Most Frequent Detainable Deficiencies (Tokyo MOU Reports)

2013

2014

PSC Deficiencies Load Line

Recent PSC Reports on an ABS Classed Double Hull Oil Carrier and
Double Hull Bulk Carrier.

Q: Which LL Reg identifies guardrail; requirements & what are they??

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PSC Deficiencies Load Line (Annex I, Chp II, Reg 25)

Regulation 25(2): Guard rails or bulwarks shall be fitted
around all exposed decks.
Regulation 25(3): Guardrails fitted on superstructure
and freeboard decks shall have at least three courses.
Regulation 25(3b): At least every 3rd stanchion shall
be supported by a bracket or stay.

PSC Deficiencies Load Line Marks

PSC Deficiencies Load Line Marks

At Annual LL Surveyor Surveyor to confirm: The freeboard marks are to be sighted,
found plainly visible, and recut and/or painted in accordance with the LL Certificate as
required. The LL Certificate is to be examined for accuracy.

PSC Deficiencies Navigation

PSC Deficiencies Navigation

Port State Control Trending

ISM related

Maintenance of the ship and equipment

Development of plans for shipboard operations
Emergency preparedness
Masters responsibility and authority
Safety and environment policy
Reports and analysis of nonconformities,
accidents and hazardous occurrences
Documentation
STCW
MLC

CIC STCW Recording of rest hours

Port State Control Trending

Main & Auxiliary Machinery

Propulsion main engine

Auxiliary engine

Cleanliness of engine room

Insulation soaked (oil)

Bilge pumping arrangements

Guards around machinery

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Port State Self-Closing Sounding Pipe Head Without test cock

2006 built Bulk at Xiamen, P.R. China, Sept14. PSC Inspector raised
raised this deficiency as a Code 17.

ABS Surveyor attended the vessel and reported:

Fuel tank sounding pipes are fitted with self-closing weighted devices &
with a screwed plug instead of a small-diameter self-closing test cock.

Rectification (Temporary)

All of screw plugs were drilled with a through (axial and radial) hole which
would allow a check on overflow level of the tank.(See below pictures)

Attending PSCO agree with delete the code 17 (Rectify deficiency before
departure) with OSR issued by ABS with a due day of three months for
permanent repair.
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Screwed plug with a through hole and sounding pipe head.

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SOLAS & ABS Rule requirement

SOLAS: Chapter II-2/Part B/ Reg.4 /2.2.3.5.3
The termination of sounding pipes are fitted with self-closing blanking
devices and with a small-diameter self-closing control cock located
below the blanking device for the purpose of ascertaining before the
blanking device is opened that oil fuel is not present.

ABS Rule SVR 4-6-4/11.3.7(a) ii)

The termination of sounding pipes is fitted with a quick-acting selfclosing valve and with a small diameter self-closing test cock or
equivalent located below the self-closing valve for the purpose of
ascertaining that fuel oil is not present before the valve is opened.
Provisions are to be made to prevent spillage of fuel oil through the test
cock from creating an ignition hazard.

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Serious Violations

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Serious Violations

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Port State Control Trending

MARPOL items Annex I

Oil Record Book

Oil filtering equipment
Shipboard oil pollution emergency plan
(SOPEP)
Oil discharge monitoring and control
system (ODMC)
Control of discharge of oil
15 ppm alarm arrangements
Retention of oil on board
Suspected discharge violations

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Oil Record Book (O.R.B.) Mandatory Entries

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Oil Record Book (O.R.B) - Deficiencies

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Oil Filtering Equipment

Examination. ABS action Rule requirement

Test of OWS at each Annual Machinery Survey (AMS)
At each Special Periodic Survey of Machinery
OWS opened up for examination system tested

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Port State Control Trending

Stability, structure and related equipment

Steering Gear
Electrical Equipment general
Emergency lighting, batteries and switches
Gangway, Accommodation Ladder
Closing devices / Watertight doors
Stability / Strength / Loading information and
Instrument.
Means of escape
Signs/Indications (WT doors, Fire detectors, fire
dampers, ventilation)
Deck/Hull corrosion, Damages impairing
seaworthiness.

