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Inspection Report Replies

Inspection Report Replies. REPLIES TO SIRE (and other) INSPECTION OBSERVATIONS Revised: 31 January 2003. Inspection Report Replies. Note:

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Inspection Report Replies

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  1. Inspection Report Replies REPLIES TO SIRE (and other) INSPECTION OBSERVATIONS Revised: 31 January 2003

  2. Inspection Report Replies Note: The following presentation represents the policies of Koch Shipping only, and may not reflect the procedures or opinions of any other SIRE user or OCIMF member.

  3. Inspection Report Replies Assumption: The quality of the replies to SIRE inspection comments or deficiencies is a measure of owner management quality.

  4. Inspection Report Replies When the SIRE inspector leaves the gangway, the vessel inspection is finished; NOW the vetting of the vessel’s management begins …………….

  5. Inspection Report Replies How is the owner going to be vetted for “fitness”? By the vetting manager’s subjective assessment of the quality of the owner’s replies to comments about his ship’s latest inspection.

  6. Inspection Report Replies “Fitness”: The vessel, crew and her owners are part of a team of resources that must “fit” together to maximize the profit of the trader’s oil trade (the “deal”).

  7. Inspection Report Replies The players on the team that carries the oil trader’s deal are: • cargo scheduler (operations assistant of the trader) • charterer’s vessel operations coordinator • cargo insurance broker and underwriter • charterer’s P&I Club • independent petroleum inspectors • measurement field agents - cargo auditors • port agents • charterer’s chartering manager • vessel, master, officers and crew • vessel owner and technical managers • vetting manager • vessel class society

  8. Inspection Report Replies We are all servants of the cargo trader .. His deals pay for all of our activities. What does he want …….. ?

  9. Inspection Report Replies The trader’s #2 objective: Competitive cost ……. A charter rate that is better than market. What is the trader’s #1 objective ……..?

  10. Inspection Report Replies OPTIONALITY! The ability to deliver the cargo anywhere the ship can safely go.

  11. Inspection Report Replies So the ships that make the most money for us are not necessarily the cheapest … but the ones that are universally accepted. They offer the greatest optionality to the trader.

  12. Inspection Report Replies The amount of money Koch makes on every vessel rejected during vetting is: Absolutely nothing! The added-value product of every vetting system is a pool of approved vessels.

  13. Inspection Report Replies Many otherwise acceptable vessels do not pass vetting because the owner’s replies to the SIRE report do not provide “closure” of the indicated conditions. Approval is delayed or denied.

  14. Inspection Report Replies So …. please help me help you get your ship accepted! Send the inspecting company, SIRE (and/or me), report responses that show us: acceptance & respect for the system.

  15. Inspection Report Replies Help me help you get accepted! Send responses that show: acceptance & respect for the system. a living Safety Management System that takes every deficiency seriously.

  16. Inspection Report Replies Send responses that show: acceptance & respect for the system. an active Safety Management System that takes every Report seriously. a reply that: identifies the root cause of the deficiency fixes the existing cause of the deficiency identifies changes to operating procedures to reduce the chance of the deficiency occurring again.

  17. Inspection Report Replies Some replies which are not accepted: • “Rectified.” ….. (trust me!?) ….

  18. Inspection Report Replies Some replies which are not acepted: • “Rectified.” • “when convenient”… (spending money is never convenient!)

  19. Inspection Report Replies Some replies which are not accepted: • “Rectified.” • “when convenient” • “at the earliest opportunity”

  20. Inspection Report Replies Some replies which are certified D.O.A.: • “Rectified.” • “when convenient” • “at the earliest opportunity” • “We have reminded the Master/Chief ...”

  21. Inspection Report Replies Some replies which are not accepted: • “Rectified.” • “when convenient” • “at the earliest opportunity” • “We have reminded the Master/Chief ...” • “The parts have been delivered on board.”

  22. Inspection Report Replies Some replies which are not accepted: • “Rectified.” • “when convenient” • “at the earliest opportunity” • “We have reminded the Master/Chief ...” • “The parts have been delivered on board.” • “He has been cautioned and instructed ...”

  23. Inspection Report Replies A world-class response includes: The Report (SIRE), number and text repeated.

  24. Inspection Report Replies A world-class response includes: The Report (SIRE), number and text repeated. A convincing statement that the root cause has been sought and found - (see: Analytic Trouble Shooting).

  25. Inspection Report Replies A world-class response includes: The Report (SIRE), number and text repeated. A convincing statement that the root cause has been sought and found - (see: Analytic Trouble Shooting). A statement that corrective action has been completed, (or will be completed by a stated date).

  26. Inspection Report Replies A world-class response includes: The Report (SIRE), number and text repeated. A convincing statement that the root cause has been sought and found - (see: Analytic Trouble Shooting). A statement that managers possess, “objective evidence”, sufficient to prove that the Report is closed (or will be completed by a stated date). A statement of action taken to avoid a repetition of the observation in the future (SMS change, etc.).

