267-0056 Tel:+81-43-294-5999 Fax:+81-43-294-7206 E-mail: [email protected] Regional Offices South Asia and Oceania Singapore Office Nippon Kaiji Kyokai 101, Cecil Street, #21-01 Tong Eng Building, Singapore, 069533 Tel: +65-62223133, Fax: +65-62255942 E-mail: [email protected] Middle East, East Mediterranean and Black Sea Piraeus Office Nippon Kaiji Kyokai 39-41 Akti Posidonos, Moschato 183 44, Piraeus, Greece Tel: +30-1-09420020, Fax: +30-1-09420079 E-mail: [email protected]

Europe and Africa London Office Nippon Kaiji Kyokai 6th Floor, Finsbury Circus House, 12-15 Finsbury Circus, London, EC2M 7EB, United Kingdom Tel: +44-20-7621-0963, Fax: +44-20-7626-0383 E-mail: [email protected] The Americas New York office Nippon Kaiji Kyokai One Parker Plaza, 11th Floor 400 Kelby Street, Fort Lee, N.J. 07024, U.S.A. Tel: +1-201-944-8021, Fax: +1-201-944-8183 E-mail: [email protected]

For more information on this publication, please contact the Safety Management Systems Department 1-8-5, Ohnodai, Midori-ku, Chiba 267-0056, Japan

TEL+81-43-294-5999 FAX+81-43-294-7206 e-mail: [email protected] http://www.classnk.or.jp

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