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Commonly Repeated China MSA Deficiencies

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Port State Control Trending

Lifesaving appliances
Lifeboats / stowage
Lifebuoys
Rescue boats
Inflatable life rafts / stowage
Lifeboat inventory
Launching arrangements for survival craft
Operational readiness and maintenance
Embarkation arrangements survival craft
Immersion suits and lifejackets
Onboard training and instructions

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Lifeboats & Launching Appliances

Lifeboats & equipment are a major
issue with Class & PSC

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Open or Locked??

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Hook indicator position external

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Hook indicator position external

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Lifeboats & Launching Appliances

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Lifeboat - freefall

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Lifeboat - freefall

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Lifeboat - freefall

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Lifeboat Seatbelts

LSA code (from MSC 48(66))

4.6.3 Capsizing and re-righting

4.6.3.1. Except in free-fall lifeboats, a safety belt shall be

found at each indicated seating position. The safety belt
shall be designed to hold a person with a mass of 100 kg
securely in place when the lifeboat is in a capsized position.
Each set of safety belts for a seat shall be of a colour
which contrasts with the belts for seats immediately
adjacent. free-fall lifeboats shall be fitted with a safety
harness at each seat in contrasting colour designed to hold
a person with a mass of 100 kg securely in place during a
free-fall launch as well as with the lifeboat in capsized
position.
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Embarkation Ladder Damage

2008 built chemical carrier

2002 built container

carrier
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Embarkation Ladder Damage

2007 built oil carrier

2007 built oil carrier

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Port State Control Trending

Fire

safety measures

Emergency Fire Pump

Fire-dampers
Fire prevention
Firefighting eqpt & appliances
Fire detection
Fixed firefighting installation
Fire pumps
Ready availability of ff eqpt
International shore connection
Jacketed piping for HP fuel line
EEBD

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Port State Control Trending

Safety of Navigation

Nautical publications
Charts
Lights, shapes and sounds
Magnetic compass and Gyro compass
Voyage data recorder (VDR or S-VDR)
Voyage or passage plan
Echo sounding device
Radar
AIS
Rudder angle indicator
Emergency steering position communication and compass
reading
LRIT
Signaling lamp

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Safety of Navigation
ECDIS, Charts and Passage
Planning/Monitoring what is being looked at.

Lack of appropriate, updated, large

scale charts/publications for:
Upcoming voyage
Arrival voyage

Voyage planning / monitoring

Berth to berth
Infrequent position fixing
Position fixing using only one means (eg.
GPS)

Lack of position fixing during pilotage

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China MSA Navigation Deficiencies

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COLREG: Navigation Lights

1998 built container carrier was detained due to:

Horizontal arc of visibility of stern light found not as per COLREG

This is the 2nd time that a vessel has been detained for this deficiency

Existing Stern Light

New Stern Light

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Port State Deficiencies

Items of Concern
Most frequent deficiencies

Ventilators, Funnel Flaps, Air

Pipes

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Common deficiencies associated with Ventilators & Air Pipes

Deficiencies categorized under Fire & Safety

1.
2.
3.
4.
5.
6.
7.
8.
9.
10.

Ventilators holed.
Ventilators repaired with soft patch/tape.
Ventilator cover securing nut broken.
Fire flap handle not easily assessed.
Fire flaps not closing fully.
Funnel dampers not operating properly.
Dampers wasted and holed.
E/R ventilator fire dampers not operational/not closing fully.
Air pipe closing device corrosion, pipe wasted.
E/R vent closing lever seized.

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Louvre Fire Dampers Engine Room Intakes &

Exhaust, including Funnel Flaps

PSC have detained several vessels in China in 2013,2014 &

and now in 2015, due to the operation of engine room & funnel
dampers. Typical deficiency reported has been:
i) Fire damper has gap.
ii) Fire damper cannot close tightly.
iii) Fire damper cannot close from outside.

Following slides show 4 similar PSC deficiencies, of which 3 are

Code 30 (detained) and one is a code 99 (rectify before
departure).
In referencing fire dampers we are referring solely to engine room
intakes/exhausts and funnel flaps and not fire dampers located in
ventilation ducts in fire control boundaries.
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China PSC Reports on fire dampers.