  27. Inspection Report Replies “Objective evidence” A document, report, message, completed checklist copy, note, or certificate in your files, that you can show me when I come to visit your offices. Something that “closes the loop” on the deficiency!

  28. Inspection Report Replies The corrective action (ISM), cycle: Identify & record the non-confomity. Find the root cause(s). Develop effective corrective action. Implement the corrective action. Revise procedures. Complete the closure process.

  29. Inspection Report Replies Helpful hint: Refer to specific parts of your Safety Management System whenever possible when writing your SIRE report replies … is shows that you really believe in the ISM system.

  30. Inspection Report Replies Bad example #1 Report: “The vessel does not have a vapor release response plan.” Reply: “The vessel’s vapor release response plan is included in section 8.3.2 of the vessel’s ISM Manual.”

  31. Inspection Report Replies Bad example #1 Better reply: + Recognizing that the Master was not aware of the location of the vapor release plan within our SMS manual, we sent our superintendent on board 11 Oct 02, and he conducted SMS training with all officers so that they are now fully aware of all contents of our SMS procedures manual.

  32. Inspection Report Replies Bad example #2 Report: “The main engine is covered with oil.” Reply: “The main engine has been cleaned.”

  33. Inspection Report Replies Bad example #2 Better reply: During the shipyard period Nov 02, we have arranged for a factory representative to supervise work to eliminate all fuel and lube oil leaks from the main engine, after which the engine will be repainted.

  34. Inspection Report Replies Bad example #3 Report: The IGS oxygen sensor bubbler was found without any water in it while the vessel was discharging. Reply: “The bubbler was filled with water immediately.”

  35. Inspection Report Replies Bad example #3 Better reply: The engineers pre-discharge checklist has been amended to include an item to verify that the IG sensor bubbler is filled to correct operating level prior to starting the cargo transfer. SMS section 13.6, revised 11 October 2002.

  36. Inspection Report Replies Bad example #4 Report: A June inspection found a C-of-C issued Feb, due in July: “vessel to submit results of stern tube lube oil analysis”. Reply: “Condition of class will be attended to in due course.”

  37. Inspection Report Replies So, Saying: “we fixed the deficiency” may no longer be sufficient to close an inspection observation, but …..

  38. Inspection Report Replies Saying: “we fixed the deficiency and we fixed the reason that the deficiency existed, (giving details).” is truly impressive and indicates the presence of an active Safety Management System.

  39. Inspection Report Replies Suggested answer format: 5.11 - no fire detection test kit root cause: used but not ordered corr action: test kit supplied preventive action: added “spare test kit on board” to monthly safety equipment inventory PMS

  40. Inspection Report Replies All SIRE report replies are important, but reports with a large number of conditions listed deserve special attention by the owner’s vetting manager. More “conditions” = less chance of approval:

  41. Inspection Report Replies Koch SIRE report grading system - score distribution: vetting number % of number % active score of ships total approved approved 10 60 5% 40 83% 9 230 18% 185 90% 8 335 26% 235 78% 7 190 15% 115 64% 6 110 8% 40 42% 5 100 8% 35 45% 4 140 11% 0 3 80 6% 0 2 40 3% 0 1 20 2% 0

  42. Inspection Report Replies Summary: Koch uses the owner’s replies to detect the presence (or absence), of an active management system that is necessary to provide a reliable vessel, and a reliable transportation partner, for routine cargo transport AND in the event of an incident.

  43. Inspection Report Replies We also try to detect from the SIRE replies whether or not the owner’s management culture includes a positive, helpful, service-oriented attitude …. always preferring an owner who would rather be helpful than be right. Because ….

  44. Inspection Report Replies It is apparent from government initiatives, legal cases and post incident comment, that regulators would like to consider the shipowner and the charterer as co-venturers (partners), in the oil transportation voyage, and jointly responsible for its outcome.

  45. Inspection Report Replies Events which demonstrate this point of view include: Erica Cerda Neptune Dorado September 18, 2002 Prestige - November 2002

  46. Inspection Report Replies Events which demonstrate this point of view include: Erica: owner invisible - charterer took the heat. Cerda Neptune Dorado September 18, 2002

  47. Inspection Report Replies Events which demonstrate this point of view include: Erica Cerda: detained in Europe - charterer was named in the press. Neptune Dorado September 18, 2002

  48. Inspection Report Replies Events which demonstrate this point of view include: Erica Cerda Neptune Dorado: detained San Francisco - FBI visited the charterer. September 18, 2002

  49. Inspection Report Replies Events which demonstrate this point of view include: Erica Cerda Neptune Dorado September 18, 2002: the USCG 96 hr Notice of Arrival must now include name & address of the charterer.

  50. Inspection Report Replies Events which demonstrate this point of view include: Prestige - Sank in November 2000; Koch named by Reuters in December as charterer of a similar “black-listed ship.”

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