Alert on detainable deficiencies

Following a recent Port State Control (PSC) inspections in all (MOU)s, seven deficiencies have been imposed that resulted in the detention of the vessels. We wish to draw attention to these detainable deficiencies to avoid re-occurrence

Emergency equipment for 2-way communication

The battery of the emergency equipment for 2-way communication was found expired. Ship Owners/ Managers / Operators are reminded on the requirements of the emergency equipment.

The equipment should be portable and capable of being used for on-scene communication between survival craft, between survival craft and ship and between survival craft and rescue unit. It may also be used for on-board communications when capable of operating on appropriate frequencies.

The equipment should:

 be capable of being operated by unskilled personnel;

 be capable of being operated by personnel wearing gloves as specified for immersion suits in regulation 33 of chapter III of 1974 SOLAS Convention;

 be capable of single-handed operation except for channel selection;

 withstand drops on to a hard surface from a height of 1 m;

 be watertight to a depth of 1 m for at least 5 min;

 maintain watertightness when subjected to a thermal shock of 45°C under conditions of immersion;

 not be unduly affected by seawater, or oil, or both;

 have no sharp projections which could damage survival craft;

 be of small size and light weight;

 be capable of operating in the ambient noise level likely to be encountered on board ships or in survival craft;

 have provisions for its attachment to the clothing of the user;

 be resistant to deterioration by prolonged exposure to sunlight; and

 be either of a highly visible yellow/orange colour or marked with a surrounding yellow/orange marking strip.

The source of energy should be integrated in the equipment and may be replaceable. In addition, provision may be made to operate the equipment using an external source of electrical energy.

Equipment for which the source of energy is intended to be user-replaceable should be provided with a dedicated primary battery for use in the event of a distress situation. This battery should be equipped with a non-replaceable seal to indicate that it has not been used.

The primary battery should have sufficient capacity to ensure 8-hour operation at its highest rated power with a duty cycle of 1:9. This duty cycle is defined as 6-second transmission, 6-second reception above squelch opening level and 48-second reception below squelch opening level.

Line-throwing appliances

During the PSC inspection it was noted that the line-throwing appliances were found expired.

A line-throwing appliance complying with the requirements of section 7.1 of the LSA Code shall be provided.

Every line-throwing appliance shall:

 be capable of throwing a line with reasonable accuracy;

 include not less than four projectiles each capable of carrying the line at least 230 m in calm weather;

 include not less than four lines each having a breaking strength of not less than 2 kN; and

 have brief instructions or diagrams clearly illustrating the use of the line-throwing appliance.

The rocket, in the case of a pistol-fired rocket, or the assembly, in the case of an integral rocket and line, shall be contained in a water-resistant casing. In addition, in the case of a pistol-fired rocket, the line and rockets together with the means of ignition shall be stowed in a container which provides protection from the weather.

Bridge Distress Flares

During the PSC inspection it was noted that the bridge distress flares were found expired.

LSA Code covering the distress flares requires that not less than 12 rocket parachute flares, complying with the requirements of section 3.1 of the Code, shall be carried and be stowed on or near the navigation bridge.

The rocket parachute flare shall:

 be contained in a water-resistant casing;

 have brief instructions or diagrams clearly illustrating the use of the rocket parachute flare printed on its casing;

 have integral means of ignition; and

 be so designed as not to cause discomfort to the person holding the casing when used in accordance with the manufacturer's operating instructions.

The rocket shall, when fired vertically, reach an altitude of not less than 300 m. At or near the top of its trajectory, the rocket shall eject a parachute flare, which shall:

 burn with a bright red colour;

 burn uniformly with an average luminous intensity of not less than 30,000 cd;

 have a burning period of not less than 40 s;

 have a rate of descent of not more than 5 m/s; and

 not damage its parachute or attachments while burning.

S-VDR Certificate missing / label indicates outdated last annual survey

The purpose of a simplified voyage data recorder (S-VDR) is to maintain a store, in a secure and retrievable form, of information concerning

the position, movement, physical status, command and control of a vessel over the period leading up to and following an incident having an impact thereon. Information contained in an S-VDR should be made available to both the Administration and the shipowner. This information is for use during any subsequent investigation to identify the cause(s) of the incident.