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Typical funnel louvre dampers/flaps

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Highlighting PSC Reports (Case Studies)

1. a) Accommodation Corridors
b) Fuel Oil Tank Valves
c) CO2 Room A-60
2. Emergency Escape Trunks
3. Engine Room Funnel Flaps

Quick Closing Valve of E/G Oil Tank (SOLAS & SVRs)

SOLAS Chapter II-2/Reg.4.2.2.3.4
Oil fuel pipes, which, if damaged, would allow oil to escape
from a storage, settling or daily service tank having a capacity
of 500ltr and above situated above the double bottom, shall be
fitted with a cock or valve directly on the tank capable
SVRs 4-6-4/13.5.3(a) Required valves (2003).
Every fuel oil pipe emanating from any fuel oil tank, which, if
damaged, would allow fuel oil to escape from the tank, is to be
provided with a positive closing valve directly on the tank.

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SVRs 4-6-4/13.5.3(a) (2013) Valves on Fuel Oil Tanks.

Quick closing valve:
PSC Interpretation not supported by Busan Eng as the attachment of
the valve to the tank by a short length of pipe is permitted per the
2013 SVRs. However, based on the contract date for the vessel and
delivery in 2012, the valve should have been fitted directly onto the
tank per the rules at that time. PSC Inspector was actually correct.

Required valves (2013). Every fuel oil pipe

emanating from any fuel oil tank, which, if
damaged, would allow fuel oil to escape from
the tank, is to be provided with a positive closing
valve. The valve is to be secured directly on the
tank. A short length of pipe, with wall thickness
in accordance to Column D of 4-6-2/Table 4,
connecting the valve to the tank is also
acceptable.

Approved drawing
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c) CO2 Pilot Pipe In CO2 Room.

SOLAS Chapter II-2/Reg.9.3.4 & MSC/Circ.1120

PSC Interpretation is not supported by ABS Engineering who have given their
interpretation. And contend that SOLAS Chapter II-2 Regulation 13.4.2.1.1
which clearly states; the ladder shall be fixed in such a way that heat is not
transferred into the enclosure through non-insulated fixing points does not
extend to the brackets as identified in the PSC Report.

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Highlighting PSC Reports (Case Studies)

There have been cases where PSC have correctly
identified deficiencies related to funnel fire dampers of
the louvre design as below. The deficiencies are
usually as a result of the flaps being inoperative and
unable to close. However there are cases where the
PSC Inspector does not appear to fully understand the
requirements and operation of funnel flaps.

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Highlighting PSC Reports (Case Studies)

2012 Built ABS Classed 34K DWT Bulk Carrier detained due to
funnel flaps which cannot be closed tightly. ABS appealed locally this
detention and although the RO was not blamed the detention
remained.

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Highlighting PSC Reports (Case Studies)

SOLAS Reg. II-2/5.2.2.1 "means of control are to be provided

for closure of openings in funnels which normally allow exhaust
ventilation and closure of ventilation dampers".

There are NO requirements for the dampers located in the engine

room funnels to be of the gastight or watertight type (normally
these dampers are located higher than 2.3 m above position 2
and accordingly they are not required to be watertight in
accordance with Load Line requirements).
The funnel flaps are not for forced ventilation they are a natural
means of exhaust. Once they are closed and ER ventilation
shutdown there is no air flow, no pressure differential across the
dampers and if CO2 is released into the machinery space it flows
to the lower levels being heavier than air. Construction tolerances
do not present a problem.
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2.14 Fire Dampers, Ref: 46 CFR 72.05-50, 116.610

The construction specifications in Subchapters H and K

may be applied to fire dampers installed in A-class
divisions on all domestic vessels. The regulations
require fire dampers to have a casing and blade
constructed of at least 3 mm (11 USSG) thick steel, with
a maximum gap of 3 mm (1/8 inch) between the blade
and the casing. The operating components of the
damper such as springs and hinges must be stainless
steel or equivalent corrosion resistant construction.
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