PORT STATE CONTROL &
ISM COMPLIANCE - 10 YEARS AFTER
THE INITIAL IMPLEMENTATION
10 DECEMBER 2008 – Σ.Δ.Ν.Μ.Ε.
STELIOS D. MARANTIS
SENIOR ISM-ISPS SPECIALIST
PORT STATE CONTROL
LLOYD’S REGISTER EMEA
What is Port State Control?
A SYSTEM designed to:
•
ensure foreign ships comply with international safety, security
and environmental standards (SOLAS 74/88, MARPOL 73/78,
ISM/ISPS, STCW, TONNAGE 69 )
•
And prevent substandard ships from sailing (i.e. detain)
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The substandard ship
defined as:
•
“A ship whose hull, machinery, equipment, or
operational safety is substantially below the standards
required by the relevant convention
or
•
whose crew is NOT in conformance with the safe
manning document.”
(Text taken from IMO Procedures for PSC 2000 Edition.)
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PSC is guided by:
IMO RES A.787(19) ‘Procedures for port State control’
as amended by A.882(21),
These procedures include provisions for the conduct of
Port State Control Inspections including:
•
•
•
•
•
guidance for grounds of detentions,
competence and training requirements of PSC officers
safety
pollution prevention
manning requirements.
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What PSCOs are guided to look for:
IMO Resolution 787(19)
A well maintained ship with …
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certificates in order
•
log books filled in correctly
•
navigational charts up to date
•
lifesaving appliances as required
•
fire fighting equipment as required
•
Marpol related items as required
•
ISM & ISPS issues as required
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If all is well…….
The PSCOs will probably go elsewhere….
If not !!!….
They probably have :
“CLEAR GROUNDS” for a “MORE DETAILED INSPECTION”
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Paris MOU “Mandatory Expanded Inspections”
•
Introduced by the EU Directive 2001/106/EC
(Obligatory to EU countries from 30-06-96
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Mandatory to all “high risk” vessels within Paris MOU every12 months
•
High Risk vessels:
•
•
•
•
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Bulk Carriers more than 12 years old,
Tankers more than 15years old and 3000 GT,
Gas and Chemical Carriers more than 10years old,
Passenger Ships more than 15years old
Failure to notify the PSC may raise a deficiency against section 10 of ISM
code (maintenance, reporting of technical deficiencies, etc.)
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Concentrated Inspections Campaigns (CIC)
Designed by several MOU members to alert owners visiting their ports in
order to promote specific compliance with a convention.
•The previous ISM campaigns in 1998 and 2002 were mainly carried out to
verify if a SMS was established on board.
•The recent ISM campaign from 1 September to 30 November 2007
focussed on the effective implementation of the SMS on board.
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ISM CIC FROM 01/09/07 UNTIL 30/09/07
•
•
•
uniform approach
port state control officers (PSCOs) used a standard checklist/questionnaire.
The following 10 deficiencies were considered as major non-conformities under the CIC:
1. ISM Certificates not on board
2. Safety Management documentation not on board
3. Senior officers unable to identify the designated person responsible for
the ship
4. No procedures to contact the company in emergency situations
5. Stand by equipment or critical equipment not included in the
maintenance routine or tested
6. Relevant safety management information not in a working language or
a language understood by crew members
7. Drills have not been carried out according to programme
8. All detainable deficiencies related to hull, structure or equipment
9. Crew members are not familiar with their duties within the SMS
10. Crew members cannot communicate with each other
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ISM CIC FROM 01/09/07 UNTIL 30/09/07
• a total of 5427 inspections were carried out within the Paris MoU on 5120 ships.
• 1 out of 5 inspections showed ISM deficiencies (non-conformities), corresponding
with 1031 inspections.
• 1868 ISM non-conformities were recorded during the inspections.
• 176 inspections resulted in a detention where one or more major non-conformities
(MNCs) were found.
• Most commonly found MNCs were issued against “effective maintenance of the
ship and equipment”, “emergency preparedness” and “reports of non-conformities
and accident occurrences”
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ISM CIC FROM 01/09/07 UNTIL 30/09/07
FLAG PERFORMANCE
• average detention rate during the campaign was 5.4%.
• The worst performing ships, with a detention rate of 16,2% (which is
three times the average) or higher, were flying the flag of : Albania,
Comoros, Cook Islands, DPR Korea, Sierra Leone, Slovakia, St
Vincent and the Grenadines and Syrian Arab Republic.
• The best performing ships, with a detention rate of 0%, were flying
the flag of: Azerbaijan, Belgium, Bermuda, China, Denmark, Faroe
Islands, Finland, France, India, Ireland, Latvia, Luxembourg, Isle of
Man, Philippines, Spain, Thailand, and United States of America.