An S-VDR with capabilities not inferior to those defined in these performance standards is required to be fitted to ships of classes defined in SOLAS chapter V, as amended.

Civil Liability for Bunker Oil Pollution

The Civil Liability for Bunker Oil Pollution was found as a damaged copy on board.

The owner of a ship registered in a Contracting State and carrying more than 2,000 tons of oil in bulk as cargo shall be required to maintain insurance or other financial security, such as the guarantee of a bank or a certificate delivered by an international compensation fund, in the sums fixed by applying the limits of liability prescribed in Article V, paragraph 1 to cover his liability for pollution damage under this Convention

A certificate attesting that insurance or other financial security is in force in accordance with the provisions of this Convention shall be issued to each ship after the appropriate authority of a Contracting State has determined that the requirements of paragraph 1 have been complied with. With respect to a ship registered in a Contracting State such certificate shall be issued or certified by the appropriate authority of the State of the ship's registry; with respect to a ship not registered in a Contracting State it may be issued or certified by the appropriate authority of any Contracting State. The certificate shall be in the form of the annexed model and shall contain the following particulars:

 name of ship and port of registration;

 name and principal place of business of owner;

 type of security;

 name and principal place of business of insurer or other person giving security and, where appropriate, place of business where the insurance or security is established;

 period of validity of certificate which shall not be longer than the period of validity of the insurance or other security.

The certificate shall be in the official language or languages of the issuing State. If the language used is neither English nor French, the text shall include a translation into one of these languages.

The certificate shall be carried on board the ship and a copy shall be deposited with the authorities who keep the record of the ship's registry or, if the ship is not registered in a Contracting State, with the authorities of the State issuing or certifying the certificate.

Main Engine Oil Mist detector alarm inoperative

As per the Unified Interpretation of SOLAS Regulation II-1/27.5, the Oil Mist Detector arrangements (or engine bearing temperature monitors or equivalent devices) are part of the automatic shut-off arrangements required by SOLAS regulation II-1/27.5, in the case of medium and high-speed diesel engines of 2,250 kW and above or having cylinders of more than 300 mm bore.

For the case of low speed diesel engines of 2,250 kW and above or having cylinders of more than 300 mm bore, the OMD arrangements (or engine bearing temperature monitors or equivalent devices) should initiate the alarm and slow down procedures.

The consequences of overriding automatic shut-off arrangements should be established and documented.

Oil water and fuel oil separators observed illegal connections

Oil residue (sludge) tanks must have no discharge connections to the bilge system, oily bilge water holding tank(s), tank top or oily water separators.

EU MRV Regulation

The first monitoring period has commenced

As of 01/01/2018 every ship above 5,000 GT irrespective of flag undertaking one or more commercial voyages into, out of or between EU ports shall monitor emissions, falling under the scope of the EU MRV Regulation, on a per-voyage basis and aggregate the voyage data in an annual report.

The monitoring on a per-voyage basis shall cover the following parameters:

 Port of departure and port of arrival, including the date and hour of departure and arrival

 Amount and emissions factor for each type of fuel consumed in total

 CO2 emitted

 Distance travelled

 Time spent at sea

 Cargo carried

 Transport work, which is defined as: distance travelled x cargo carried

The EU MRV Regulation allows for exemption from the per-voyage monitoring when all the ship’s voyages during the reporting period either start from or end at a port under the jurisdiction of an EU Member State and the ship performs more than 300 voyages during the reporting period. In case your ship falls under this exemption it shall already be indicated under Table C.3 of the assessed monitoring plan.

The EU MRV Regulation applies to commercial voyages only, which means any ship that calls at an EU port to:

 load/unload cargo, or

 ballast voyage, or

 embark/ disembark passengers.

On the other hand, ships' movements that do not serve the purpose of transporting cargo or passengers for commercial purposes are not subject to EU MRV Regulation, for example dry docking, maintenance, relieving crew etc.

It is also important to note that for voyages starting in previous calendar year and ending in the next calendar year, the data are to be reported under the first calendar year. For example, a voyage starting from Limassol on 28th of December 2018 and ending in Piraeus on 02nd of January 2019 must be included in the 2018 annual report.