PORT STATE CONTROL & ISM COMPLIANCE - 10 YEARS AFTER THE INITIAL IMPLEMENTATION 10 DECEMBER 2008

1. 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

2. What is Port State Control? A SYSTEMdesigned 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)

3. The substandard ship defined as: • “A ship whose hull, machinery, equipment, or operational safety issubstantially 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.)

4. 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.

6. What PSCOs are guided to look for: IMO Resolution 787(19) A well maintained ship with … • 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

7. If all is well……. The PSCOs will probably go elsewhere…. If not !!!…. They probably have : “CLEAR GROUNDS” for a “MORE DETAILED INSPECTION”

8. Paris MOU“Mandatory Expanded Inspections” • Introduced by the EU Directive 2001/106/EC(Obligatory to EU countries from 30-06-96 • Mandatory to all “high risk” vessels within Paris MOU every12 months • High Risk vessels: • 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.)

9. 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.

10. 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

11. 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”

12. 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.

13. 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.’’

14. 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

15. 2500 Paris MOU Codes ISM related deficiencies 2510 safety and environmental policy 2515 company responsibility and authority 2520 designated person(s) 2525 masters responsibility and authority 2530 resources and personnel 2535 development of plans for shipboard operations 2540 emergency preparedness 2545 reports and analysis of non-conformities 2550 maintenance of the ship and equipment 2555 documentation 2560 company verification, review and evaluation 2565 certification, verification and control 2599 other (ISM)

16. Paris MOU Codes for actions taken 18 Non-conformity rectify within 3 months (now ‘G’) 19 Major non-conformity rectify before departure (now ‘H’)

17. NUMBER OF INSPECTIONS (PARIS MOU)

18. NUMBER OF INDIVIDUAL SHIPS INSPECTED (PARIS MOU)

19. NUMBER OF DEFICIENCIES OBSERVED (PARIS MOU)

20. NUMBER OF DETENTIONS (PARIS MOU)

21. Deficiency Analysis by Group

22. Follow-up Actions • Correction (Immediate Action) can be defined as “action to eliminate a detected non-conformity” (ISO 9000:2000) • 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)

23. 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.

24. Words of advice • 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. • In general, co-operative attitudes are of benefit to all. • Class timely involvement at PSC inspections helpful to all