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OFFICIAL CONCLUSION
‘’Although some serious problems were encountered in general it
can be said that the last CIC shows that the ISM system is
working onboard ships. Both ship-owners and crew on board
understand the system and implement it. The Paris MoU will
keep monitoring the implementation of the management
systems to ensure the ISM requirements are complied with.’’
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PROBLEMS REPORTED IN ISM IMPLEMENTATION
• Too much paperwork
• Voluminous procedures manuals
• Irrelevant procedures
• Bought -off-the-shelf systems
• No feeling of involvement in the system
• Ticking boxes in checklists (without actually carrying out the required task)
• Not enough people to undertake all the extra work involved
• Not enough time to undertake all the extra work involved
• Inadequately trained people
• Inadequately motivated people
• No support from the Company
• No perceived benefit compared with the input required
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2500 Paris MOU Codes ISM related deficiencies
2510
2515
2520
2525
2530
2535
2540
2545
2550
2555
2560
2565
2599
safety and environmental policy
company responsibility and authority
designated person(s)
masters responsibility and authority
resources and personnel
development of plans for shipboard operations
emergency preparedness
reports and analysis of non-conformities
maintenance of the ship and equipment
documentation
company verification, review and evaluation
certification, verification and control
other (ISM)
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Paris MOU Codes for actions taken
18
Non-conformity rectify within 3 months (now ‘G’)
19
Major non-conformity rectify before departure (now ‘H’)
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NUMBER OF INSPECTIONS (PARIS MOU)
25000
20000
22877
17643
18399
18559
18681
19766
20309
20316
21302
21566
15000
10000
5000
0
1998 1999 2000 2001 2002 2003 2004 2005 2006 2007
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NUMBER OF INDIVIDUAL SHIPS INSPECTED (PARIS
MOU)
16000
14182
14000
12000
11358
11168 11248
11658
11823
12382
12538
13024
13417
10000
8000
6000
4000
2000
0
1998 1999 2000 2001 2002 2003 2004 2005 2006 2007
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NUMBER OF DEFICIENCIES OBSERVED (PARIS MOU)
80000
67735
70000
60000
60670
68756
69079
74713
71928
64113
66142
62434
57831
50000
40000
30000
20000
10000
0
1998 1999 2000 2001 2002 2003 2004 2005 2006 2007
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NUMBER OF DETENTIONS (PARIS MOU)
1800
1600
1400
1684
1598
1764
1699
1577
1431
1187
1200
1000
800
600
1174
1250
994
400
200
0
1998 1999 2000 2001 2002 2003 2004 2005 2006 2007
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Deficiency Analysis by Group
0700 : Fire safety measures
16.29%
0900 : Safety in general
11.68%
1400 : Propulsion and auxiliary machinery
11.06%
0600 : Life saving appliances
9.68%
1200 : Load lines
7.91%
1500 : Safety of navigation
7.76%
2500 : ISM related deficiencies
4.98%
1700 : MARPOL - annex I
4.85%
0100 : Ship`s certificates/logbooks
4.73%
1600 : Radio
3.65%
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Follow-up Actions
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Correction (Immediate Action) can be defined as “action to eliminate
a detected non-conformity” (ISO 9000:2000)
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Corrective action can be defined as “action to eliminate the cause of
a detected nonconformity”, taking into account that there can be more
than one cause for a non-conformity. (ISO 9000:2000)
•
Preventive action can be defined as “action to eliminate the cause of
a potential nonconformity”, taking into account that there can be more
than one cause for a potential non-conformity. (ISO 9000:2000)
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EXAMPLE:
• A lifeboat engine does not start properly during a PSC drill.
• This is corrected immediately by repair and this is the correction.
• The cause of the event could be any of the following: lack of
maintenance, faulty fitting, faulty design, faulty preparation, lack of
training etc. Let us suppose in this instance that the operator was
inexperienced, and that in fact there was no mechanical fault.
Identified cause of non-conformity - lack of training. Corrective
action - ensure practical lifeboat engine training.
• Possible Preventive Action could be to introduce a programme of
on-board lifeboat training for seafarers for all vessels managed by the
company and monitor this through internal audits etc.
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Words of advice
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No one should expect to benefit from a Substandard ship, so all
parties involved should endeavour to either remedy its condition or
restrict its operation
•
PSCOs are NOT “the enemy”.
Their tasks are mandated by the International Conventions and law.
•
Not all ships are “suspect” by default.
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In general, co-operative attitudes are of benefit to all.
•
Class timely involvement at PSC inspections helpful to all
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