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Anti-fouling Systems—Port State Control Inspection. Huang Tianbing Marine Biosafety Section Bangkok, June 2009. Views expressed in this presentation are those of the author and should not be construed as necessarily reflecting the views of IMO or its Secretariat.
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Anti-fouling Systems—Port State Control Inspection Huang Tianbing Marine Biosafety Section Bangkok, June 2009 Views expressed in this presentation are those of the author and should not be construed as necessarily reflecting the views of IMO or its Secretariat.
AFS—Port State Control Inspection • ARTICLE 11 - Inspections and detections of violations • May be carried out in any Port, shipyard or offshore terminal to determine compliance with the Convention
AFS—Port State Control Inspection • ARTICLE 11 (continue) • A brief sampling is included in the process of initial inspection. • The time required to process the result of such sampling shall not be used as a basis for preventing the movement and departure of the ship
AFS—Port State Control Inspection • ARTICLE 13 - Undue delay or detention of ships • All possible efforts shall be made to avoid a ship being unduly detained or delayed • When being unduly detained or delayed, it shall be entitled to compensation for any loss or damage suffered
AFS—Port State Control Inspection Guidelines for inspection of anti-fouling systems on ships, adopted by resolution MEPC.105(49); Guidelines for brief sampling of anti-fouling systems on ships, adopted by resolution MEPC.104(49).
AFS—Port State Control Inspection • Reference should also be made to: • - Procedures for port State control (resolution A.787(19), as amended by resolution A.882(21)) ; • - Procedure developed by regional PSC MoUs
AFS—Port State Control Inspection • MEPC.105 (49) • Initial inspection • Detailed inspection • Violation detection
AFS—Port State Control Inspection • Tokyo MoU • Initial inspection • Detailed inspection • Violation detection
AFS—Port State Control Inspection • Initial inspection • - ships of Parties to the AFS Convention • IAFS Certificate or • Declaration on anti-fouling system • - ships of Non-Parties • Statement of compliance or • other documentation
AFS—Port State Control Inspection • PSCO should verify: • - the certificate is properly completed • - initial survey matches the drydock period • - only one tick-box in the IAFS is marked • - Record of anti-fouling system is up-to date
AFS—Port State Control Inspection • More Detailed inspection • clear grounds warrant a detailed inspection: • - the ship is from a flag of a non-party to the convention and there is no AFS documentation; • - the ship is from a flag of a party to the convention but there is no valid IAFS Certificate; • - the painting date shown on the IAFS Certificate does not match the drydock period of the ship; • - the ship’s hull shows excessive patches of different paints; and • - the IAFS Certificate is not properly completed.
AFS—Port State Control Inspection • If the IAFS Certificate is not properly completed the following questions may be pertinent: • - When was the ship’s anti-fouling system last applied? • - If the anti-fouling system is controlled under Annex 1 to AFS 2001 and was removed, what was the name of the facility and date of the work performed?; • - If the anti-fouling system is controlled under Annex 1 of AFS 2001 and has been covered by a sealer coat, what was the name of the facility and date applied?; • .
AFS—Port State Control Inspection • If the IAFS Certificate is not properly completed the following questions may be pertinent (continue): • - What is the name of the anti-fouling/sealer products and the manufacturer or distributor for the existing anti- fouling system? And • - If the current anti-fouling system was changed from the previous system, what was the type of anti-fouling system and name of the previous manufacturer or distributor?
AFS—Port State Control Inspection • More Detailed inspection • - sampling and analysis may be included, subject to practical feasibility or to constraints relating to the safety of persons, the ship or the port; • - sample may be taken by contracted specialist company or trained PSCO
AFS—Port State Control Inspection • More Detailed inspection • sampling methodology • The guidelines to the Convention allow that any other scientifically recognized method of sampling and analysis of AFS controlled by the Convention than those described in the appendix to the Guidelines may be used (subject to the satisfaction of the Administration or the port State).
AFS—Port State Control Inspection • Sample analysis • - It is to the discretion of the Authority to choose which analysis methods are used; • - a portable X-ray fluorescence analyzer or any other scientifically justified method allowing on-site analyses could be considered best practice; • - only make conclusions on compliance based on the second stage (organotin) analysis of the sample
AFS—Detention • Detention could be appropriate in any of following cases: • .1 certificate is invalid or missing; • .2 ship admits it does not comply with Convention • .3 sampling proves that it is non-compliant